An EICR observation must state the defect, where it is, the regulation of BS 7671 it departs from and one classification code. On the BS 7671:2018+A4:2026 model form, in force on its own since the Amendment 2 forms were withdrawn on 15 October 2026, only C1 and C2 observations make the report unsatisfactory; C3 and FI ("Further investigation is advised") are advisory. That puts more weight on each C2 being justified in the item that carries it. Electrical Safety First Best Practice Guide 4, now Issue 7.4 (August 2026), and IET Guidance Note 3 give the accepted codes and phrasing. This guide sets out the structure and rewrites twelve typical observations from vague to defensible.
- Every observation: defect, location (board, circuit, room), regulation, code. Four parts, every time, and one code per item.
- Describe the situation, not the repair. BPG4 says the observation should detail what the situation is, not what is needed to put it right; a brief pointer is fine, a design is not.
- Under A4 only C1 and C2 drive an unsatisfactory outcome. FI now reads "further investigation is advised" and no longer fails the report, so it is no longer a reason to avoid committing to a code, and no longer an excuse for one.
- "Not to current regulations" is not a defect. BPG4 Issue 7.4 adds an "NC" category for departures that are neither dangerous nor worth recommending, and says they need not go on the report at all.
- Photograph every C1 and C2 and reference the photo from the item. BPG4 calls photographic evidence "advantageous"; in a dispute it is decisive.
Why does the wording of an observation matter?
An EICR is a written professional opinion on the condition of an installation against BS 7671, and the observations are where that opinion is expressed. Chapter 65 of BS 7671 requires any damage, deterioration, defects, dangerous conditions and non-compliances that may give rise to danger to be recorded and, where appropriate, given a classification code. Three groups read them closely. The first is the landlord or agent: under the Electrical Safety Standards in the Private Rented Sector and Social Rented Sector (England) Regulations 2020 they must complete further investigative or remedial work within 28 days of an unsatisfactory report, with a civil penalty of up to £40,000 for breach. The second is the electrician doing the remedial work, who may not be you and may not have seen the property. The third is anyone assessing the report afterwards, from a scheme assessor to a local authority officer to a court. Each needs to find the defect from the words alone, understand the code and confirm later that it has been dealt with.
The codes themselves are explained in EICR Codes Explained: C1, C2, C3 and FI. This guide is about the sentence that carries the code.
What changed for observations under Amendment 4?
BS 7671:2018+A4:2026 was published on 15 April 2026 and the IET issued new model forms with it. For the observations section the changes are small on paper and large in practice.
| Point | A2:2022 model form | A4:2026 model form |
|---|---|---|
| FI wording | Further investigation required without delay | Further investigation is advised |
| Codes that make the report unsatisfactory | C1, C2 or FI | C1 or C2 only |
| C3 and FI | C3 advisory; FI failed the report | Both advisory, decoupled from C1 and C2 |
| Section K layout | One observations list | C1 and C2 observations listed together, then C3 and FI observations |
| Next inspection | Interval in years | A date by which the installation should be further inspected and tested (Section F) |
IET Wiring Matters 110 (July 2026) explains the thinking: an EICR "is not a fault-finding exercise", and "it should not be necessary to attribute an FI classification code in the majority of circumstances." The FI code is for a potential issue that cannot be classified until someone investigates, not for a defect you could have inspected and did not. BPG4 Issue 7.4 goes further for houses and flats: it gives no FI examples at all for domestic and similar installations, because in a dwelling it should generally be possible to put a code on everything you find.
One consequence to watch. The England regulations still speak of "further investigative or remedial work", so a letting agent may treat an FI as starting the 28-day clock even though the report is satisfactory. Write the FI so the reader knows exactly what needs investigating and why you could not resolve it on the day.
What are the four parts of a good observation?
| Part | What to write | Weak example | Defensible example |
|---|---|---|---|
| Defect | What is actually wrong, in physical terms | "Sockets not RCD protected" | "Socket-outlets rated 13 A have no additional protection by a 30 mA RCD" |
| Location | Board, circuit number, room, position | "Kitchen" | "DB1, circuit 5 (kitchen ring final), all socket-outlets" |
| Regulation | The regulation number, or the requirement in words if the number is not certain | none | "Regulation 411.3.3" |
| Code | One of C1, C2, C3 or FI, consistent with GN3 and BPG4 | "C2 to be safe" | "C3" |
The regulation reference tells the reader which requirement is not met and forces you to check that there really is one. If you cannot name the regulation or state the requirement in a sentence, ask whether it is a defect or a preference. BPG4's own test for an observation is that it is "written in a clear, accurate and concise manner" and "likely to be understood by the person ordering the work".
