Devon has more than 12,000 short-term let properties stretched along the coast, across Dartmoor and into the Exmoor edge. Many are run by retired owners, family trusts or part-time hosts. Every one of them is treated, in law, as a commercial premises. If you let your property to paying guests, the same five compliance documents apply to you as to any hotel, and 2026 is the year HMRC, councils and insurers all expect to see them.
Quick answer: Every Devon holiday let must hold five documents in 2026: a written fire risk assessment, a current gas safety certificate (if gas is present), an Electrical Installation Condition Report, a PAT testing register, and a Legionella risk assessment. The mandatory short-term let registration scheme also lands this year.
Why holiday lets are non-domestic premises in the eyes of the law
A common misunderstanding among Devon owners, particularly those who let out a former family cottage or an inherited bolthole on the moor, is that a holiday let is somehow halfway between a home and a business. It is not. The moment you let your property to paying guests, even for a single weekend a year, it falls within the scope of non-domestic safety law. The same legal framework that applies to a guesthouse in Sidmouth or a small hotel in Salcombe applies to the converted barn outside Chagford and the harbour-front apartment in Dartmouth.
That single point sits underneath everything else in this article. The Regulatory Reform (Fire Safety) Order 2005 applies. The Gas Safety (Installation and Use) Regulations 1998 apply. The Electricity at Work Regulations 1989 apply. The HSE Approved Code of Practice L8 on Legionella applies. UK GDPR applies. Insurers expect compliance, councils expect compliance, and as of 2026, the registration scheme will ask you to attest to it.
Document one: a written fire risk assessment
Of the five documents, the one most commonly missing in Devon holiday lets is the fire risk assessment. Until October 2023, owners of small lets often argued, with some justification, that the risk assessment could be informal. That changed when section 156 of the Building Safety Act 2022 came into force, amending the Regulatory Reform (Fire Safety) Order 2005. Since that date, the small-premises exemption has gone. Every non-domestic premises in England, regardless of size, must have a fire risk assessment recorded in writing.
For a holiday let, the owner is the person with the legal duty for fire safety. The owner must arrange for the risk assessment, record significant findings in writing, act on the findings, give guests appropriate fire safety information, and review the assessment when something material changes. A printed copy in the property, with the date and the assessor's details, is the bare minimum. Our fire risk assessment service produces the written record, the action list and a fire door and emergency lighting check at the same time.
- Identify fire hazards: cooking appliances, open fires, log burners, candles, electric blankets, hot tub plant rooms
- Identify who is at risk: guests unfamiliar with the layout, families with children, guests with mobility needs
- Evaluate, remove or reduce the risks: working alarms on every floor, clear escape route, fire blanket and extinguisher
- Record significant findings in writing and tell guests what to do in a fire
- Review and update when things change, and otherwise on a sensible cycle
A common failure in Devon lets is wood burners installed without a carbon monoxide alarm in the room, log stores stacked against a timber boundary, or escape windows blocked by fitted furniture put in to maximise sleeping capacity. None of these are exotic. All of them get flagged in a written fire risk assessment.
Document two: a current gas safety certificate
If your property has any gas appliance, a boiler, hob, oven, gas fire, gas water heater, the Gas Safety (Installation and Use) Regulations 1998 require an annual gas safety check by a Gas Safe registered engineer. The certificate, often called a CP12, must be in date. A copy must be available in the property for guests, and the original kept by the owner.
A practical Devon point: many older cottages still have a single gas hob fitted decades ago alongside an oil-fired boiler. The presence of the hob alone triggers the certificate requirement. Two more points worth flagging. First, the engineer who carries out the check must be Gas Safe registered, not simply a plumber or heating engineer. Check the engineer's ID card at the property. Second, the certificate is only as good as the appliance behind it, and a gas appliance that has been moved, modified or fitted with an after-market part since the last check is not necessarily covered. If you have done any work on the kitchen or boiler, ask for a re-check.
