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Gas safety in commercial premises: what the law requires and what to record

By the Field Suite editorial team. Every fact checked against its official source (Gas Safety (Installation and Use) Regulations 1998, HSE and Gas Safe Register) on 5 November 2026.

Short answer: in workplaces such as shops, restaurants and offices, regulation 35 of the Gas Safety (Installation and Use) Regulations 1998 makes the employer or self-employed person keep the gas appliances, pipework and flues they control in a safe condition. The law sets no annual certificate for these premises. The annual check and record in regulation 36 apply to residential lets. Gas Safe Register suggests at least yearly checks as evidence.

Which rules apply where

The 1998 Regulations (GSIUR) apply to gas fittings using gas from a distribution main or a gas storage vessel (reg 2(3)). Within that, two maintenance duties sit side by side: regulation 35 for places of work and regulation 36 for landlords of residential lets. Some premises are taken out of most of the Regulations altogether by regulation 2(4). GSIUR applies in England, Wales and Scotland. Northern Ireland has its own Gas Safety (Installation and Use) Regulations (Northern Ireland) 2004, which this guide does not cover.

GSIUR duties by type of premises
PremisesMaintenance dutyWho may do the gas workAnnual check and record set by law?
Workplace: shop, restaurant, office, school, hospitalReg 35: employer or self-employed person keeps appliances, pipework and flues under their control safeA business on the Gas Safe Register (reg 3(3)), with an engineer qualified for the workNo fixed interval or record format in GSIUR
Residential let under a lease of less than 7 years or a licence: flat, house, bedsit, holiday letReg 36(2): landlord keeps relevant gas fittings and flues safeA Gas Safe registered business (reg 36(4))Yes: check every 12 months, record kept, copy to tenants (reg 36(3) and (6))
Mixed: appliance in a commercial part that also serves flats, such as a boilerReg 36 (it is a "relevant gas fitting" where it sits in a part of the building in which the landlord has an estate or interest, or the landlord owns or controls it), and reg 35 if it is in a workplaceGas Safe registered businessYes, under reg 36
Appliance used only in a non-residential part of a let building, such as a gas fire in a pub barReg 35 where that part is a workplace; reg 36 does not applyGas Safe registered businessNo
Factory, mine, quarry, agricultural premises, temporary construction installations, sewage worksGSIUR does not apply except regs 37, 38 and 41 (reg 2(4)); general duties of the Health and Safety at Work etc Act 1974 applyA competent person; HSE says it is the employer's job to check competenceNo

The exclusion in regulation 2(4) stops at any part of those premises "used for domestic or residential purposes or as sleeping accommodation". HSE says gas work in those parts must be done by a Gas Safe registered engineer.

Which gas duty covers which appliance in a restaurant with a flat above A two-storey building. Upstairs is a let flat with a gas fire, covered by regulation 36. Downstairs is a restaurant kitchen with a range and a fryer, covered by regulation 35. A boiler in the restaurant serves both the restaurant and the flat, so it is covered by regulation 36 as well as regulation 35. Let flat: regulation 36 Gas fire Range Fryer Boiler Restaurant (a workplace): regulation 35 Heating to the flat Boiler: regs 35 and 36
The boiler serves the flat, so it is a relevant gas fitting under regulation 36 even though it sits in the restaurant.

Regulation 35: the employer's duty

Regulation 35 reads in full: "It shall be the duty of every employer or self-employed person to ensure that any gas appliance, installation pipework or flue installed at any place of work under his control is maintained in a safe condition so as to prevent risk of injury to any person."

Three points follow from the wording:

  • The duty sits with whoever controls the place of work, not with the gas engineer. The engineer helps them meet it.
  • It covers pipework and flues, not only appliances. A service record that lists the appliances but never mentions the pipework or flues leaves a gap.
  • It sets an outcome, not a frequency. GSIUR has no annual interval and no record format for workplaces.

Gas Safe Register's guidance for commercial catering says the duty means gas equipment should be "installed commissioned and maintained by an appropriately qualified Gas Safe registered engineer", and that the business "may be required to provide evidence that this duty has/is being met". It goes on: "One way of achieving this is to have paperwork that shows the gas installation and appliances have been safety checked/serviced at least annually." It also notes that the maximum period between services set by equipment manufacturers is generally 12 months, and that an Environmental Health Officer will likely ask for evidence of ongoing maintenance.

