Asbestos · Mandatory · Pre-Construction
Asbestos Register
The Asbestos Register is a live document recording the location, type, condition, and risk rating of all known asbestos-containing materials in a building. It must be made available to anyone planning or carrying out work that might disturb ACMs. The register is updated following surveys, re-inspections, removal works, or any change in ACM condition.
Last reviewed: 29 March 2026 — This guide reflects UK law as of this date. CAR 2012 Reg 4 remains current with no amendments enacted as of 29 March 2026. Next scheduled review: 29 March 2027.
| Legal requirement | Control of Asbestos Regulations 2012 (CAR 2012), Regulation 4(8) — the dutyholder must prepare a written plan (which includes the register) that sets out how the risks from asbestos-containing materials are to be managed. |
| What it records | For each ACM: its precise location within the building, the material type, asbestos fibre type, extent and quantity, condition assessment, risk score, recommended management action, current status, and next re-inspection date. |
| Accessibility | Regulation 4(9)(c)(ii) requires the dutyholder to make information about the location and condition of ACMs available to every person who is or may be liable to disturb them. The register must be accessible to maintenance staff, contractors, and building occupants — not archived in a filing cabinet. |
| Update triggers | The register must be updated following any new survey, any disturbance or removal of an ACM, any re-inspection that identifies a change in condition, any building alteration that exposes or affects ACMs, and at each annual management plan review. |
| Nil register | Where a survey concludes that no ACMs are present, the dutyholder must still record this conclusion. A nil register confirms that a survey was carried out and that no asbestos was identified. Without a nil register, there is no evidence that the duty to identify asbestos has been discharged. |
1. The Asbestos Register — Core of the Management System
The asbestos register is the central record of all known asbestos-containing materials (ACMs) within a building or premises. It is populated from the findings of the asbestos management survey and, where applicable, the refurbishment and demolition (R&D) survey. Every ACM identified by the surveyor must be recorded in the register with sufficient detail to allow the dutyholder, maintenance staff, and contractors to identify its exact location, understand its current condition, and know what management action applies to it.
The register serves three critical functions. First, it is the primary tool for communicating asbestos risks to anyone who may carry out work in the building. Before any maintenance, repair, or construction work begins, the contractor or maintenance operative must check the register to determine whether ACMs are present in the work area. Second, it is the mechanism for tracking the condition of ACMs over time — each re-inspection is recorded against the relevant entry, building a history of condition changes. Third, it provides the evidence that the dutyholder has discharged their legal obligation under Regulation 4 of CAR 2012 to manage asbestos in the premises.
The register is not a static document. It must be updated whenever the condition of an ACM changes, whenever an ACM is removed, whenever a new survey is carried out, whenever building work disturbs or exposes ACMs, and at each periodic re-inspection. A register that has not been updated since the original survey was carried out is a register that may contain inaccurate information — which is worse than having no register at all, because it creates a false sense of security. Workers may rely on the register to confirm that an area is free of asbestos when in fact the position has changed.
The register must be held in a format and location that makes it genuinely accessible to those who need it. Regulation 4(9)(c)(ii) requires the dutyholder to make information about the location and condition of ACMs available to every person who is or may be liable to disturb them. This means the register — or a clear summary of it — must be available at the point of work. It must be provided to contractors before they begin work, made available to building management and maintenance staff at all times, and kept in a location that can be accessed without delay.
The register must be accessible, not archived
A register that is filed in a drawer, saved on a server that contractors cannot access, or held only at the building owner's head office does not comply with Regulation 4(9)(c)(ii). The register must be physically or electronically available at the premises and must be actively provided to every person who may disturb an ACM. This includes maintenance operatives, building services engineers, contractors, sub-contractors, and any other worker who may come into contact with building fabric. Failing to make the register accessible is one of the most common Regulation 4 breaches identified by HSE inspectors.
2. What the Register Should Contain for Each ACM Entry
Each entry in the asbestos register should contain sufficient detail to identify the ACM, describe its current condition, and set out the management action that applies to it. The following table describes the fields that a comprehensive register entry should include. While there is no prescribed format for the register under CAR 2012, HSE guidance (HSG264) sets out the information that should be recorded.
