Portable appliance testing has been affected by two separate developments, and they are commonly reported as one. The first is a change of name; the second is a change of law.
Neither replaces the underlying duty to keep electrical equipment safe, but conflating them (as much trade coverage in 2026 does) has left many businesses and landlords unsure what, if anything, they now have to do differently. The distinction is straightforward once the two threads are pulled apart.
What “PAT testing regulation changes” refers to
The phrase covers two things: a terminology shift from PAT to EET under industry guidance, and a legal extension of electrical safety duties into the social rented sector. The first is a relabelling with no new statutory force. The second is a genuine change to the law, and it applies to a defined group of landlords rather than to everyone. The rest of this piece treats them separately, because the obligations attached to each are different, and a reader who merges them tends to over- or under-comply.
The rename from PAT to EET
EET stands for Electrical Equipment Testing, and it is the term now used in place of Portable Appliance Testing. The change originates in the IET Code of Practice for In-Service Inspection and Testing of Electrical Equipment, not in any Act or Statutory Instrument.
Its purpose is descriptive accuracy: the older label implied the work was confined to small, movable items, when in practice it always extended to fixed and stationary equipment (air-conditioning units, hand dryers, and security access systems among them). The name was changed to match the actual scope of the work.
Why the terminology was misleading
“Portable” was never a reliable guide to what fell within testing scope. The Code of Practice has for some editions grouped equipment by construction and use rather than by whether it can be carried, which is why a hard-wired extractor fan and a desk lamp could sit within the same testing regime despite the obvious difference in portability. The label lagged the practice. EET closes that gap.
What the IET 5th Edition Code of Practice is — and when it was published
The 5th Edition of the IET Code of Practice was published in 2020, and this is where much of the 2026 confusion begins. The Code is guidance issued by the Institution of Engineering and Technology; it is the recognised benchmark for what constitutes reasonable care, and it is referenced by courts and enforcement bodies, but it is not itself legislation. Reporting that presents “EET” as a new rule introduced in 2025 or 2026 is mistaken on the date — the terminology and the risk-based approach it sits alongside predate that framing by several years. What changed more recently is the law described in the next section, which is a separate matter entirely. The rename carries no penalty, no deadline, and no new procedure.
The legal duty behind testing, which has not changed
The duty to maintain electrical equipment in a safe condition long predates both the EET rename and the 2025 regulations. It sits in health and safety law that has been in force for decades, and none of the recent changes alter it. What testing does is provide evidence that the duty has been met; the duty itself is the fixed point around which everything else moves.
Electricity at Work Regulations 1989
Regulation 4(2) of the Electricity at Work Regulations 1989 requires that electrical systems be maintained, so far as reasonably practicable, to prevent danger. The wording is deliberately broad. It names no method, no interval, and no document, because the intention was to describe an outcome (safety) rather than prescribe a procedure. Portable and movable equipment falls within “electrical systems” for these purposes, which is why the 1989 Regulations are usually cited as the primary duty behind workplace testing. The obligation rests on the duty holder — typically the employer, though the Regulations extend the term to anyone with control over an electrical system.
Health and Safety at Work Act 1974 and PUWER 1998
Two further instruments reinforce the same duty from different angles. The Health and Safety at Work etc. Act 1974 places a general duty on employers to ensure, so far as is reasonably practicable, the health and safety of employees and others affected by their work, which extends to the equipment provided. The Provision and Use of Work Equipment Regulations 1998 (PUWER) require that work equipment be maintained in efficient working order and good repair. Between them, the 1974 Act sets the principle and the 1998 Regulations apply it to equipment specifically. Neither has been amended by the 2025 changes.
Why testing is a method, not a named requirement
No UK statute contains the words “PAT testing” or requires it by name. This is the single most persistent misconception in the field, and it survives partly because internal company policies and some training materials state the opposite. The law requires that equipment be safe and maintained; inspection and testing are the recognised means of demonstrating that safety, not a duty in their own right. The practical consequence is that a duty holder who never tests but can otherwise prove equipment is maintained has not, strictly, broken the law — though in reality, showing maintenance without any inspection record is difficult, which is why testing has become the default evidence. The distinction matters most when it comes to frequency: because the law names no interval, fixed annual testing is a convention, not a statutory rule.
The confusion usually stems from guidance that blurs the legal duty (maintenance) with the accepted method (formal inspection and testing). Training that separates the two explicitly tends to prevent it; the PAT Training Now course is structured around that distinction, setting out where the statutory duty ends and industry practice begins.
