Your Annual Commercial Electrical Compliance Checklist (UK, 2026)

Electrical compliance in UK commercial buildings is not a once-and-done exercise. It is a continuous programme of inspection, testing, and record-keeping that must be managed on an annual cycle - and tracked rigorously across every asset on your portfolio.

For facilities managers responsible for multiple commercial sites, maintaining full electrical compliance is both a legal obligation and an operational risk management priority. This checklist sets out the core elements of an annual commercial electrical compliance programme, the regulations underpinning each requirement, and the practical steps required to maintain a defensible compliance record.

Why Annual Electrical Compliance Matters

Electrical faults are one of the leading causes of fire in UK commercial buildings. According to data published by the Home Office, electrical distribution and appliances account for a significant proportion of accidental fires in non-domestic premises each year. Beyond fire risk, electrical failures create serious risk of electric shock, arc flash, and equipment damage - each with potential consequences for occupant safety, business continuity, and regulatory liability.

The legal duty to maintain electrical safety in commercial premises falls on the duty holder - typically the employer, building owner, or the person responsible for the premises. This duty is not discharged by a single inspection. It requires an ongoing programme of assessment, testing, and remediation, with documented evidence that each element has been addressed.

An annual review cycle is the industry standard baseline. Some elements require more frequent attention; others operate on longer cycles but must be reviewed annually to confirm their continued adequacy.

The Legal Framework: Regulations and Standards

Commercial electrical compliance in the UK is governed by several interconnected pieces of legislation and technical standards:

The Electricity at Work Regulations 1989 (EAWR)

The EAWR places a duty on employers and duty holders to ensure that all electrical systems are constructed, maintained, and used in a manner that prevents danger. Regulation 4(2) requires that electrical systems are maintained to prevent such danger. There is no prescribed frequency for inspection and testing in the Regulations - the duty is to maintain systems so far as is reasonably practicable, which in practice means regular inspection and testing appropriate to the risk.

BS 7671: Requirements for Electrical Installations (18th Edition)

BS 7671 is the national standard for electrical installation design, erection, and verification in the UK. The 18th Edition, incorporating Amendment 2, is the current operative standard. It provides the technical requirements against which electrical installations are assessed during EICR inspections.

BS 5266: Emergency Lighting

BS 5266 sets out the requirements for emergency lighting systems in non-domestic premises, including minimum illumination levels, duration requirements, and testing and maintenance schedules.

BS 5839: Fire Detection and Alarm Systems

BS 5839 provides guidance on the design, installation, commissioning, and maintenance of fire detection and alarm systems. Part 1 covers commercial buildings and specifies inspection and testing intervals.

Electrical Installation Condition Reports (EICR)

The Electrical Installation Condition Report (EICR) sometimes called a periodic inspection report is the foundational document of fixed wire compliance. An EICR assesses the condition of a building's fixed electrical installation against the requirements of BS 7671.

For most commercial premises, an EICR is required every five years, though higher-risk environments may require more frequent inspection. Your fixed wire testing programme should be scheduled in advance to ensure no site falls out of cycle.

In your annual review, the key EICR checks are: confirming the current report is within its recommended re-inspection period; identifying any outstanding code 1 (C1 - danger present) or code 2 (C2 - potentially dangerous) observations and verifying they have been remediated; confirming that any remediation recommended in the report has been completed and recorded; and assessing whether any changes to the installation or the building's use since the last inspection necessitate an earlier re-inspection.

A C1 observation requires immediate remedial action — it represents a condition that poses a direct danger to persons. A C2 requires urgent remediation. Both must be addressed before the installation can be considered compliant. Facilities managers should ensure they have a process for tracking EICR observation status through to resolution.

Portable Appliance Testing (PAT)

Portable Appliance Testing (PAT testing) - assesses the safety of portable electrical equipment used in the workplace. The duty to maintain portable appliances derives from the EAWR and the Provision and Use of Work Equipment Regulations 1998 (PUWER).

There is no single mandated frequency for PAT testing; the Health and Safety Executive (HSE) guidance makes clear that the appropriate frequency depends on the type of equipment, the environment in which it is used, and the results of previous testing.

PAT testing should be scheduled as part of your annual compliance calendar, with frequencies set by risk assessment.

In your annual review: confirm that all portable appliances in use at each site have been tested within the appropriate interval for their risk category; verify that failed or quarantined items have been withdrawn from use and either repaired or disposed of; and check that records identify each item tested, the test result, the date, and the identity of the tester.

Equipment used in demanding environments - kitchens, workshops, outdoor areas - requires more frequent inspection than office equipment used in a controlled environment. Your PAT schedule should reflect this differentiation.

Emergency Lighting Testing and Certification

Emergency lighting is a life-safety system. Under BS 5266, emergency lighting in commercial buildings must be tested monthly (a brief functional test) and annually (a full-duration discharge test of three hours for maintained systems). Emergency lighting testing must be recorded and the records retained as part of your compliance evidence.