Document three: an Electrical Installation Condition Report
The Electrical Installation Condition Report, or EICR, is the formal inspection of the fixed wiring in the property. Sockets, switches, consumer unit, light fittings, the cable behind the plasterboard. The Electricity at Work Regulations 1989 require the installation to be maintained so as not to cause danger, and a current EICR is the documentary evidence that the duty has been met.
There is no single statutory interval for short-term lets the way there is for residential rentals, but the standard professional recommendation is every five years, with the report carried out by a qualified electrician working to BS 7671 (the IET Wiring Regulations). Older Devon properties, granite cottages with wiring from the 1960s, converted outbuildings and barns with patchy upgrades, are routinely recommended on a shorter cycle. A property with a hot tub, an EV charger, a sauna or any significant garden lighting installation should be carefully scoped.
An EICR sits separately from the portable appliance check below. The EICR covers what is fixed in the walls and ceiling. PAT covers what plugs into the wall.
Document four: a PAT testing register
Portable Appliance Testing, or PAT, is not named in primary legislation in the way a gas certificate is. It is, however, the practical method by which a holiday let owner demonstrates compliance with the Electricity at Work Regulations 1989 and with the wider duty to manage risk under the Health and Safety at Work etc Act 1974. Holiday let insurers expect a PAT register. The 2026 registration scheme asks owners to attest to electrical safety. A documented PAT cycle is the answer to both.
In a holiday let, you are looking at kettles, toasters, microwaves, hair dryers, irons, lamps, televisions, fridges, freezers, washing machines, dishwashers, and any small appliance left for guest use. Guest turnover, unknown handling and the routine wear of cables in a property used by dozens of people a year all push the sensible interval down to annual. Our PAT testing service covers the test, the register, the pass or fail per item and the recommendation on anything that should be withdrawn from service.
- Visual inspection of cable, plug and casing
- Earth continuity test on Class I appliances
- Insulation resistance test
- Pass or fail per item, with a register dated and signed
- Replacement recommendation for anything failed
Document five: a Legionella risk assessment
The fifth document is the one most often misunderstood. The HSE Approved Code of Practice L8 sets out the duty to assess and control the risk of Legionnaires' disease in any water system that presents a foreseeable risk. The HSE has explicitly confirmed, in published guidance, that holiday let owners must carry out a Legionella risk assessment. It is not optional and it does not vanish just because the property is small or rural.
Holiday lets sit higher on the risk curve than ordinary homes for three reasons. First, vacancy. A let that sits empty between bookings is a system with warm, static water, exactly the conditions in which Legionella bacteria multiply. Second, shower heads, which aerosolise water and produce the droplet size that can be inhaled. Third, the property type. Devon is full of properties with combination boilers, hot water cylinders in airing cupboards, outdoor taps, and the occasional dead leg from a removed appliance, all of which deserve attention.
Practical control measures for a Devon holiday let include flushing all outlets, including showers, for two minutes before guest arrival after any vacancy of more than a week; setting hot water cylinders to a minimum of 60 degrees Celsius; cold water below 20 degrees Celsius; descaling shower heads at a defined interval; and recording the checks. Our water safety service covers the routine temperature monitoring and TMV testing that sits inside the wider water hygiene scheme. The full Legionella risk assessment itself needs a specialist, and we point owners at the right local assessor.
Hot tubs: a separate category of risk
If your Devon holiday let has a hot tub, and many do because guests love them, the compliance picture changes. HSE guidance HSG282 on the control of Legionella and other infectious agents in spa pools applies to commercial hot tubs, and a let where the tub is part of the offering is treated as commercial. You need a dedicated risk assessment for the tub itself, chemistry monitoring (chlorine or bromine, pH, alkalinity), a defined drain and clean schedule, a filter cleaning regime, and written records.
Most insurance claims involving holiday let hot tubs hinge on whether the owner can produce the chemistry log and the drain record at the time of the incident. If they cannot, the claim is likely to be declined. A tub left for a week with two guests in it is a higher-risk system than most domestic owners realise. Take it seriously, get it assessed, and keep the log.