Regulation 36: where the landlord's duty stops

Regulation 36 applies to "relevant premises", which are premises occupied for residential purposes under a lease or licence. Its definition of "relevant gas fitting" ends with an exclusion: it "shall not include any gas appliance or installation pipework exclusively used in a part of premises occupied for non-residential purposes".

HSE explains the effect for mixed buildings. Regulation 36 does not apply to an appliance used only in the non-residential part, but "where the part of the premises concerned is a workplace, maintenance requirements under regulation 35" apply. An appliance in the commercial part that also serves the homes, such as a central heating boiler, is a relevant gas fitting and so is covered by regulation 36. HSE also says a landlord and tenant may agree by contract who looks after an appliance in a non-residential part such as a shop or pub, but a full repairing and insuring lease cannot be used to pass the residential duties to a tenant.

Where regulation 36 applies, the landlord must:

  • have each appliance and flue checked for safety within 12 months of installation and then at intervals of not more than 12 months (reg 36(3)(a));
  • keep the record until there have been two further checks (reg 36(3)(c));
  • give a copy to each existing tenant within 28 days of the check (reg 36(6)(a)).

Under regulation 36A, a check done in the 2 months before the deadline date is treated as done on the deadline date, so the 12-month cycle does not drift earlier.

Who may do the gas work

Regulation 3(1) says no one may work on a gas fitting unless competent. Regulation 3(3) goes further for most premises: an employer may not let employees work on gas fittings, and a self-employed person may not do so, unless they are "a member of a class of persons approved for the time being by the Health and Safety Executive". That approved class is the Gas Safe Register. Regulation 3(2) puts a duty on any employer who has control of the work, or who has required work to be carried out at a place of work under their control, to make sure the work is done by someone competent. That covers a business owner who calls in a contractor, and a main contractor who brings in a subcontractor.

HSE tells employers that "it's your responsibility to check a person is registered and is qualified". Gas Safe Register's catering guidance says the engineer must be registered for the type of work (for example catering), the type of gas (natural gas or LPG) and the type of appliance. Its example: in a fish and chip shop the engineer must be registered for catering, natural gas and fish and chip ranges. HSE says the Gas Safe ID card shows the type of work the holder is qualified to do and whether their qualifications are up to date. You can check on the Gas Safe Register website or on 0800 408 5500.

For subcontracted gas work, see our guide to subcontractor documents to check.

What the check covers

For workplaces the law does not list the content of a safety check. It does list what an engineer must examine straight after any work on a gas appliance (reg 26(9)):

  • the effectiveness of any flue;
  • the supply of combustion air;
  • its operating pressure or heat input, or both where necessary (or its combustion performance where those are not reasonably practicable to examine);
  • its operation, so as to ensure it works safely.

The engineer must then take all reasonably practicable steps to notify any defect to the responsible person and, where different, the owner of the premises. The landlord's annual check must include at least the same four matters (reg 36(9)). Using them as the minimum for a workplace record keeps both kinds of record consistent. HSE's employer guidance adds checks for industrial and commercial plant, such as making sure the gas supply is interlocked with the appliance's ventilation where needed.

Worked example: a restaurant with a flat above

A restaurant company leases the ground floor of a two-storey building. The freeholder lets the flat above to a tenant. The gas appliances are a six-burner range and a twin-tank fryer in the kitchen, a boiler in the restaurant's plant cupboard that heats both the restaurant and the flat, and a gas fire in the flat's living room.

Duties and records for the example building
ApplianceDutyDutyholderRecord
Range and fryerReg 35The restaurant company (it controls the workplace)Service and safety check record from a Gas Safe engineer registered for catering appliances
BoilerReg 36 (it serves the flat) and reg 35 (it is in a workplace)The landlord of the flat for reg 36; the restaurant company for reg 35, depending on who controls it under the leaseIncluded in the landlord gas safety record for the flat
Gas fire in the flatReg 36The landlord of the flatLandlord gas safety record, copy to the tenant within 28 days

A maintenance firm with both contracts can book one visit a year that covers everything, with two records: a landlord gas safety record for the boiler and the gas fire, and a commercial service record for the kitchen. The engineer's ID card must cover each appliance type. If the visit lands up to 2 months before the flat's deadline date, regulation 36A keeps the original anniversary.