What about the recommended action? Earlier editions of this guide treated it as a fifth part. BPG4 Issue 7.4 is explicit that "the observation should detail what the situation is, and not what is considered necessary to put it right." The reason is that the EICR is a condition report, not a specification, and a line such as "rewire the circuit" can be quoted back at you when the remedial electrician finds a cheaper fix. The practical position most inspectors take is a short pointer, "provide 30 mA RCD protection for the circuit", which tells a landlord roughly what the job is without designing it. Keep it to a clause, keep it general, and never put a price or a product in it.
The most common weak observation on domestic reports is "not to current regulations, recommend upgrade". BPG4 states that installations built to earlier editions "may not comply with the current edition in every respect" and that "this does not necessarily mean that they are unsafe for continued use or require upgrading". The phrase identifies no defect, no location and no risk. If the consumer unit has a thermoplastic enclosure, say so and code it according to where it is (see item 2 below); if the lighting has no circuit protective conductor, say that Class I fittings on it have no fault protection, which BPG4 codes C2.
Where does each code go on the form?
BPG4 asks for two entries per defect. The code goes in the outcome column of the schedule of inspections (or the remarks column of the test results) at the point where you found it, and a corresponding numbered observation goes in Section K with the same code. The two must agree. A C2 in the schedule with no Section K item, or a Section K item the schedule never mentions, is the first inconsistency an assessor will pick up, and it is the easiest to avoid: write the observation when you put the tick in the box, not from memory in the van.
The A4 form prints the observations in two groups, C1 and C2 first, then C3 and FI, each "referring to the attached Schedule(s) of Inspection and Schedule(s) of Circuit Details and Schedule(s) of Test Results". The table has an item number and a classification code column; the location lives in the text of the observation, so put it at the start of the sentence where it cannot be missed. Form Note 12 for the inspector states that the overall assessment must be unsatisfactory where an observation carries C1 or C2, and Note 10 for the recipient explains that FI is used where the inspector cannot determine a code until investigation takes place.
Items that BPG4 now calls "NC only", a non-conformity with BS 7671 "which does not give rise to danger and where improvement is not recommended", are "not required to be recorded on an EICR". A board with no circuit chart in a two-bed flat where every device is clearly labelled is the classic example. If you want the client to know, put it in the summary or a covering note, not as a coded observation that pads the count.
How should observations be numbered and laid out?
Number every item from 1, one defect per item, and keep the numbering fixed once issued so remedial certificates can refer to "EICR item 7". BPG4 says "only one of the standard Classification Codes should be attributed to each observation", which rules out "C2/C3" and rules out items that bundle a C2 bonding defect with a C3 labelling point. Where the same defect exists on several circuits, write one item per circuit or list every circuit affected; "various circuits" is not a location. The front-page summary states the outcome, the number of C1, C2, C3 and FI items and the main reasons in two or three sentences; it is not a substitute for the items. Photograph every C1 and C2 and anything that could be disputed, label each photograph with its item number and reference it from the item.
Limitations agreed with the client (no access to a tenant's room, accessories sampled) go in Section D, extent and limitations, which the A4 form ties to Regulation 651, and they carry no code. Where a limitation stopped you confirming something that might be dangerous, that is what the FI code is for; see EICR Sampling and Limitations Explained for the line between the two. Remarks that are not defects belong in the summary.
Twelve observations rewritten
Each pair shows the wording as it commonly appears and a version a remedial electrician, assessor or council officer could act on. Codes follow BPG4 Issue 7.4; the regulation numbers are BS 7671:2018+A4:2026.