What genuinely changed in 2025 and 2026: social housing
The substantive legal change of this period applies to social landlords, not to businesses or private landlords. It extends electrical safety duties that private landlords have carried since 2020 into the social rented sector, and for the first time it makes in-service testing of landlord-supplied electrical equipment an explicit statutory requirement rather than an inference from general safety law. For most duty holders reading about “2026 PAT changes,” this is the only part with genuine legal force behind it.
The 2025 Amendment Regulations and the dates that apply
The change is made by the Electrical Safety Standards in the Private Rented Sector (England) (Amendment) (Extension to the Social Rented Sector) Regulations 2025 (S.I. 2025/1043). The instrument amends the 2020 Regulations that already governed private lets and brings social housing within the same framework, with a staggered commencement. It applies to new social housing tenancies granted on or after 1 December 2025, with the duty in force from 1 November 2025; for existing tenancies granted before that date, it comes into force on 1 May 2026. A transitional deadline requires that, for those existing tenancies, electrical installations are inspected and tested, and landlord-supplied equipment checked, by a qualified person no later than 1 November 2026. Subsequent checks fall on at least a five-yearly cycle, and unsafe items must be repaired or replaced within 28 days.
The equipment limb is the notable addition. Social landlords have in many cases already worked to a five-year EICR cycle as good practice, so the installation duty is familiar; the requirement to check electrical equipment provided under the tenancy — built-in cookers, integrated appliances, supplied white goods — is the part that is new in substance rather than merely in name. In practice, the harder question for many providers is not how to test but what falls within scope, which turns on a review of tenancy agreements and historic furnishing practice.
Penalties and enforcement
The maximum civil penalty for breach of the electrical safety duties rose from £30,000 to £40,000 per property, effective from 1 November 2025. Enforcement sits with local authorities, which may issue remedial notices where an inspection shows the installation or equipment falls below standard, triggering the 28-day window for corrective work. The penalty is civil and per-property, so exposure scales with portfolio size rather than being capped at a single sum — a point of some significance for larger social landlords managing thousands of units. Where a defective supplied appliance causes injury, separate criminal liability under the Consumer Protection Act 1987 can also arise, independent of the housing penalty regime. The consequences of non-compliance, and how they are calculated, are set out further in What Are the Penalties for Failing to Maintain Electrical Equipment at Work?.
The lithium-ion battery angle
Lithium-ion battery equipment has become a distinct area of concern within in-service inspection, driven by fire risk rather than by any single regulatory change. E-bikes, e-scooters, and large power-tool battery packs have featured in a number of serious fires, and the response has come through updated guidance and insurer attention rather than through a named testing duty. For premises where this equipment is charged or stored, the scrutiny is real even though the rulebook is still catching up.
Why battery equipment sits awkwardly within testing
Conventional appliance testing was built around mains-powered equipment with a flex and a plug, and much of it does not translate cleanly to battery systems. An insulation resistance test on a charger tells you little about the health of the cells it feeds, and cell degradation — the usual precursor to thermal runaway — is largely invisible to the instrument checks that make up a standard test. The failure mode that matters most here is one that portable appliance testing was never designed to detect. In practice, management of this equipment leans more on visual inspection, charging discipline, storage separation, and manufacturer guidance than on instrument testing, which is why current advice treats it as a risk-assessment question rather than a pass/fail one.
What duty holders are generally expected to do
There is no fixed procedure mandated for lithium-ion equipment at the time of writing, and any specific interval quoted should be treated with caution. The direction of travel in guidance is toward documented visual checks, controlled charging arrangements (away from escape routes and, ideally, on timed or monitored circuits), and prompt removal of damaged or swollen units. Insurers have begun to ask about battery equipment specifically when assessing commercial and residential risk, and an absence of any management record is increasingly treated as a gap. What testing can and cannot detect on this equipment is a useful thing for a duty holder to understand before relying on it — the limits of a standard test, examined in Can a PAT Test Detect Every Electrical Fault? Understanding the Limits, are the point, not an afterthought.
PAT/EET testing and EICR: two different inspections
Appliance testing and an EICR examine different parts of the electrical system, and holding one does not satisfy the requirement for the other.
This is a routine source of confusion, particularly among landlords who assume a valid EICR covers everything electrical on the premises. It does not. The two inspections meet at the plug socket and diverge from there.
What an EICR covers
An Electrical Installation Condition Report assesses the fixed installation: the wiring, consumer unit, sockets, switches, and circuits permanently connected to the building. It is the inspection that has been mandatory in the private rented sector in England on a five-yearly cycle since the 2020 Regulations, and it is now the installation duty extended to social landlords under S.I. 2025/1043. An EICR is carried out by a qualified electrician.
