PAT testing — or more accurately, Electrical Equipment Testing (EET) as it is now called — is one of the most misunderstood compliance topics in the UK equipment rental industry. Many rental companies believe PAT testing is a legal requirement. It is not, at least not in the way most people think. But that does not mean you can ignore it.
This guide explains the actual legal position, what the current standards say, and what rental companies specifically need to do to stay compliant and protect themselves.
The Legal Position: What the Law Actually Says
There is no single piece of UK legislation called "The PAT Testing Law." The term PAT testing does not appear in any statute. However, several regulations create a clear legal obligation to maintain electrical equipment:
The Electricity at Work Regulations 1989 are the primary legislation. Regulation 4(2) states:
"As may be necessary to prevent danger, all systems shall be maintained so as to prevent, so far as is reasonably practicable, such danger."
This applies to all electrical equipment used in a work environment. For rental companies, this covers both the equipment you use in your own operations and the equipment you hire out to clients.
Additionally, the Provision and Use of Work Equipment Regulations 1998 (PUWER) require that work equipment is maintained in an efficient state, in efficient working order, and in good repair. The Health and Safety at Work Act 1974 places a general duty on employers to ensure, so far as is reasonably practicable, the health, safety, and welfare of employees and others affected by their undertaking.
For hire companies specifically, the Electricity at Work Regulations 1989 apply because you are supplying electrical equipment for use at work. You have a duty to ensure that equipment is safe when it leaves your premises.
From PAT to EET: The Name Change
The IET Code of Practice for In-Service Inspection and Testing of Electrical Equipment is the industry benchmark document for electrical equipment testing. Courts and the HSE reference it as the standard of good practice.
The 5th Edition of the Code of Practice, published in 2020, introduced a significant terminology change. The term "Portable Appliance Testing" (PAT) was replaced with "Electrical Equipment Testing" (EET). The reason was straightforward: the old term was misleading. Testing is not limited to portable appliances — it covers fixed equipment, stationary equipment, IT equipment, and built-in appliances as well.
You will still hear the term "PAT testing" used widely in the industry, and most people understand what it means. But if you are updating your processes or documentation, using the term EET is more accurate and aligns with the current Code of Practice.
Key Changes in the 5th Edition
The 5th Edition introduced several important technical changes that rental companies should be aware of:
- Leakage test limits increased: The maximum permissible protective conductor / touch current for Class 1 equipment increased to 5mA (from the previous lower limits). The same 5mA limit was applied to Class 2 equipment, which was a significant change.
- New equipment classification: A new category was introduced — Class 2 FE (Functional Earth). This covers equipment that is double-insulated but has a functional earth connection (common in IT equipment and some AV gear). Previously, this type of equipment did not fit neatly into existing classifications.
- RCD testing: The 5th Edition added a requirement to test RCDs (Residual Current Devices) at 5 times the rated tripping current. For a standard 30mA RCD, this means testing at 150mA. This is particularly relevant for rental companies supplying temporary power distribution equipment.
- Greater emphasis on visual inspection: The Code reinforced that a thorough visual inspection catches the majority of faults. Combined testing (visual inspection plus electrical tests) is not always necessary — the decision should be risk-based.
Testing Frequency: Risk-Based, Not Calendar-Based
One of the most persistent myths about PAT testing is that it must be done annually. This is not correct. The HSE is clear on this point: the frequency of inspection and testing should be determined by a risk assessment, not by a fixed calendar schedule.
Factors that affect testing frequency include:
- Equipment type: A handheld power tool used on construction sites faces far more risk than an LED panel used in a conference room.
- Environment: Equipment used outdoors, in wet conditions, or on construction sites needs more frequent testing than equipment used in an office or studio.
- Usage: Equipment that is used daily needs more frequent testing than equipment that is used occasionally.
- User: Equipment used by trained professionals may need less frequent testing than equipment used by the general public.
Special Guidance for Hire and Rental Equipment
The HSE provides specific guidance for hire and rental companies. Because rental equipment is used by different people, in different environments, and is subject to transport and handling between hires, it carries a higher risk profile than equipment that stays in one place.
The HSE recommends that hire equipment should be inspected and tested before each hire. This is a higher standard than for equipment used in a fixed workplace, and it reflects the increased risk that comes with equipment changing hands regularly.
In practice, this means:
- Visual inspection of every electrical item before it goes out on hire
- Electrical testing (earth continuity, insulation resistance, and functional checks) based on the risk profile of the equipment
- Any faults identified must be rectified before the equipment is hired out
- On return, equipment should be inspected again before being put back into available stock
For rental companies, the "before each hire" recommendation from the HSE means that testing is not a once-a-year exercise — it is part of your prep workflow for every job.
Record Keeping
There is no legal requirement to keep records of PAT/EET testing. However, the HSE and the IET Code of Practice both strongly recommend it, and in practice, not keeping records would be extremely difficult to defend if something went wrong.
Good records demonstrate due diligence. If a piece of equipment causes an injury and the HSE investigates, your testing records are your primary evidence that you took reasonable steps to ensure the equipment was safe.
As a minimum, your records should include:
- Date of test
- Name or identifier of the person who carried out the test
- Equipment identification (asset tag, serial number, or barcode)
- Description of the equipment
- Test results (earth continuity, insulation resistance, leakage current, etc.)
- Pass or fail outcome
- Next test due date
- Details of any remedial action taken
Tracking PAT Testing with Software
For rental companies with hundreds or thousands of electrical assets, managing testing schedules manually is impractical. Dedicated software helps by:
- Tracking test dates and results per asset: Every serial number has a testing history, so you can see at a glance when it was last tested and what the results were.
- Flagging overdue tests: The system alerts you when equipment is due for retesting, preventing items from going out on hire with expired test certificates.
- Blocking non-compliant equipment: Some systems can prevent equipment from being added to a booking if its PAT/EET test has expired, adding a safety net to the booking process.
- Generating compliance reports: When a client asks for proof that the equipment you are supplying has been tested, you can produce a report instantly rather than digging through paper files.
NexusRMS includes built-in PAT/EET testing tracking as part of its equipment management module. Test dates, results, and certifications are stored against each serialised asset, and the system flags equipment that is overdue for testing. This integrates directly with the booking workflow, so your team can see compliance status when prepping an order.
Summary
PAT testing (now EET) is not a named legal requirement in the UK, but the Electricity at Work Regulations 1989 and other legislation create a clear duty to maintain electrical equipment safety. The IET Code of Practice 5th Edition is the industry benchmark. For hire and rental companies, the HSE recommends testing before each hire, which is a higher standard than for fixed-workplace equipment.
The key takeaways for rental companies are: test based on risk, not just on a calendar schedule; keep thorough records even though it is not legally mandated; and use software to manage testing schedules across your fleet. Compliance is not just about avoiding prosecution — it is about protecting your clients, your staff, and your business.