| # | As commonly written | Rewritten |
|---|---|---|
| 1 | No RCD on sockets. C2 | DB1, circuits 3 and 5 (ring finals, ground and first floor): socket-outlets rated 13 A have no additional protection by a 30 mA RCD. Regulation 411.3.3. C3. Written as a separate item: DB1, circuit 4 (kitchen ring final): the socket-outlet adjacent to the rear door is reasonably expected to supply mobile equipment used outdoors and has no 30 mA RCD protection. Regulation 411.3.3. C2. Photo 2. |
| 2 | Plastic CU. C2 | DB1, cupboard beneath the timber staircase: consumer unit enclosure is of thermoplastic material, not non-combustible, and the staircase forms the escape route from the first floor. Regulation 421.1.201 (applies to consumer units installed since January 2016). No signs of thermal damage. C3. Photo 1. |
| 3 | No bonding | Main protective bonding conductor to the incoming water service is absent; the service pipe is metallic and continuous to earth. Gas is bonded in 10 mm². Regulations 411.3.1.2 and 544.1.2. C2. Photo 3. |
| 4 | Bathroom dodgy | First-floor bathroom: circuits DB1/7 (lighting) and DB1/9 (shower) serving the location have no 30 mA RCD protection and no supplementary bonding is present, so the conditions of Regulation 701.415.2 for omitting it are not met. Regulations 701.411.3.3 and 701.415.2. C2. Photo 5. Written as a separate item: Class I ceiling luminaire within zone 1 above the bath has no IP marking. Regulation 701.512.2 (IPX4 required). C3; no evidence of water ingress at the time of inspection. |
| 5 | Recommend upgrade to current regs | Lighting circuits DB1/6 and DB1/7 are wired in cable with no circuit protective conductor; Class I metal switch plates in the hall and a Class I pendant in the landing have no connection to earth, so fault protection under Chapter 41 cannot be achieved at those points. Regulation 411.3.1.1. C2. Photo 4. |
| 6 | Zs high on circuit 2 | DB1, circuit 2 (cooker, 32 A Type B circuit-breaker): measured Zs 1.62 Ω against a maximum of 1.37 Ω in Table 41.3 (1.10 Ω after the 80 % rule of thumb for conductor temperature), so the device cannot be relied on to disconnect within 0.4 s. Regulations 411.3.2.2 and 411.4.4. No RCD protection on the circuit. C2. |
| 7 | Exposed live parts at CU | DB1: two unused ways had no blanks fitted and live busbar was accessible to a finger with the cover in place. Regulation 416.2 (IPXXB). Blanks of the correct type were fitted and secured during the inspection and the condition no longer exists; recorded here as a remark, not coded. Photo 1 shows the board as found. (If only a temporary barrier had been fitted, the item stays C1 and the report is unsatisfactory.) |
| 8 | Burnt socket | Ground-floor rear bedroom, socket-outlet nearest the window on DB1/3: faceplate shows thermal damage and the line terminal screw was found loose. Regulation 526.1. C2. Photo 6. |
| 9 | Ring broken | DB1, circuit 3 (first-floor ring final): end-to-end continuity of the line conductor could not be established (r1 open circuit); rn 0.42 Ω, r2 0.68 Ω. The circuit is operating as two radials in 2.5 mm² cable protected by a 32 A device. Regulations 433.1 and 433.1.204. C2. See schedule of test results. |
| 10 | Old wiring | Kitchen and utility, DB1/5: rubber-insulated cable at the socket-outlet behind the washing machine; insulation is brittle and has broken away at the termination exposing the conductor. Insulation resistance to earth on this circuit 0.35 MΩ against the 1.0 MΩ minimum of Table 64. Regulations 643.3.2 and 522.6. C2. Photo 7. |
| 11 | Shower cable too small | DB1, circuit 9 (electric shower, 40 A Type B circuit-breaker): wired in 4 mm² cable clipped direct, current-carrying capacity 37 A, with a 9.5 kW shower connected drawing approximately 41 A at 230 V. Both conductor and protective device are rated below the design current. Regulations 433.1.1 and 523.1. C2. |
| 12 | Unknown cable under floor | DB1, circuit 8: a 2.5 mm² cable leaves the board and passes below the ground floor; no accessory or load supplied by it could be found and the floor could not be lifted (see Section D). Insulation resistance satisfactory, no load measured. FI: further investigation is advised to trace the cable and either terminate it correctly or remove it. Report remains satisfactory on this item alone. |
Each rewrite adds a location precise enough to walk to, a regulation cited where certain, a single code consistent with BPG4, and a photograph where one settles the argument. Items 1 and 4 have been split in two because the original versions carried two different risks, and therefore two different codes, in one line. Item 7 is the one that has changed most since the Amendment 2 version of this guide: fitting the blanks is a permanent fix, and BPG4 Issue 7.4 says a dangerous condition "rectified permanently and hence made satisfactory" need not be classified. Recording it as C1 "for the record" would fail the report for a defect that no longer exists.
