At that point two entirely different questions get muddled together — "does this need to be notified to building control?" and "does this affect my EICR?" They are not the same question, they run on different legislation, and getting them confused is how landlords end up either paying for a self-certification they didn't need, or skipping one they did.
Two systems, not one
The first system is periodic condition reporting. For a privately rented home in England, the Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020 (SI 2020/312) set out the landlord's duties at regulation 3: inspect and test the installation (3(1)(b)), at intervals of no more than five years (3(2)(a)), supply the report to the tenant within 28 days (3(3)), carry out any required remedial work within 28 days (3(4)), and confirm that in writing (3(5)). That is the EICR — a periodic survey of the existing installation's condition. It is a landlord duty for rented homes; it does not apply because you happened to fit a new light.
The second system is completely different: it governs new work, and it applies whether the property is rented, owner-occupied or being refurbished ahead of sale. Under regulation 12(6A) of the Building Regulations 2010 (SI 2010/2214), certain electrical work is notifiable — it must either be carried out and certified by someone registered with a competent-person scheme, or notified to building control before it starts. Notifiable work is: a new circuit, a consumer-unit replacement, or an addition or alteration to an existing circuit that falls within a "special location". Bathrooms are one of the special locations named in the wiring regulations, which is exactly where this gets confused.
What counts as the "special location" in a bathroom
This is the detail most people get wrong. A special location in a bathroom is not the whole room — it is the zone around the bath tap or shower head, extending to roughly 2.25 metres high and 0.6 metres out. Work outside that zone, on an existing circuit, is not automatically notifiable purely because it happens to be in a room with a bath in it. Work inside that zone — adding a socket, an extension lead to a light circuit, anything that alters wiring within the zone — is where regulation 12(6A) is engaged.
In practice, on a typical refurbishment this covers:
- Installing a new circuit for anything — an extractor fan, underfloor heating, a shaver point run from a fresh spur.
- Replacing the consumer unit, which is always notifiable regardless of which room it feeds.
- Adding to or altering an existing circuit where the alteration sits within the zone around the bath or shower.
It does not generally cover simple like-for-like replacement of an accessory outside the special location, or work that doesn't touch the fixed wiring at all. Approved Document P is worth reading for the practical guidance it gives on this, but it is guidance on Part P of the Building Regulations — the legal trigger is regulation 12(6A) itself, and that's the point worth being precise about if a managing agent or building control officer ever asks what was actually notified and why.
Who signs it off
Most domestic electricians working on notifiable jobs are registered with a competent-person scheme (NICEIC, NAPIT and similar), which lets them self-certify the work and notify building control on your behalf — you get a certificate, and that's the end of it. If your electrician isn't scheme-registered, the alternative route is a direct building control application before work starts, which is slower and adds cost for no real benefit on a domestic job. Ask the question before you book, not after the tiler has gone in.
Where this meets the EICR
New or altered work should be tested at the point it's installed — that's part of the electrician's own certification, separate from your landlord EICR cycle. But it's worth thinking about timing. If your existing EICR is two years old and you're now adding a new circuit and swapping the consumer unit as part of the bathroom job, it's often more efficient to have the whole installation tested and re-certified once the refurbishment work is complete, rather than treating the new work and the old report as two unconnected documents. Our guide to EICR certificates for landlords covers the five-year duty in detail, and if the consumer unit itself is part of the scope, consumer unit upgrade regulations sets out what a replacement involves. Either way, regulation 4 of SI 2020/312 — the power to serve a remedial notice — belongs to the local housing authority, not to you as landlord; your obligations are all in regulation 3, and it's worth knowing the difference if a report or a notice ever cites the wrong one.
The HMO trap worth avoiding
If the property is a licensed HMO, it's tempting to assume the mandatory licence conditions include an electrical-safety requirement. They don't, directly. Mandatory HMO licence conditions sit in the Housing Act 2004, section 67 and Schedule 4 — and the 2018 amendment to that schedule (SI 2018/616) added minimum room-size conditions, not an electrical one. Electrical safety for an HMO is still governed by the same EICR duty under SI 2020/312 and by Part P for any notifiable work, run alongside the licence rather than folded into it. Our page on HMO licensing in Westminster covers the licence conditions specifically; don't rely on the licence paperwork alone to tell you your electrics are compliant.
A practical sequence for a refurbishment
- Agree the electrical scope before tiling starts — moving a socket after the tiler has finished is expensive and avoidable.
- Confirm your electrician is scheme-registered so notifiable work is self-certified, not left in limbo.
- If a consumer unit swap is part of the job, treat it as notifiable regardless of which room it's in.
- Book a fresh EICR after the work if the existing one is more than a couple of years old, rather than leaving two documents that don't agree with each other.
- Keep every certificate — the Part P certificate for the new work and the EICR for the wider installation are different documents answering different questions, and a solicitor, insurer or incoming tenant may ask for either.
Our bathroom refurbishment service is from £2,800 for labour-only first and second fix, with a typical full refurbishment from £7,000, and electrical work on a refurbishment starts with a call-out (contact us for the current rate) and is quoted properly once the scope — including anything notifiable — is agreed. See electrical services for the detail, or send us a photo of the space and what's planned and we'll tell you what's actually involved.
Nothing in this article is legal advice. Electrical safety and building control requirements are fact-specific and change from time to time — confirm the current position for your property, tenancy and licence with a qualified electrician or building control before work starts.
Ready to plan the electrics for your bathroom refurbishment? Get a fixed quote and we'll sequence the notifiable work correctly the first time.