A gas safety record sent as an email attachment or a portal link is valid in England, if your tenant has agreed to receive it that way and can open it, and if the file can be printed on request, kept secure against alteration and clearly identifies the Gas Safe registered engineer who did the check. A paper copy is the one to hold if the tenant asks for paper, because HSE guidance says a printed copy must then be provided. A cropped phone photo is the weak link, as it usually loses the engineer's registration number and other fields the regulations require.
Digital copy or paper copy of the gas safety record: what differs
Regulation 36 of the Gas Safety (Installation and Use) Regulations 1998 as amended says what a gas safety record must contain in England. It does not say what the record has to be printed on, so the real differences are practical ones.
| Criterion | Digital copy: PDF, email or portal link | Paper copy handed over |
|---|---|---|
| Standing with the tenant | Accepted where the tenant agrees to receive it electronically and can open it | Always accepted, and must be provided when the tenant asks for paper |
| Condition attached | Has to be printable at any time and protected against loss or alteration | Already in print, so nothing has to be reproduced later |
| Engineer identification | Needs an electronic or scanned signature, or the engineer name and registration number | Carries the signature and registration number on the sheet itself |
| Finding it again | Sits in a mailbox or an issuing portal and can be searched by address and date | Depends on where the sheet was filed, and a lost sheet means asking for a reissue |
| Giving it to a new tenant | Can be forwarded before the move in date without a visit to the property | Handed over at the viewing or inside the tenancy pack |
| Keeping records for two years | Backups are simple, so the two year duty is easy to meet | One sheet unless you scan or photocopy it |
Both forms carry the same weight once the content is right. The Health and Safety Executive allows a landlord to supply the record electronically where the tenant agrees to it and can actually access it. The same guidance states that a paper copy must be given if the tenant asks for one. The decision is therefore about how you issue and store the record, not about whether it is valid.
When an emailed PDF or a portal link is the copy to rely on
An emailed PDF or a portal link suits you when the tenant has agreed to receive the record that way and can open it without help. That covers most tenancies arranged by email, where the same address already carries the tenancy agreement and the rent statements. It also covers a tenant who moves in from another city and never meets you in person before the start date.
Electronic issue also helps where several properties share one renewal cycle. HSE guidance allows the record to be sent to the tenant by the landlord, or by the gas engineer directly, with the landlord's agreement. A file that lands in both mailboxes on the day of the check leaves a dated trail without anyone posting a sheet.
The electronic form only holds up if three conditions are met. The record must be reproducible on paper at any time, for the tenant, an HSE inspector or a local authority officer. It must be secure against loss and against alteration. And it must clearly identify the Gas Safe registered engineer who carried out the check, through an electronic or scanned signature, a unique licence or personnel number, or the engineer's name. The deadlines for getting that copy to the tenant are set out in do I have to give my tenant the gas safety certificate.
When a paper copy of the gas safety record is the one to hold
Paper is the copy to hold whenever the tenant asks for paper, because HSE guidance says a printed copy must be provided on request. You do not get to decide that an email was easier. The same applies where a tenant has no email address, shares one mailbox with four housemates, or simply never opens attachments.
Paper also earns its place at handover. A sheet inside the tenancy pack, signed for alongside the keys, settles later arguments about what was received and when. Letting agents and council housing officers often work from that pack during a visit, and a printed record is read in seconds.
One old reason for insisting on signed paper has changed in England. Handing over the record used to be a prescribed requirement before a section 21 notice could be served. Since 1 May 2026 the Renters' Rights Act 2025 has ended assured shorthold tenancies and section 21 evictions in England, so possession runs through section 8 grounds instead. The background to that change is set out in gas safety records and section 21 notices in England.
Does a photo of the gas safety certificate sent on WhatsApp count?