What appliance testing covers
EET (or PAT) testing covers the equipment that connects to that fixed installation by plug and flex: kettles, washing machines, lamps, extension leads, and the movable or supplied items a fixed inspection does not reach. It requires competence rather than the full electrician’s qualification, and it produces a pass or fail per item along with a dated register. The demarcation is set out in the IET Code of Practice, which draws the line at the point where equipment connects to the fixed installation. Everything upstream of that point is the EICR’s territory; everything downstream is the appliance test’s.
Where both are needed
For a landlord supplying a furnished property, the two inspections are complementary rather than alternative. The EICR confirms the building’s wiring is sound; the appliance test confirms the supplied equipment is safe. A property can hold a clean EICR and still carry a dangerous supplied appliance, and the reverse is equally possible, which is why full compliance for a furnished let generally requires both. For social landlords, the 2025 Regulations now make this explicit by naming the installation and the equipment as separate duties within the same instrument.
What the changes mean for businesses
For businesses, the legal position is unchanged: the duty under the Electricity at Work Regulations 1989 to maintain equipment in a safe condition applies exactly as it did before, and the social housing regulations do not touch it. What has shifted is the surrounding expectation. Insurers and auditors increasingly treat current, well-documented testing records as a baseline rather than a bonus, and the EET terminology now appears on certificates and in guidance where “PAT” once stood.
The duty holder and the record
The employer, as duty holder, carries the obligation, though the Regulations extend that term to anyone with control over the equipment facilities managers and contractors included. The evidence that the duty has been met is the test register: a dated record showing each item, its result, the tester, and any action taken on failures (what to do with a failed item is covered in What Happens When an Appliance Fails a PAT Test?). Because the law names no interval, the frequency is set by risk assessment rather than by a fixed annual rule, and a defensible record is one that shows the reasoning behind the chosen intervals, not merely the results. The register is the document an insurer or inspector asks for first.
Record-keeping is often where in-house testing programmes weaken, not at the point of testing but at the point of documentation. Course materials from PAT Training Now include equipment registers and record-keeping templates aligned with the current IET Code of Practice, which delegates tend to keep using after certification.
Battery equipment on commercial premises
Where a workplace charges or stores lithium-ion equipment increasingly common in warehousing, hospitality, and delivery operations — the risk assessment is generally expected to address it specifically, along the lines set out earlier. This is the area where insurer questions have sharpened most, and where the absence of any documented approach is most likely to be noticed.
What the changes mean for landlords
The landlord position is genuinely layered in 2026, and the correct answer depends on whether the landlord is private or social. The two sit under different rules, and the recent change affects only one of them directly.
Treating all landlords as a single group as much coverage does is the main reason the picture reads as more confusing than it is.
Private landlords
For private landlords, the named legal duty concerns the fixed installation: a five-yearly EICR, mandatory in England since the 2020 Regulations. There is no separate statute that names appliance testing for private lets. However, a landlord who supplies appliances as part of a furnished tenancy is supplying them commercially, which brings duties under the Electrical Equipment (Safety) Regulations 2016 and the General Product Safety Regulations 2005 to keep those items safe and appliance testing is the recognised way to demonstrate it. The 2025 changes did not alter this; private landlords who already test supplied appliances need do nothing new, and those who never have should treat testing as the accepted evidence of a duty they already hold.
Social landlords
Social landlords are the group the 2025 Regulations directly affect. As set out above, S.I. 2025/1043 makes both the five-yearly EICR and the checking of landlord-supplied electrical equipment explicit statutory duties, phased in from 1 November 2025 for new tenancies and 1 May 2026 for existing ones, with first checks due by 1 November 2026. For a social landlord, appliance checking has moved from good practice to legal obligation, and the £40,000 per-property penalty makes the scope question what supplied equipment falls within the duty — a matter worth resolving early rather than at inspection.
Scotland, Wales, and HMOs
Outside England, the framework differs. In Scotland, the Repairing Standard under the Housing (Scotland) Act 2006 requires landlord-supplied appliances to be in proper working order, with appliance testing the recognised means of showing it. In Wales, the Renting Homes (Fitness for Human Habitation) (Wales) Regulations 2022 impose a fitness standard that covers supplied electrical equipment without naming testing directly. Houses in Multiple Occupation carry the strictest position across all nations: local authorities commonly make appliance testing an explicit condition of the HMO licence, and a breach of licence conditions can put the licence itself at risk. The 2025 English social housing changes do not extend to these regimes, which continue under their own rules.