In your annual review: confirm that monthly functional tests have been carried out and recorded throughout the year; commission and document the annual full-duration discharge test; verify that all luminaires have achieved the required duration and illumination levels; identify any failed units and confirm they have been replaced or repaired before being returned to service; and check that the emergency lighting log book is up to date.

BS 5266 also requires that the responsible person ensures emergency lighting is adequate for the escape routes and high-risk task areas in the building, taking account of any changes to the building layout or use since the system was last assessed. If the building has undergone refurbishment or change of use, a reassessment of emergency lighting adequacy should be included in the annual review.

Fire Alarm Inspection and Testing

Under BS 5839-1, fire detection and alarm systems in commercial premises must be tested weekly (a brief test of one call point), inspected and tested by a competent person at six-monthly intervals, and subject to a full annual inspection. The annual inspection covers all detection devices, manual call points, sounders, control and indicating equipment, and power supplies.

In your annual review: confirm that weekly tests have been carried out and logged throughout the year; confirm that the six-monthly inspections have been completed by a competent contractor; review the annual inspection report for any recommendations or deficiencies; and verify that any remediation identified has been completed and documented.

Changes to building layout - new partition walls, extended cable containment, modified occupancy - may affect detector coverage and require a system reassessment. This should be flagged and assessed as part of the annual review.

Thermographic Surveys: Identifying Hidden Electrical Risk

Thermographic (infrared) surveys use thermal imaging cameras to identify hotspots in electrical installations - distribution boards, switchgear, cable connections, and busbars - that indicate overloading, loose connections, or deteriorating insulation.

These risks are invisible to the naked eye and will not be detected during a standard EICR unless they are severe enough to produce visible signs of damage. A thermal imaging survey carried out under live load conditions provides a uniquely accurate picture of where electrical risk exists in your installation.

For commercial buildings with significant electrical load - manufacturing facilities, data centres, large retail, multi-tenanted offices - an annual thermographic survey of primary distribution equipment is considered best practice and is increasingly expected by commercial insurers as a condition of cover.

In your annual review: schedule a thermographic survey of all main distribution boards, sub-boards, and switchgear; review the survey report for hotspots classified as urgent, significant, or monitor; ensure urgent and significant findings are remediated without delay; and update your asset records with the survey date and findings.

EV Charging Point Inspection and Testing

Electric vehicle charging infrastructure is now a compliance requirement - not just a facilities amenity. The Electric Vehicles (Smart Charge Points) Regulations 2021 set requirements for smart charge point functionality in new installations.

Beyond this, EV charging points must be inspected and tested as part of the overall electrical installation under BS 7671. EV charging point testing should be included in your annual electrical compliance programme as the number of charge points on commercial estates continues to grow.

In your annual review: confirm that all EV charging points have been included in your fixed wire testing scope; verify that any new charge point installations have been designed and certified to BS 7671 and the relevant IET Code of Practice for EV Charging Equipment Installation; check that smart charge point functionality - including demand management - is operating correctly; and confirm that charge point records are maintained and accessible.

Coordination with Your Fire Risk Assessment

Electrical compliance and fire safety are closely interdependent. Electrical faults are a leading cause of commercial building fires, and the findings of your electrical testing programme should be reviewed in conjunction with your fire risk assessment to ensure that electrical risks are properly evaluated and reflected in your overall fire safety management.

In your annual review: confirm that the fire risk assessment has been reviewed and updated within the last 12 months, or following any significant change to the building, its use, or its occupancy; ensure that any significant electrical deficiencies identified through EICR, thermographic survey, or emergency lighting testing are reflected as identified hazards in the fire risk assessment; and verify that the emergency lighting and fire alarm systems are assessed as adequate for the current building configuration.

Facilities managers running multi-site portfolios benefit from ensuring that electrical compliance and fire risk assessment reviews are coordinated - both in terms of timing and in terms of the contractors involved - to produce a coherent, cross-discipline compliance picture.

Record-Keeping: Building Your Compliance Evidence File

The legal value of your electrical compliance programme depends almost entirely on the quality of your records. A completed inspection that is not documented provides no legal protection for the duty holder and no operational visibility for the facilities manager.

Your annual compliance evidence file should contain: current EICR for each site, with a record of any remediation completed; PAT testing records covering all portable appliances, identifying each item, test date, result, and tester; emergency lighting monthly test logs and annual full-duration test certificates; fire alarm weekly test logs, six-monthly inspection reports, and annual inspection certificate; thermographic survey reports with findings and remediation records; and EV charging point installation certificates and inspection records.

Records should be site-specific, dated, and retained for a minimum of five years - or longer where the records form part of an ongoing compliance trail. For higher-risk buildings under the Building Safety Act 2022, these records contribute to the golden thread of building safety information and must be maintained in a form that is accessible to the Building Safety Regulator on request.

Managing Electrical Compliance Across Multiple Sites

For facilities managers responsible for large commercial portfolios, managing electrical compliance across dozens or hundreds of sites presents a significant logistical challenge. The risks of a decentralised approach - where each site manages its own records and scheduling - include missed inspection cycles, inconsistent contractor standards, and fragmented compliance evidence.