The 2026 short-term let registration scheme
Phase 1 of the mandatory short-term let registration scheme in England rolls out across 2026, under powers granted to the Department for Culture, Media and Sport by the Levelling Up and Regeneration Act 2023. Every owner of a property let on a short-term basis in England must register the property, pay a fee per property and confirm that the safety documentation listed in this article is in place.
The registration scheme is not, in itself, a safety regulation. It is an attestation. You confirm to the government that you hold the documents. If you attest and you do not in fact hold them, you are exposed on two fronts: the underlying safety law remains breached, and you have now made a false statement on a public register. Devon owners across the coast, on Dartmoor and on the Exmoor edge should treat the registration trigger as the deadline by which the five documents must be sorted.
Insurance: where most owners discover the gap
Almost every holiday let insurance policy on the UK market today contains a condition that the property complies with current safety legislation and that the relevant certificates are in place and current. This is not a courtesy clause. It is a condition precedent to the cover. If a fire occurs and your fire risk assessment is missing or out of date, the insurer is entitled to decline the claim. If a guest is electrocuted and your EICR has expired, the insurer is entitled to decline the claim. If Legionella is confirmed in your property and no risk assessment exists, the insurer is entitled to decline the claim.
The amounts involved are not modest. A serious fire in a coastal cottage can write off £400,000 to £800,000 of structure and contents. A guest injury claim from a defective electrical installation can run to six figures. A Legionella outbreak with a confirmed hospital admission produces both a civil claim and an HSE investigation. The cost of holding the five documents, by contrast, is a few hundred pounds a year. The mathematics is not close.
GDPR and guest data: the document people forget
Sitting alongside the five safety documents is the data side. The booking platform, Airbnb, Booking.com, Vrbo, or a local agency, handles the public-facing part of the data flow. The moment the guest's data lands with you, the owner, you become the data controller. UK GDPR requires you to have a privacy notice, a lawful basis for processing, a clear retention period and a record of any sharing.
For a Devon owner letting through multiple platforms, the simplest approach is a single privacy notice on your own welcome pack or check-in email, a retention period of no more than 24 months after the stay (longer only if a specific reason exists), and a brief written register of the booking platforms you use and what they share with you. None of this is onerous. All of it is required.
Welcome packs, food and pest management
If you provide a welcome hamper, a breakfast pack, complimentary milk and bread, or any prepared food to guests, you may be drawn into food business operator territory. The threshold is lower than most owners expect. A pre-packaged commercial hamper from a Devon producer is one thing. Bread you have baked yourself or jam from a friend's hedgerow is another. The Food Standards Agency guidance and any food-related provision should be reviewed if you go beyond sealed shop-bought items.
Pest management plans are similarly often overlooked. A property in a rural setting with food on site is a magnet for mice and rats. A documented pest management approach, traps, bait stations placed responsibly, a contractor's annual visit, sits alongside the food provision and protects both you and the guest.
What good looks like in a Devon let: a working compliance pack
When we audit holiday lets across Devon, the properties that pass cleanly all share one feature: a single, dated compliance pack kept at the property and digitally with the owner. The pack contains the current fire risk assessment, the gas safety certificate, the EICR, the PAT register, the Legionella risk assessment, the hot tub risk assessment and chemistry log where applicable, the privacy notice, and the public liability insurance schedule. Each document is dated and shows the next review date.
The reason this works is that an inspector, an insurer, a council officer or the registration scheme can be answered from a single folder. The owner who has to dig through emails, ring last year's electrician and chase a Gas Safe engineer in the middle of a claim is the owner who loses the claim. The pack costs nothing extra to put together once the underlying work is done. Put it together. Keep it on the kitchen shelf in a plastic wallet, and a second copy in the cloud.