For wording on the defects that come up most often, EICR Fails: The Ten Most Common Observations gives a model sentence and code for each, and Borrowed Neutrals: How to Find, Test and Code Them covers the one domestic defect that most often earns an honest FI.
Which codes does BPG4 Issue 7.4 give for the common domestic defects?
The guide is free from Electrical Safety First and is backed by NICEIC, NAPIT, ECA, SELECT, the IET, BEAMA, City & Guilds and EAL among others, which is why both sides of any coding dispute reach for it. The entries you will use most, as they stand in Issue 7.4:
| Defect as found | BPG4 7.4 code | Notes |
|---|---|---|
| No 30 mA RCD for socket-outlets, indoor use only | C3 | C2 where mobile equipment is reasonably expected to be used outdoors |
| No 30 mA RCD for cables concealed less than 50 mm deep without earthed covering | C3 | Regulation 522.6.202 |
| Thermoplastic consumer unit, no thermal damage | NC only, or C3 | C3 beneath a wooden staircase or within an escape route |
| Main bonding to water or gas absent | C2 | Where the service is an extraneous-conductive-part |
| Main bonding present but undersized | C2 | NC only if at least 6 mm² with no thermal damage |
| No circuit protective conductor, Class I equipment on the circuit | C2 | C3 if only Class II equipment and unlikely to change |
| Supplementary bonding absent in a bath or shower room | C2 | Unless the Regulation 701.415.2 conditions for omission are met |
| Blank missing, live parts accessible | C1 | C2 where a blank is present but not secured on a non-lockable unit |
| Evidence of overheating at an accessory or connection | C2 | |
| Ring final circuit with a discontinuous conductor | C2 | |
| Zs too high for the device, no RCD on the circuit | C2 | |
| Circuits not identified at the consumer unit | NC only |
Two things follow. First, the age of the installation is never the reason for a code; the risk is. Second, where BPG4 gives a code, departing from it is allowed but has to be explained in the observation, because the reader will check. "C2: thermoplastic consumer unit" with no mention of thermal damage or location reads as a code chosen before the inspection.
How do observations drive the outcome?
The overall assessment is now a mechanical consequence of two codes only: any C1 or C2 means unsatisfactory; C3 and FI items alone mean satisfactory with improvements recommended or investigation advised. Coding everything C2 "to be safe" hides the genuine risks among trivial ones and costs credibility when the remedial electrician disagrees with half of them. Coding everything C3 to give a landlord the satisfactory report they want is a false statement on a document the 2020 Regulations rely on, and the first thing a local authority officer looks for. See Unsatisfactory EICR: What Happens Next for what follows an unsatisfactory outcome, and Landlord EICR Regulations England for the duties the report triggers.
FI has changed character rather than disappeared. Under A2 it failed the report, so inspectors were pushed to avoid it; under A4 it does not, so the temptation runs the other way, towards parking anything awkward under FI and moving on. Wiring Matters 110 is clear that this is not what the code is for. Use it when a limitation genuinely stopped you classifying something that might be dangerous, state what you found, what you tried and what needs to happen, and expect to be asked why you could not resolve it on the day.
A short checklist before you sign
Read each observation and ask whether a stranger could walk to the defect from the words. Check that every coded item in the schedules has a Section K entry with the same code, and the other way round. Confirm each C2 is a C2 by BPG4 or has a sentence explaining why not. Confirm there are no "various", no "upgrade to current regs", no double codes and no repair designs. Check the summary count matches the list. Then check the schedule of test results supports what the observations say, because item 6 and item 9 above are only as good as the figures behind them; How to Fill In a Schedule of Test Results covers that side.
How Certio helps
Certio produces the EICR, EIC, Minor Works certificate and PAT records on the BS 7671 model forms and turns them into branded PDFs. Photograph the consumer unit and the circuit schedule drafts itself; point the phone camera at a Megger MFT-X1 and the reading goes straight into the schedule of test results, or dictate it while your hands stay on the probes. Suggested observation wording with the regulation reference is there for you to check and confirm. The judgement stays yours; the typing goes. Starter is £4.99 a month, charged when you sign up.