Landlord Gas Safety Record (CP12): what to give tenants, how long to keep it, and the 10–12 month renewal window (London, 2026)

This practical guide explains your duties around the Landlord Gas Safety Record (often called a CP12) in London for 2026: what to give tenants and when, how long to keep records, how the 10–12 month “MOT-style” renewal window works, and how to deal with common issues like tenant access and HMO licensing checks. It is based on the Gas Safety (Installation and Use) Regulations 1998 (Regulation 36) and current HSE guidance. Always check the latest official guidance before acting.

What the law requires in England (London) in 2026

In brief, landlords must:

• Arrange an annual gas safety check on each gas appliance and flue provided by the landlord.
• Give a copy of the gas safety record to existing tenants within 28 days of the check, and to new tenants before they move in. This is the well-known “gas safety certificate 28 days” rule.
• Keep a record of each safety check (paper or digital) for at least two years from the date of that check. See retention nuances below.
• Ensure checks are completed by a Gas Safe registered engineer.

When to give the CP12 to tenants (28-day rule and before move-in)

• Existing tenants: Provide the gas safety record within 28 days of the date of the safety check.
• New tenants: Provide the record before they occupy the property.
• Renewals and periodic tenancies: Treat the current occupant as an “existing tenant” and serve within 28 days after each annual check.

Keep evidence of service (for example, email delivery receipts or signed acknowledgements) in case the council or a tribunal later asks you to prove when and how you served it.

What the record must include (mandatory content)

The gas safety record must include specific information required by Regulation 36(3)(c). A professional CP12 typically contains:

Many records also show a “next check due” date for convenience, though the statutory requirement is the annual interval plus the permitted 10––12 month window described below.

How long to keep it and in what format (paper vs digital)

• Retention: Keep each gas safety record for at least two years from the date of that check. If an appliance or flue is later removed, keep the most recent record relating to it for two years from removal.
• Format: Paper or electronic records are acceptable. Electronic copies should be secure, tamper-evident where possible, and capable of being reproduced in hard copy on request.
• Practical tip: Keep a continuous chain of CP12s. Even though the legal minimum is two years, keeping the last two or more checks helps demonstrate compliance with the renewal window and satisfies most council/HMO licensing audits.

The 2018 amendment: using the 10–12 month window without losing your due date

Since 2018, you can carry out the next annual safety check any time from 10 months to 12 months after the previous check without bringing the renewal date forward. This is often called the “MOT-style” rule.

• Example: Your 2025 CP12 was dated 15 March. In 2026 you can lawfully renew any time between 15 January and 15 March. If you renew on 20 January 2026, the next due date in 2027 still anchors to mid-March (i.e., you don’t lose time by doing it early).
• Not a grace period: It doesn’t let you go past 12 months. Aim to complete the check on or before the anniversary.
• Record-keeping: Keep consecutive records to show there was no gap in compliance.

Emailing and digital CP12s: what’s acceptable and what to avoid

• Serving by email: HSE accepts electronic records and tenant delivery by email, provided tenants can access them. If a tenant prefers post, provide a paper copy.
• Proof of service: Save email timestamps, read receipts, or delivery confirmations. For paper service, use dated cover letters or signed acknowledgements.
• Data protection: Double-check recipient addresses before sending and avoid including unrelated tenant data in attachments.
• Avoid: Messaging apps or formats that are hard to reproduce or store. Keep a master copy in a secure repository.

HMOs and council licensing touchpoints in London

HMOs have extra management and licensing oversight. Typical touchpoints include:

• Produce on request: Under HMO management regulations, you must produce the current gas safety record to the local authority within a set period (commonly within 7 days) if asked.
• Tenant provision: You must still provide each tenant with the CP12 (28 days / before occupation) as per Regulation 36.
• Display: Some borough licences require you to display a copy of the gas safety record in the common parts. This is not universal. Check your specific licence conditions for your London borough and property.
• Communal systems: If the HMO has a communal boiler/flue, ensure that system is included on the CP12. If individual flats or rooms have their own gas appliances or flues, each must be checked and recorded.

Supplying the certificate to the council on request; display requirements in some HMOs

• Be ready to email or upload the latest CP12 promptly when the licensing team requests it.
• If your licence requires display, mount the most recent CP12 in a protective wallet in a common area (e.g., hallway noticeboard) and replace it after each renewal.

Tenant access problems: steps HSE recommends and how to evidence attempts

HSE expects landlords to take reasonable steps to gain access for safety checks. If a tenant refuses or misses appointments:

• Communicate in writing: Send polite letters/emails explaining legal duties and safety reasons. Offer multiple time slots, including evenings/weekends if possible.
• Leave calling cards: If the engineer attends and cannot gain access, leave a card with rebooking instructions.
• Provide contact routes: Offer phone, email, and an online booking option if available.
• Do not force entry: Forced entry is not permitted except under very limited lawful circumstances. Consider legal advice for injunctions only as a last resort.
• Evidence everything: Keep copies of letters, emails, SMS logs, call notes, engineer attendance notes (with timestamps), and photographs of letters delivered where appropriate.