Common Devon failure points we see most often
- Verbal fire risk assessments by the owner from years ago, never written down
- Gas certificate expired by months, never re-booked after the previous engineer retired
- EICR more than ten years old, often pre-dating the current consumer unit
- PAT testing never carried out at all on inherited appliances
- Legionella risk assessment dismissed as unnecessary because the property is small
- Hot tub run on a casual chemistry routine with no written log
- Welcome hamper supplied with home-prepared items and no food-business consideration
- No privacy notice anywhere in the guest journey
- Wood burner installed without a working carbon monoxide alarm in the room
- Insurance schedule that requires current certificates the owner does not actually hold
None of this is wilful neglect. The pattern is almost always the same. A property gets passed down or bought for retirement, started as a soft side-business, gradually picks up bookings, and the compliance never catches up with the commercial reality. The 2026 registration scheme is the moment that catch-up gets formalised.
How TestSafe works with Devon holiday let owners
We work across Devon, from Salcombe and Dartmouth on the south coast, through the Dart Valley and the South Hams, up to Croyde and Bigbury, across Dartmoor and onto the Exmoor edge. We visit your property, work through the five documents with you, produce the written records we are qualified to produce ourselves, and refer the specialist pieces (full Legionella risk assessment, EICR) to qualified local contractors we trust.
We are not a national chain. We are not a corporate retainer. We are a Devon business that talks the way a Devon owner talks, charges what a small holiday let can afford, and follows up rather than disappearing after the first invoice. If you run a let in Devon and 2026 is the year the registration scheme makes the paperwork unavoidable, we can work through it with you on your terms and on your timetable.
This article is for general information only and reflects the law as it stood on the date of publication. It does not constitute legal advice and should not be relied upon as a substitute for advice specific to your situation. TestSafe Compliance provides audit and assessment services only. Where a specific legal question arises, seek advice from a qualified solicitor or employment law specialist.
Frequently asked questions
Do holiday lets in Devon legally need a written fire risk assessment?
Yes. Since the Building Safety Act 2022 amended the Regulatory Reform (Fire Safety) Order 2005 in October 2023, every short-term let in England must hold a written fire risk assessment, regardless of size. The owner is the person with duties under the order. A verbal or mental check is no longer acceptable. The assessment must be reviewed when something material changes and otherwise on a sensible cycle, typically annually for a busy let with high guest turnover.
How often does a holiday let need an EICR in Devon?
Standard advice from electrical bodies and from holiday let insurers is every five years, with the report dated and signed by a qualified electrician. Older properties, properties with known wiring issues, and high-turnover lets are often recommended on a shorter cycle. The Electricity at Work Regulations 1989 require electrical installations to be maintained so as not to cause danger, and a current EICR is the practical evidence that this duty is being met.
Is a Legionella risk assessment really needed for a small Devon cottage?
Yes. The HSE Approved Code of Practice L8 applies to any water system that presents a foreseeable risk, and the HSE has confirmed in guidance that holiday let owners must carry out an assessment. Periods of vacancy, warm pipework, infrequent use of outlets and aerosol-producing showers all combine to make holiday lets a higher risk than a normal home. The assessment is usually brief, but it must exist in writing and be kept current.
Will the 2026 short-term let registration scheme apply to my Devon property?
If you let a property in England on a short-term basis, the scheme applies. Phase 1 of the registration scheme rolls out across 2026 under powers granted by the Levelling Up and Regeneration Act 2023. Registration is mandatory, a fee per property is payable, and you are asked to confirm that safety documentation is in place. Devon owners along the coast and across Dartmoor and Exmoor villages should not assume that rural location means exemption.
What happens if my holiday let insurance claim is rejected for missing certificates?
Most holiday let policies have a condition that requires current statutory safety documentation to be in place. If a fire occurs and the fire risk assessment is missing or out of date, if a guest is electrocuted and the EICR is expired, or if Legionella is confirmed and no risk assessment exists, the insurer is likely to decline the claim on the grounds of a breach of policy condition. The owner is then personally exposed to property damage, guest injury claims and any prosecution costs.