Who does what

  • The employer or self-employed person in control of the workplace keeps the appliances, pipework and flues safe (reg 35), checks the engineer is registered and qualified, and keeps evidence of maintenance.
  • The landlord of residential parts arranges the 12-monthly check of relevant gas fittings, keeps the record and gives tenants copies (reg 36).
  • The gas engineer works within the categories on their ID card, examines the appliance after any work (reg 26(9)) and reports defects to the responsible person. Anyone working on gas who knows or suspects an appliance is dangerous must take all reasonably practicable steps to tell the responsible person and, where different, the owner (reg 34(3)).
  • The occupier, owner or anyone with authority over the gas fittings must not use an appliance, or let it be used, if they know or have reason to suspect it is dangerous (reg 34(1) and (2)). An appliance the engineer has reported as dangerous stays off until it is put right.
  • The maintenance contractor's office books visits before each due date, sends the right engineer for the categories needed and issues the record.

What to record

For residential parts, regulation 36(3)(c) lists what the record must contain: the date of the check, the address, the landlord's name and address (or agent's), a description and location of each appliance or flue checked, any safety defect, any remedial action, confirmation that the check covered the reg 26(9) matters, the engineer's name and signature, and the Gas Safe registration number. For workplaces there is no prescribed list. A record that would answer an Environmental Health Officer could include:

  • Site address and the business in control of the workplace
  • Each appliance: type, make, model, location, and the flue type
  • Installation pipework and the gas tightness result
  • The reg 26(9) results for each appliance: flue, combustion air, operating pressure or heat input, safe operation
  • Ventilation and any interlock with mechanical extraction
  • Defects found, the action taken, and who was told
  • Engineer's name, signature, Gas Safe registration number and the categories used
  • Date of the check and the date the next one is due

Running gas contracts in Field Suite

  • Forms library: the library has a ready-made landlord gas safety record for domestic lets, built on regulation 36(3), including the 2-month rule in regulation 36A for the next due date. There is no commercial gas form in the library today. You can build your own commercial checklist with the form builder, on your own registration body's guidance.
  • Sign-off by a qualified engineer: with the People module on, a form can be set so that only someone with an in-date qualification, such as Gas Safe, recorded in People and checked by an owner or admin, can sign it off. The owner can override this with a reason, and the override is logged. Field Suite checks that the qualification is recorded and in date, not which Gas Safe categories it covers: matching the card's categories to the appliance stays your check.
  • Contracts and equipment: each appliance sits in the equipment register at its site with its service interval. A contract creates the yearly visit as a job with the form attached, a set number of days before it is due.
  • Defects: the engineer records what they found and how urgent it is. The office turns it into a quote.

See planned maintenance software, read about checking a subcontractor's Gas Safe registration, or book a demo.

Field Suite is job management software. The Regulations, your registration body and the manufacturer's instructions decide how gas work is done and recorded.

Questions

Is a commercial gas safety certificate a legal requirement?

No document of that name is required by GSIUR. Regulation 35 requires workplace gas appliances, pipework and flues to be kept safe. Gas Safe Register says paperwork showing at least yearly checks is one way to prove it.

Does the landlord of a shop need an annual gas safety check?

Not under regulation 36 for appliances used only in the shop. The shop's operator has the regulation 35 duty for the workplace. HSE notes that a landlord's general maintenance duties under section 4 of the Health and Safety at Work etc Act 1974 may in some cases extend to such equipment, so the lease should say who maintains it. If an appliance in the shop also serves a flat, regulation 36 applies to it.

Can any Gas Safe engineer work on a commercial kitchen?

Only if their registration covers the work, gas type and appliance. Check the categories on their ID card or on the Gas Safe Register.

Does GSIUR apply in a factory?

Mostly not: regulation 2(4) excludes factories except for regulations 37, 38 and 41, and except for parts used as homes or sleeping accommodation. Health and Safety at Work Act duties still apply, and the work must be done by a competent person.

Sources

Last checked: 5 November 2026 against the sources above.

Checked in detail: GSIUR 1998 regs 2, 3, 26, 34, 35, 36 and 36A (latest revised versions, no outstanding effects) on legislation.gov.uk, the Northern Ireland 2004 Regulations' listing, HSE gas pages for employers and landlords, and Gas Safe Register commercial catering guidance (PDF text read directly).

Field Suite is job management software for UK building services firms, not a consultancy. Your own risk assessments, contracts and advisers decide what applies to your work. Spotted a mistake? Email info@fieldsuiteapp.com and we correct it.

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