A photo counts only if it shows everything the record has to show, and most photos do not. Phone pictures crop the footer, blur the small print, or catch a glare across the appliance table. Regulation 36 of the Gas Safety (Installation and Use) Regulations 1998 as amended requires the engineer's name and signature and the registration number of the engineer or their employer, and a cut off image loses exactly those fields.
There is a second problem with a photo. An electronic record has to be secure against alteration, and an image forwarded through a chat app offers nothing on that front. If a picture is all you have been sent, ask the landlord or the engineer for the full record as issued. Whether a record that simply looks unfamiliar is still sound is covered in how to check a gas safety certificate is genuine.
A copy is only a gas safety record if it shows every field regulation 36 requires, including the engineer's name, signature and registration number. A cropped photo that loses the footer is not a record of the check, whichever app it arrived through.
What a gas safety record must show before any copy counts
The content decides whether your copy is worth anything, in any format. Regulation 36 of the Gas Safety (Installation and Use) Regulations 1998 as amended lists what the record of the annual check must contain in England.
- the date the appliances and flues were checked
- the address of the premises where they are installed
- the name and address of the landlord, or the agent acting for the landlord
- a description and the location of each appliance and flue that was checked
- any safety defect that was found
- any remedial action that was taken
- confirmation that the check complied with the regulations
- the name and signature of the person who carried out the check
- the registration number of that person, or of their employer, with the body approved by the Executive
Note the words used. HSE calls this a gas safety check record, or landlord gas safety record, rather than a certificate, and the trade shorthand CP12 refers to the same document. The ticks, readings and the letters ID, AR and NCS in the results column are explained in what the codes on a gas safety record mean.
Which other boiler documents arrive as a PDF or a portal link
The gas safety record is not the only paperwork that has gone digital, and the others have different issuers and different purposes. Mixing them up is the most common reason a landlord thinks a document is missing when it is not.
- Benchmark commissioning checklist: filled in by the installer and left with the appliance, as the documented evidence that a Gas Safe registered engineer commissioned it to the manufacturer's instructions. Annual service entries belong in its service interval record.
- Manufacturer guarantee: registered after installation, with Vaillant asking for registration within 30 days and Ideal Heating within a month. Worcester Bosch lets the owner call up the guarantee certificate and the engineer report online.
- Building regulations compliance certificate: issued after a boiler replacement by an installer registered with a competent person scheme, or by the scheme operator, and expected within eight weeks of the work being completed.
- Gas safety check record: the annual record under regulation 36, which the landlord keeps for at least two years and copies to the tenant.
The two year retention period applies to the gas safety records only. Guarantee and building regulations paperwork matters far longer, because a buyer's solicitor asks for it at sale. How those duties fit together across a tenancy is set out in landlord gas safety in England.
Which copy of the gas safety record should you be holding?
Hold the PDF as issued if your tenant has agreed to electronic copies, can open the file, and the record names and identifies the registered engineer. Hold a printed copy if the tenant has asked for paper, has no reliable email, or if a handover pack has to be signed for. Keep a photo as a reminder only, never as your record, because it is the format most likely to drop a required field.
A portal link sits between the two. It works where the issuing system keeps the file unchanged and you can still print it on request, which is what the electronic record conditions ask for. It works against you if the link expires or the account is closed, so a saved copy of the file belongs in your own records as well.
FM Power sends the CP12 by email on the day of the check, which gives you the file to forward and to print as you need. If a check is due on a property you let, you can arrange a landlord gas safety certificate (CP12) in London and keep the record in whichever form your tenant has agreed to.
Sources
- HSE — Gas safety check records and what to keep
- HSE — Domestic gas: frequently asked questions
- legislation.gov.uk — Gas Safety (Installation and Use) Regulations 1998, regulation 36
- GOV.UK — Private renting: your landlord's safety responsibilities
- GOV.UK — Guide to the Renters' Rights Act
- GOV.UK — Building regulations approval: use a competent person scheme
- Vaillant — Domestic boiler guarantee terms and conditions
- Worcester Bosch — Access your guarantee certificate