PAT labels are not a legal requirement, and neither is a written PAT register. What the Electricity at Work Regulations 1989 require is that electrical equipment is maintained so far as reasonably practicable to prevent danger — and that you can evidence you have done so. Labels and records are how most workplaces prove it; they are not what the law names.
The practical answer for most UK employers: use a label and keep a register, because that is what insurers, landlords and enforcing officers expect to see. Just do not confuse “everyone does this” with “the law says so”.
What the law actually says about records
Regulation 4(2) of the Electricity at Work Regulations 1989 requires maintenance sufficient to prevent danger. HSE guidance in HSG107 Maintaining portable electric equipment is clear: records are recommended, not mandatory, and they help demonstrate compliance if challenged.
See Is PAT testing a legal requirement? for the underlying legal position, and What is PAT testing? for how the whole regime fits together.
What a PAT label should contain
There is no prescribed format. HSG107 suggests, and industry has settled on:
- Unique appliance ID — a number or asset code so the label ties back to the register
- Pass or fail — usually a colour: green for pass, red for fail (with the appliance removed from service)
- Date of test
- Name or ID of the tester — so competence can be verified
- Retest date (optional, and see the caveat below)
The “retest by” date problem
Printing a retest date is common — and often misleading. It suggests the appliance is safe until that date, which is not what the test says. The test says the appliance was safe at the time it was tested. Anything can happen between tests: dropped, kinked cable, coffee spilt into the housing.
HSE guidance is that user checks — a visual look before use — matter more than any label date. See How often should PAT testing be done? for the difference between user checks, formal visual inspections and combined inspection and testing.
Coloured labels — the informal convention
Green, yellow and red are the common convention:
- Green — passed, in service
- Yellow — passed, with a note (for example, extension leads or IT equipment on a different schedule)
- Red — failed and removed from service
None of these colours is prescribed in law. Different testers and contractors use different systems. If you use a contractor, ask what their colour scheme means so you can read your own register.
What goes in a PAT register
A register lists what you own, what condition it is in, and when it was last checked. A workable minimum:
| Field | Purpose |
|---|---|
| Asset ID | Ties test data to a specific item |
| Description | What it is (kettle, extension lead, laptop charger) |
| Location | Where it lives, so it can be found for retest |
| Class (I or II) | Determines which tests apply — see which appliances need PAT testing |
| Date of last inspection | Formal visual inspection date |
| Date of last combined test | Where combined testing applies |
| Result | Pass, fail, or repaired and retested |
| Tester | Name or ID; supports competence evidence |
| Next inspection due | Risk-based — not the same for every item |
| Notes | Damage, repairs, removed from service |
How long to keep the records
There is no statutory retention period for PAT records specifically. The practical minimum is the current cycle plus one — so if you test annually, keep at least two years so a pattern is visible.
Where an incident has occurred, records tied to the appliance in question must be retained as evidence — potentially indefinitely — and never destroyed while any claim, investigation or prosecution is possible.
Digital vs paper
Both are legal. Digital has practical advantages:
- Searchable by asset ID, location, or overdue status
- Photos of damage attached to the record
- Automated reminders when a retest is due
- Backup — a paper register in a burnt-out office is not evidence
What matters is not the format, but that the record is accurate, current, and retrievable. A neat register that has not been updated for two years is worse evidence than a scrappy spreadsheet that has.
What insurers, landlords and auditors actually want
Public liability and property insurers commonly require:
- A written policy on portable electrical equipment
- A register
- Evidence of periodic inspection at a stated frequency
- Named competent person(s)
Landlords of let commercial premises usually require the same before the tenant takes occupation. Residential landlords have separate duties under the Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020 (EICR every five years) — that is not PAT and should not be conflated.
When labels lie
A green PAT label is not a guarantee. It is an evidential snapshot on the day the tester tested. The label goes stale as soon as the appliance is used. Real safety comes from:
- User checks before use — the biggest control
- Prompt removal of visibly damaged equipment
- A route to report a fault that does not punish the reporter
- A repair or replace budget so items actually leave service when they fail
An appliance with a valid label but a cracked case, taped joint or bent pin is not safe just because the label says so. If it looks wrong, it is out of service.
Common register mistakes
- No unique IDs. “Kettle” is not an asset. Two kettles need two IDs.
- Contractor register that never gets to the client. The client company holds the duty — if the register lives on the contractor’s laptop, it is not your evidence.
- Missing sensitive equipment. IT equipment, medical devices, laboratory kit and stage equipment sometimes get excluded because they are on separate maintenance regimes. Note this in the register with the cross-reference.
- No “removed from service” entries. The register should show what has left, when, and why. Missing entries look like missed tests.
Further reading
- HSE HSG107 — Maintaining portable electric equipment
- Electricity at Work Regulations 1989, Regulation 4
- HSE — Portable appliance testing FAQ
PAT testing training
Our PAT Testing Awareness course covers what the law actually requires, the roles of user checks, formal visual inspection and combined testing, how to set risk-based frequencies, and how to keep records that stand up to scrutiny.
Related reading: Is PAT testing a legal requirement? · How often should PAT testing be done? · Who can carry out PAT testing?
£9 per course. CPD accredited, 100 % online, verifiable e-certificate on completion. Pay for 2, get 3 — any 3 courses for £18.
Please note: this is a CPD-accredited awareness course and general information, not legal advice. It is not an Ofqual-regulated qualification and does not replace the practical competence needed to operate a PAT tester and interpret its results. Where a duty holder needs to carry out combined inspection and testing, additional hands-on training and appropriate test equipment are required.