If you ultimately cannot gain access despite reasonable efforts, keep your evidence file. Councils and HSE look for diligence rather than silence.

What to prepare for your CP12 visit

• Ensure the engineer can access all gas appliances, flues, and the gas meter/cupboards.
• Provide previous CP12(s) if available — helpful for cross-checking appliance lists and due dates.
• Make sure prepayment meters have credit and isolation valves are accessible.
• Secure pets and clear obstructions to boilers, fires, or flue inspection hatches.
• Confirm an adult (18+) can provide access for the booked time.
• If any flues are concealed, ensure appropriate inspection hatches are installed for a full visual check.

What happens during the gas safety check

A Gas Safe engineer will verify appliance identity and location, undertake safety tests (e.g., combustion/ventilation checks, burner pressure or gas rate, appliance tightness where relevant), confirm flue integrity and termination, check emergency controls, and visually inspect associated pipework. If an appliance is found unsafe, the engineer will classify it (e.g., Immediately Dangerous or At Risk), make it safe (e.g., cap off), and record this on the CP12 along with remedial recommendations.

Common pitfalls that cause re-visits or enforcement action

• Missing the 28-day service to existing tenants: You must serve the record within 28 days after each annual check.
• Letting the CP12 expire: Book inside the 10–12 month window to protect your anchor date and avoid gaps.
• Incomplete appliance list: Ensure every landlord-provided gas appliance and flue on site is included.
• Poor access planning: No-shows and locked cupboards often waste visits. Confirm access beforehand.
• Concealed flues without hatches: May prevent a pass on the day and require a return visit after hatches are installed.
• Using unregistered engineers: Always verify Gas Safe registration and the engineer’s competence for the appliance type.
• Weak record-keeping: Keep copies of served CP12s and proof of delivery, especially for HMOs and licensed properties.

FAQs

• Can I email the CP12 to tenants?
  Yes. Electronic CP12s are acceptable. Ensure the tenant can access the document, and retain proof of sending. Provide a paper copy if requested.
• Do I need to give a CP12 to prospective tenants or only once they move in?
  Provide it before occupation to the incoming tenant. You do not need to supply it to every enquirer viewing the property.
• How long must I keep gas safety records—2 years or until two further checks?
  The legal minimum is two years from the date of each check. In practice, keep a continuous chain (e.g., the last two or more records) to evidence no gaps and to support the 10–12 month renewal approach.
• Do I need separate CP12s for each unit in an HMO with a communal boiler?
  You need a valid record for the appliances/flues present. A communal boiler/flue can be recorded on one CP12 covering the premises it serves; where individual rooms/flats have their own appliances/flues, each requires its own check and entry on a record for that dwelling.
• What if there’s no gas appliance in a tenant’s room?
  You must still provide a copy of the property’s current gas safety record to each tenant. If there are no landlord-owned gas appliances or flues in the dwelling but a live gas supply remains, you remain responsible for maintaining the pipework. Many landlords commission and retain a tightness test record even where no appliances are present.
• Can I align multiple properties to one renewal month?
  Yes. Use the 10–12 month window to bring checks slightly forward and group renewals by month. Do not exceed 12 months between checks.
• What proof do councils ask for during HMO licensing/renewal?
  Typically: the latest CP12(s), engineer details (Gas Safe reg number), and occasionally the previous certificate to confirm continuity. Some licences require you to display the certificate in common parts. Check your specific licence conditions.
• Does missing the 28-day service to an existing tenant affect possession routes?
  Rules on possession (e.g., Section 21 and any replacements) are subject to legislative change. Seek current legal advice before serving notice.

Booking your CP12 in London: how First Landlord Certificates London (FLCL) can help

We work with Gas Safe registered engineers across London and can help landlords and agents stay compliant with the 28-day service rule and the 10–12 month renewal window.

• Digital records: CP12 supplied as a PDF for easy email service and storage.
• Tenant copies: On request, we can send tenant copies directly once you approve.
• Portfolio scheduling: Ask about grouping renewals across your properties using the MOT-style window.
• Reminders: Renewal reminders to help avoid lapses (e.g., notifications at 10 and 11 months).

Book your CP12 in London or call 07424 498988 to discuss scheduling and tenant access.

Key takeaways

• Serve the CP12 to existing tenants within 28 days and to new tenants before move-in.
• Keep each record for at least two years; maintain a continuous chain of checks.
• Use the 10–12 month window to avoid losing your renewal date and to consolidate portfolios.
• Electronic CP12s and service by email are acceptable with proper record-keeping.
• For HMOs, be ready to show your CP12 to the council promptly and follow any display rules in your licence.
• Document all attempts to gain access if tenants do not cooperate.

This article provides general guidance for London landlords and agents and is not legal advice. Always check current HSE and legislative guidance before acting.