The 1 October Deadline Electricians Are Still Ignoring: EAS Level 3 Competence Rules Explained

You may believe your business is covered because your Qualified Supervisor holds the right qualifications.

That assumption could become a serious operational problem.

From 1 October 2026, the updated Electrotechnical Assessment Specification (EAS) introduces clearer individual competence requirements for specific categories of electrical work. This EAS update 2026 means a business will no longer be able to rely on one Qualified Supervisor's qualifications to cover every operative carrying out higher-risk or specialist work.

This is a workforce planning, compliance tracking, and capacity issue that goes well beyond a training requirement. If you have not audited who carries out each type of work, checked their qualifications, and gathered evidence of experience, you have less than two weeks to understand the gap before the EAS changes 2026 take effect.

What Is Changing Under the EAS?

The EAS was updated in October 2024. Its purpose is to provide a consistent framework for certification and registration bodies assessing the technical competence of electrical businesses.

One of the most important changes is the move towards individual competence assessment.

Previously, some businesses operated on the basis that one suitably qualified Qualified Supervisor could oversee work completed by several operatives. From 1 October 2026, that model ends for specific work categories.

Each person carrying out affected work must be able to demonstrate their own competence.

The EAS definition of an "employed person" is also broader than many business owners realise. It can include:

PAYE employees, CIS subcontractors, temporary or agency workers, self-employed individuals, sole traders engaged by the business, and other contracted labour carrying out electrical work on the business's behalf.

The label on the invoice does not remove the responsibility. If the person is carrying out work under your business's registration and within its declared scope, you need to understand their qualifications, experience, and supervision arrangements.

Which Work Categories Are Affected?

The requirements taking effect on 1 October 2026 apply to the following work categories:

Periodic inspection and testing, including EICRs. Electric vehicle charging installations. Solar photovoltaic systems. Electrical energy storage systems, including battery storage. Micro wind turbine installations.

The requirements apply across relevant domestic and non-domestic work categories. Your scheme provider will determine the precise evidence and qualification routes accepted for your registration.

EICR Qualifications: The Experience-Only Route Is Closing

EICR work deserves particular attention because many electricians have built years of practical experience without holding a dedicated Level 3 inspection and testing award.

From 1 October 2026, that experience alone will not be enough for the affected registration requirements.

A person carrying out periodic inspection and testing will need to demonstrate a relevant Level 3 qualification, at least two years' documented experience in periodic inspection and testing, and evidence of ongoing continuing professional development.

The two commonly recognised routes are the City & Guilds 2391-51 Level 3 Award, which covers periodic inspection and testing only, and the 2391-52, which covers both initial verification and periodic inspection and testing, or an equivalent Level 3 award accepted by your certification or registration body. This matters because your existing EICR certificate qualification needs to match one of these specific Level 3 Awards. A Level 3 Diploma in Electrical Installation, such as the 2365, is a foundational trade qualification and is not accepted on its own as the inspection and testing qualification the EAS requires.

The two years of experience must also be evidenced. A general statement that someone has "done EICRs for years" is unlikely to be sufficient on its own.

Useful evidence may include EICRs signed or completed by the individual, inspection and testing records, assessment reports, job histories, employer or contractor confirmation, and records showing the type and extent of periodic inspection work completed.

This is where many businesses will discover that their technical knowledge is not the same as their audit readiness. The work may have been carried out safely. The documentation may still be incomplete.

New Competence Requirements for Low-Carbon Work

The EAS also introduces defined competence requirements for newer and growing areas of electrical work.

EV charging installations. Electric vehicle charging equipment installation is now treated as a specific work category. Each employed person undertaking this work will need the relevant Level 3 qualification and supporting evidence required by the scheme provider. Manufacturer training may be useful, but it should not be assumed to replace the required regulated qualification.

Solar PV systems. Solar PV installation is also included as a separate work category. Businesses must ensure that anyone undertaking or responsible for this work has the appropriate qualification, relevant experience, and current technical knowledge. The EAS Qualifications Guide includes recognised routes, such as Level 3 solar PV qualifications. Long-standing experience does not automatically create a permanent exemption.

Battery storage and EESS. Electrical energy storage systems, including battery storage, have their own competence requirements. Battery storage work involves specific design, installation, commissioning, and safety considerations. A general electrical qualification, or training on one manufacturer's equipment, may not be sufficient for registration purposes.

Micro wind turbine installations. Micro wind turbine installation is also listed as a separate category. If your business does not carry out this work, it may not affect your current scope. If it does, the relevant individuals must be included in your competence review.

Do not register for categories simply because they appear commercially attractive. Your scope should reflect the work your people are genuinely qualified and equipped to undertake.

The EAS October 2026 Update Timeline

The change has not appeared without warning. Implementation has run in three phases: an awareness phase from October 2024 to October 2025, where assessors flagged qualification gaps during visits without formal enforcement; an improvement phase from October 2025 to October 2026, where assessors work with businesses to agree action plans; and the hard deadline on 1 October 2026, when full enforcement begins.

A business with an open action plan is not necessarily facing immediate removal from its scheme. That should not be treated as permission to carry on indefinitely.

