Does an FI Code Still Fail an EICR? What BS 7671 Amendment 4 Changes

Amendment 4 to BS 7671:2018 — the “Orange Book” — was published on 15 April 2026. From 15 October 2026, the previous version is withdrawn and Amendment 4 becomes the definitive standard for compliance in the UK. While much of the industry conversation has focused on the headline additions, there is a quieter but arguably more consequential set of changes in Part 6 that every inspection and testing engineer needs to understand.

The Bigger Picture: Part 6 and Chapter 65

Part 6 of BS 7671 governs inspection, testing and certification. Chapter 64 covers initial verification; Chapter 65 covers periodic inspection and testing — the framework underpinning every EICR you issue.

Amendment 4 doesn’t tear up the existing structure. Instead, it refines it. The key changes engineers need to be aware of are:

• Regulation 653.1 — now requires that the notes for the person producing the report (in Appendix 6) are taken into account when preparing the EICR.
• Regulation 653.2 — the report must include guidance for the recipient(s), based on the model in Appendix 6.
• Reworked notes for the person producing the EICR — redrafted and reorganised in Appendix 6 for clarity.
• Explicit allowance for photographic and thermographic images as supporting evidence within the report.
• Clarification on signatures — confirming they belong to the person(s) actually executing the inspection and testing and authorising the report for issue.
• The reclassification of how the FI code affects the overall outcome — covered in detail below.

The FI Code: A Decade-Long Convention Reversed

To understand why this matters, it’s worth recapping the journey.

Since Amendment 3 to the 17th Edition in July 2015, the convention has been clear: any observation classified as C1, C2 or FI rendered an EICR “Unsatisfactory” overall. The FI code — designed for cases where an apparent deficiency could not be fully assessed within the agreed scope of inspection — was treated identically to confirmed danger when it came to the bottom line.

(A small but important technical note: the C1/C2/C3/FI classification codes themselves are not defined in BS 7671. They sit in Table 3.5 of IET Guidance Note 3. What BS 7671 governs is the format and notes of the EICR via Appendix 6 — and it is those notes that have changed.)

For inspectors, the old position created a known tension. An FI is, by definition, a flag of uncertainty, not a confirmed hazard. Yet awarding one carried the same headline consequence as identifying a genuine C2 issue. The result was twofold:

1. Disincentive to use FI properly. Inspectors sometimes avoided FI to spare clients the disruption of an “unsatisfactory” outcome on something that might turn out to be entirely benign.
2. Disproportionate consequences for the client. A labelled MCB with no obvious circuit, an inaccessible cable run, an unidentified isolator — all could tip an otherwise sound installation into “fail” territory pending further work.

What Amendment 4 Actually Says

The redrafted notes in Appendix 6 are clear: the code FI no longer needs to be marked as unsatisfactory. The notes for the person producing the EICR have been rewritten accordingly, and the IET’s own commentary (in Wiring Matters) confirms the position — issuing an FI code for further investigation should not result in an unsatisfactory outcome.

The FI code is no longer a guaranteed fail, but it is not a guaranteed pass either. The decision rests with the inspector’s professional judgement.

If the FI relates to something the inspector reasonably believes is more likely to be safe than not — a circuit that couldn’t be fully traced, a cable concealed within the building fabric, a suspected but unverified deficiency — the report can now be issued as Satisfactory while still flagging the need for further work. If the FI conceals something the inspector genuinely suspects could be a C1 or C2 once investigated, an Unsatisfactory outcome remains entirely appropriate.

Why This Is an Education Issue, Not Just a Coding Change

This is where the spotlight needs to fall on engineer competency, because the change shifts more weight onto judgement — and judgement only delivers safe outcomes when it is properly trained, properly evidenced and properly documented.