A centralised, portfolio-level approach to electrical compliance management delivers significant advantages: a single view of compliance status across all sites; coordinated scheduling to avoid peaks in contractor demand; consistent standards for inspection, testing, and documentation; and the ability to aggregate compliance data for board-level reporting and insurer requirements.

This is particularly relevant for facilities managers procuring compliance services through a single multi-discipline contractor - where passive fire protection surveys, electrical testing, and fire risk assessments can be coordinated across a portfolio on a managed programme basis, delivering consistency of standard and efficiency of mobilisation.

Your Annual Electrical Compliance Action Plan

Use the following checklist as the basis for your annual electrical compliance review across each commercial site in your portfolio:

EICR status: Current report within recommended inspection period? All C1 and C2 observations remediated and documented?

PAT testing: All equipment tested within appropriate risk-based interval? Failed items withdrawn and disposed of or repaired? Records complete and itemised?

Emergency lighting: Monthly functional tests carried out and logged? Annual full-duration test completed, all luminaires passed? Failed units replaced?

Thermographic survey: All primary distribution equipment surveyed under load? Urgent and significant hotspots remediated?

EV charge points: All charge points included in fixed wire testing scope? New installations certified? Smart functionality verified?

Fire risk assessment coordination: FRA reviewed within 12 months? Electrical deficiencies reflected in FRA? Emergency systems assessed as adequate?

Record-keeping: All certificates and reports filed, dated, and site-specific? Records retained for minimum five years? Running through this checklist annually - and acting on the findings - is the foundation of a defensible, effective electrical compliance programme for UK commercial buildings.

Frequently Asked Questions

How often is an EICR required for a commercial building?

For most commercial premises, an EICR is required every five years. However, the appropriate frequency depends on the type of installation, the environment, and the findings of previous inspections. Higher-risk installations - such as those in humid, dusty, or demanding environments - may require inspection more frequently. The EICR report itself will specify the recommended re-inspection period.

Is PAT testing a legal requirement?

There is no specific legal requirement to carry out PAT testing as such, but the Electricity at Work Regulations 1989 place a legal duty on employers to maintain all electrical systems - including portable appliances - to prevent danger. PAT testing is the accepted method for demonstrating that this duty has been discharged for portable electrical equipment.

What is the difference between an EICR and a PAT test?

An EICR assesses the condition of the fixed electrical installation - the wiring, distribution boards, switches, and sockets permanently installed in the building. A PAT test assesses the safety of portable electrical appliances - equipment that is plugged into sockets and can be moved. Both are required as part of a complete electrical compliance programme.

How long does an emergency lighting full-duration test take?

A full-duration discharge test for a maintained emergency lighting system lasts three hours, as required by BS 5266. During this period, the normal supply to the emergency luminaires is interrupted and the system must sustain the required illumination from its battery backup for the full three-hour period. The test should be carried out annually, ideally outside normal building operating hours.

What is a thermographic survey and why is it recommended?

A thermographic (infrared) survey uses thermal imaging cameras to identify hotspots in electrical installations under live load conditions. Hotspots indicate loose connections, overloading, or deteriorating components - risks that are invisible during a standard visual inspection. Thermographic surveys are considered best practice for commercial buildings with significant electrical load and are increasingly required by commercial insurers.

Do EV charging points need to be included in electrical compliance testing?

Yes. EV charging points form part of the building's electrical installation and must be included in the scope of fixed wire testing. In addition, new EV charging point installations must be designed, installed, and certified in accordance with BS 7671 and the IET Code of Practice for EV Charging Equipment Installation.

What records should I keep for electrical compliance?

You should retain current EICRs, PAT testing records for all portable appliances, emergency lighting monthly test logs and annual test certificates, fire alarm weekly test logs and inspection reports, thermographic survey reports, and EV charging point installation and inspection records. Records should be site-specific, dated, and retained for a minimum of five years.

What does a C1 observation on an EICR mean?

A C1 (Code 1) observation on an EICR indicates that danger is present - a condition that poses an immediate risk to persons. C1 observations require immediate remedial action. The installation should not be used until the condition has been rectified. A C2 (Code 2) observation indicates a potentially dangerous condition requiring urgent remediation.

How do I manage electrical compliance across multiple sites?

A centralised, portfolio-level approach is the most effective method. This involves maintaining a single compliance tracker covering all sites, coordinating inspection and testing schedules across the portfolio, using consistent contractor standards, and consolidating compliance records in a single accessible system. Engaging a single multi-discipline contractor to manage compliance across all sites simplifies coordination and improves consistency of standard.

Does electrical compliance need to be coordinated with fire safety?

Yes. Electrical faults are a leading cause of commercial building fires, and the findings of electrical testing - particularly EICR observations and thermographic survey results - should be reviewed alongside the fire risk assessment to ensure that electrical risks are properly evaluated. Emergency lighting and fire alarm compliance are also directly relevant to fire safety management and should be coordinated with the overall fire safety programme.