Ireland: how the picture differs
The Republic of Ireland has no direct equivalent to UK portable appliance testing, but it imposes a comparable duty to keep electrical equipment safe, so the practical outcome is broadly similar even though the legal route differs. UK-focused coverage almost never addresses this, which leaves Irish employers and landlords reading English regulations that do not apply to them. The distinction is worth drawing cleanly.
The duty in Irish law
The governing instrument is the Safety, Health and Welfare at Work Act 2005, supported by the Safety, Health and Welfare at Work (General Application) Regulations 2007, which place duties on employers to ensure that electrical equipment is safe and maintained. As in the UK, the law describes an outcome rather than naming a test or an interval; there is no Irish statute that requires “PAT testing” by name, and the term is used informally to describe the inspection and testing that satisfies the general duty. The Health and Safety Authority (HSA) is the enforcing body, occupying broadly the position that the HSE holds in Great Britain.
What this means in practice
For an Irish duty holder, the sensible reference point is the same risk-based inspection and testing regime used in the UK, documented to the same standard, rather than any Irish-specific certificate scheme because none is mandated. The 2025 English social housing regulations have no effect in the Republic, and neither does the EET terminology as a matter of law, though the IET Code of Practice is often used on both sides of the border as the practical benchmark for competent testing. An Irish landlord or employer following UK good practice will generally meet the Irish duty; the gap is one of paperwork and naming, not of substance.
Demonstrating competence after the changes
Testing must be carried out by a competent person, and competence not a specific licence is what the law and the Code of Practice require. This holds across every strand discussed so far: the businesses under EWR 1989, the social landlords under S.I. 2025/1043, and the private landlords relying on testing as evidence. What “competent” means in practice is the question the recent changes have made more pressing, because more duty holders now need to show it.
What competence involves
Competence is generally understood as the combination of training, knowledge, and practical ability sufficient to carry out the inspection, use the instrument correctly, and interpret the results. Formal electrical qualifications are not required for appliance testing (unlike an EICR, which needs a qualified electrician), but the tester must understand appliance classes, the sequence of visual and instrument checks, and the thresholds that separate a pass from a fail. Risk assessment sits alongside this: since the law sets no interval, deciding how often to test is itself part of the competent person’s role. A recognised course is the usual way to establish and evidence this, and it is the route insurers and licensing authorities most readily accept.
For those needing to demonstrate competence formally, a structured course remains the accepted route. PAT Training Now delivers a one-day UKRS-accredited course — available in person, on-site, or by live remote session, from £145 plus VAT taught throughout to the current IET Code of Practice, with a Certificate of Competence issued on completion and no prior electrical experience required.
Frequently asked questions
Is EET testing the same as PAT testing?
Yes. EET (Electrical Equipment Testing) is the updated term for PAT (Portable Appliance Testing), introduced through the IET Code of Practice to reflect that the work covers more than small portable items. The testing process is essentially unchanged; only the name and some surrounding guidance have been updated.
Did the law on PAT testing change in 2026?
Not for most duty holders. The substantive legal change was the extension of electrical safety duties to social landlords in England under S.I. 2025/1043, phased in from 1 November 2025 and 1 May 2026. The general duty to maintain equipment under the Electricity at Work Regulations 1989 did not change, and no statute has introduced a named PAT testing requirement.
Do landlords have to PAT test now?
It depends on the landlord. Social landlords in England must now check landlord-supplied electrical equipment under the 2025 Regulations. Private landlords have no separately named appliance-testing duty, but where they supply appliances, testing remains the recognised way to demonstrate those items are safe under existing product safety and safety-at-work law.
What is the penalty for non-compliance?
For the social housing electrical safety duties, the maximum civil penalty rose to £40,000 per property from 1 November 2025, enforced by local authorities. Separate criminal liability under the Consumer Protection Act 1987 can arise where a defective supplied appliance causes injury, independent of that penalty regime.
Does testing now cover e-bike and e-scooter batteries?
Guidance gives lithium-ion battery equipment specific attention following a number of serious fires, but standard appliance testing was not designed to assess cell condition. Management of this equipment generally relies on visual inspection, controlled charging, and risk assessment rather than a pass/fail instrument test, and no fixed interval is currently mandated.
Conclusion
The 2026 picture is smaller than the coverage suggests. One development is a name: PAT became EET under IET guidance published in 2020, with no new duty attached. The other is a law: social landlords in England now carry explicit installation and equipment duties under S.I. 2025/1043, backed by a £40,000 per-property penalty. Everything else the workplace duty, the private landlord’s position, the competent-person requirement stands where it did. Separate the name from the law and the changes are clear.