If you cannot demonstrate compliance, your scheme provider may reduce the scope of work shown on your registration. That could mean losing the ability to undertake or certify particular categories.

Persistent non-compliance can put the whole competent person scheme registration at risk, with real commercial consequences that go beyond a simple administrative correction.

The Capacity Risk Most Electricians Are Missing

Training providers are already facing increased demand as more electrical businesses attempt to qualify staff before this EAS October 2026 update. Course places, assessments, and assessor availability can become limited.

This creates a capacity bottleneck. A qualification gap may not be resolved simply by deciding to book a course. You may also need to consider whether the person meets the course entry requirements, whether the course is accepted by your scheme provider, whether the qualification can be completed before your next assessment, how work will be allocated while the person is training, whether existing qualified staff can absorb additional EICRs or specialist installations, whether your business has enough suitable evidence of experience, and whether customer commitments need to be rescheduled or subcontracted.

This is why the deadline should be managed as an operational project. The question is not only which staff need a qualification. It also covers whether the business can continue delivering this work at its current capacity.

A Practical EAS Audit To Complete This Week

Start with a simple workforce and scope audit.

1. List every person carrying out affected work. Include employees, subcontractors, agency workers, and sole traders. Do not limit the review to people on the payroll.

2. Map each person to the work they actually undertake. Record whether they complete EICRs, EV charging installations, solar PV work, battery storage work, or micro wind installations. A person may work across several categories. Each category should be reviewed separately.

3. Check the qualification held for each category. Record the qualification title, awarding organisation, certificate number, and date achieved. Do not rely on job titles or verbal confirmation. Check whether an existing qualification is accepted by your certification or registration body. The EAS Qualifications Guide provides supporting information, but your scheme provider should confirm how it applies to your business.

4. Gather evidence of experience. For EICR work, collect at least two years of relevant periodic inspection evidence for each person affected. For the other categories, gather the experience and work records required by your scheme provider. Keep the records organised by individual and work category.

5. Check CPD and technical references. Review CPD logs, training records, and toolbox talks. Make sure the business has access to the relevant current technical documents and that staff are working to the correct standards.

6. Review equipment and calibration records. Specialist work may require additional testing equipment. Check that instruments are available, suitable, calibrated, or subject to an appropriate ongoing accuracy-checking system.

7. Speak to your scheme provider. Contact NICEIC, NAPIT, ECA, or your relevant certification or registration body directly. Ask what evidence they require, which qualifications they accept, and what will be reviewed at your next assessment. Do not rely on informal industry advice where your registration is concerned.

Do Not Overlook Amendment 4

There is another important deadline close to the EAS change.

BS 7671 Amendment 4 was published on 15 April 2026. The previous edition and Amendment 4 run in parallel until 15 October 2026. After that date, new electrical work must comply with Amendment 4.

This means your business needs to manage two linked changes: the individual competence requirements taking effect on 1 October, and the transition to the current edition of BS 7671 from 15 October.

Your team should understand which edition applies to work being designed, installed, inspected, and documented during the transition period. The IET's BS 7671 guidance and your scheme provider should be your first points of reference.

Compliance Needs a Reliable System

Many small electrical businesses keep compliance information in a mixture of emails, paper folders, spreadsheets, and personal reminders. That system may appear to work while the business is small. It becomes fragile when you add subcontractors, new technologies, multiple registration categories, and recurring certificate requirements.

A proper process should show who is authorised to carry out each category of work, which qualifications they hold, when qualifications or registrations need reviewing, what experience evidence is missing, which training has been booked, what CPD has been completed, which documents are ready for assessment, what actions remain open, and who is responsible for completing each action.

The same principle applies to Gas Safe compliance tracking, vehicle records, insurance renewals, and other operational controls. Compliance should be visible, assigned, and monitored, and it should not depend on the owner remembering everything between jobs.

How TradeOps Solutions Can Help

TradeOps Solutions acts as an outsourced operations department for trades businesses that need structure behind the work.

For electrical contractors, that can include maintaining a central qualifications and training matrix, tracking certification and registration expiry dates, recording CPD and development actions, organising documentation for assessments, monitoring subcontractor records, creating repeatable compliance processes, coordinating reminders, follow-ups and outstanding actions, and improving visibility across the job lifecycle.

Our electrician operations support is built around the way electrical businesses actually operate. It supports the office, the engineers, and the owner without adding another layer of disconnected administration.

If you want a clear picture of where your own EAS compliance and qualifications tracking stands, our free 15-Point Operations Audit takes ten minutes and shows you exactly where to start. Or if you already know your business needs proper support in place before 1 October, book a free 30-minute call with Lindsay and we will show you clearly where we can help.

Compliance is part of how the business remains able to trade, and this deadline is a test of operational maturity as much as it is a risk. Review your people. Confirm your categories. Book the training. Organise the evidence. Build a system that continues working after 1 October.

Important: This article provides general operational information and is not legal, regulatory, or certification advice. Requirements and accepted evidence may vary between certification and registration bodies. Always check the latest guidance from your scheme provider, the NICEIC EAS guidance, the EAS website, and the IET before making decisions about your business or workforce.