The Risk of Misuse

The change has not been universally welcomed in the trade press and on industry forums, and the concerns are legitimate. The phrase “FI everything” has already started circulating — the worry being that some inspectors will use FI as a low-effort exit route. Ten minutes on site, a handful of FIs, a Satisfactory outcome, job done. That is a misuse of the code and a misreading of the amendment.

The FI code’s purpose has not changed. It is for observations where:

• The inspection has identified an apparent deficiency;
• That deficiency cannot be fully assessed within the agreed extent of the inspection; and
• Further investigation is required before the true classification (potentially C1, C2 or C3) can be determined.

It is not a substitute for inspection. It is a flag for limitations on inspection.

What Engineers Need to Be Trained On

Three competencies become more important under Amendment 4:

1. Distinguishing FI from C2. If you can identify the deficiency, you can usually code it. FI exists for genuine uncertainty, not for inconvenience or scope creep.
2. Articulating the reasoning behind the Satisfactory/Unsatisfactory call. When FIs are present and you’ve issued a Satisfactory report, the report should make the basis for that judgement clear. “FI relates to a labelled but untraced final circuit; no evidence of distress at the consumer unit and no other indicators of risk on adjacent circuits” is defensible. “FI on the supply” with no further detail is not.
3. Using supporting evidence properly. Amendment 4’s explicit endorsement of photographic and thermographic images in EICRs is no accident. Where you’ve made a judgement call, visual evidence makes that judgement auditable. This is now best practice, not optional polish.

What Else Is Changing in Part 6

Beyond the FI clarification, several smaller but meaningful changes affect how reports are produced:

• Recipient guidance is now a required inclusion (Reg 653.2). The model in Appendix 6 should be the basis. This is about ensuring duty holders, landlords and end-users genuinely understand what the report is telling them — not just the codes, but what to do about them and on what timescale.
• Photographic and thermographic evidence is formally recognised. This was always permitted in practice; Amendment 4 now states it explicitly. For complex installations, ambiguous findings, or anything sitting on a judgement call, attaching imagery is now strongly advisable.
• Signature requirements are tightened. The signatures on the report must belong to the person(s) actually executing the inspection and testing work and authorising the report for issue.
• Initial verification continues to follow Chapter 64, with no fundamental restructuring — but the redrafted Appendix 6 forms should be adopted as soon as practicable.

Practical Steps for Inspection and Testing Engineers

If you produce EICRs under your competent person scheme registration, the transition window between now and 15 October 2026 is the time to:

1. Update your certificate templates and software to reflect the redrafted Appendix 6 model forms. Most certification platforms are rolling out Amendment 4 updates now.
2. Review your in-house coding policy — particularly the relationship between FI awards and overall outcome. Document how your inspectors should reason through the Satisfactory/Unsatisfactory call when only FI codes are present.
3. Invest in CPD. NICEIC, NAPIT and the IET are running Amendment 4 update training across 2026. Scheme providers will require evidence of Amendment 4 knowledge from October.
4. Standardise the use of photographic evidence. Issue site staff with clear guidance on what to photograph, how to caption it, and how it gets attached to the report.
5. Audit a sample of reports issued under the new framework after a few months. Look specifically at FI usage and whether the reasoning behind the overall outcome is clearly documented.

Closing Thought

Amendment 4’s testing and inspection changes are, on the face of it, modest. There’s no new test method, no fundamental change to the verification sequence, no rewriting of Chapter 65 from scratch.

But the FI clarification in particular reflects a quiet shift in how the standard treats the inspector. It assumes a higher level of professional judgement, and it gives engineers more room to apply it. That trust comes with responsibility — to use the FI code for what it was always meant for, to document reasoning clearly, and to back judgement calls with evidence.

The engineers who treat Amendment 4 as a prompt to raise their game on documentation and CPD will find these changes genuinely helpful. The ones who treat the FI clarification as a shortcut to easier sign-offs will find themselves on the wrong side of an audit, a complaint, or worse.

The Orange Book has set the standard. The rest is on us.

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Author: Alan Woodhams.