| Field | Description |
|---|---|
| Reference number | A unique identifier for each ACM entry, cross-referenced to the survey report sample number and floor plan annotation. This provides traceability between the register, the survey report, the floor plans, and the laboratory results. |
| Location | The precise location of the ACM within the building — including floor level, room number or name, the building element (e.g. ceiling, wall lining, pipe lagging, floor tile), and sufficient description to allow a person unfamiliar with the building to find the material without ambiguity. |
| Material type | The type of product or material in which asbestos is present — for example, insulation board (AIB), textured coating (Artex), cement sheet, floor tile, pipe lagging, rope seal, sprayed coating, gasket, or fire blanket. This affects the risk assessment and the work category (licensed, NNLW, or non-licensed). |
| Asbestos type | The type of asbestos fibre identified by laboratory analysis — chrysotile (white), amosite (brown), or crocidolite (blue). Where laboratory analysis has not been carried out, the material must be recorded as presumed asbestos and treated as the most hazardous type until confirmed otherwise. |
| Extent | The approximate quantity or area of the ACM — expressed in square metres, linear metres, or number of items as appropriate. This information is needed for removal planning, waste disposal calculations, and understanding the scale of the risk. |
| Condition | A description of the current condition of the ACM — good (intact, undamaged, sealed surface), fair (minor damage, slight deterioration), or poor (significantly damaged, deteriorated, friable, or releasing fibres). The condition is based on the most recent inspection and determines the urgency of management action. |
| Risk score | The material assessment score and priority assessment score assigned by the surveyor using the HSE algorithm. The combined score determines the urgency of the management action. Higher scores indicate a greater risk of fibre release and a more urgent need for action. |
| Recommended action | The action recommended by the surveyor based on the risk score — typically: monitor in situ, encapsulate or seal, repair, remove, or restrict access. This is the action that should be implemented through the management plan. |
| Current action | The action that has actually been taken in respect of this ACM — for example: labelled and monitored, encapsulated on a specific date, removed on a specific date with clearance certificate reference. This field tracks what has been done, as distinct from what was recommended. |
| Next re-inspection | The date of the next scheduled re-inspection for this ACM. Re-inspection intervals should be set based on the risk score and the condition of the material — typically 6 to 12 months for ACMs in fair or poor condition, and 12 to 24 months for ACMs in good condition. |
| Survey reference | The reference number and date of the survey report from which this entry was derived. Where the entry has been updated following a re-inspection or further survey, the most recent survey or inspection reference should be recorded, with a history of previous references retained. |
| Last updated | The date on which this register entry was last reviewed or updated. This provides a clear audit trail showing when the information was last confirmed as current. An entry that has not been updated for an extended period should be flagged for re-inspection. |
3. Common Mistakes
Treating the register as a static document
The asbestos register is not a one-time record. It must be a living document that is updated following every survey, every re-inspection, every removal, every building alteration, and every change in the condition of an ACM. A register that has not been updated since the original survey was carried out is likely to contain inaccurate information. ACMs that were in good condition may have deteriorated. ACMs may have been disturbed by maintenance work. New ACMs may have been discovered. Failing to update the register means that workers relying on it may be exposed to risks that are not reflected in the current entries.
Not making the register available to contractors
Regulation 4(9)(c)(ii) requires the dutyholder to provide information about the location and condition of ACMs to every person who is or may be liable to disturb them. This means that every contractor, sub-contractor, and maintenance operative who will carry out work in the building must be given access to the register — or a clear summary of relevant entries — before they begin work. Simply having the register on file is not sufficient. There must be an active process for checking the register against the proposed work area and communicating the findings to the worker. Many dutyholders fail this requirement because the register exists but is not integrated into the contractor induction or permit-to-work system.
Failing to record a nil register when no ACMs are found
Where a management survey concludes that no ACMs are present in the building, the dutyholder must still record this conclusion formally. A nil register confirms that a survey was carried out, by whom, on what date, and that no asbestos was identified. Without a nil register, there is no documentary evidence that the duty to identify asbestos has been discharged. If the building is subsequently sold, leased, or subjected to refurbishment, the absence of a nil register means the new dutyholder or contractor has no evidence that asbestos has been considered, and must commission a new survey from scratch.
Not distinguishing between confirmed and suspected ACMs
Where laboratory analysis has confirmed the presence and type of asbestos, the register entry should state this clearly and reference the laboratory certificate. Where a material has been presumed to contain asbestos (because it was not sampled, or because the sample was inconclusive), the entry must clearly state that the material is presumed to contain asbestos and must be treated as the most hazardous type until confirmed otherwise. Failing to make this distinction can lead to either under-management (treating a presumed ACM as confirmed non-asbestos) or unnecessary removal of materials that may not contain asbestos. Both outcomes are avoided by clearly recording the confirmation status.
Removing an ACM from the register without a clearance certificate
When an ACM is removed from the building, the register entry must not simply be deleted. The entry should be updated to record the date of removal, the contractor who carried out the removal, the method used, and the reference number of the clearance certificate (for licensed removal) or the completion record (for NNLW or non-licensed removal). Deleting the entry removes the audit trail and makes it impossible to demonstrate that asbestos was present and was properly removed. The register should retain a complete history of all ACMs — both current and removed — as a permanent record.
5. Frequently Asked Questions
Who is responsible for maintaining the asbestos register?▾
The dutyholder under Regulation 4 of CAR 2012 is responsible for maintaining the asbestos register. The dutyholder is the person who has the duty to manage asbestos in the premises — typically the building owner, the occupier under a repairing lease, or the person who has responsibility for maintenance and repair by virtue of a contract or tenancy agreement. In practice, the dutyholder may delegate the task of maintaining the register to a facilities manager, building manager, or specialist asbestos consultancy, but the legal responsibility remains with the dutyholder. The dutyholder must ensure the register is accurate, current, and accessible.
What should be done if an ACM is found to be in poor condition?▾
If a re-inspection or report identifies an ACM in poor condition (significantly damaged, deteriorated, friable, or releasing fibres), the dutyholder must take immediate action. The area should be restricted to prevent further disturbance. The ACM should be assessed by a competent person to determine whether emergency encapsulation, sealing, or removal is required. If the material is releasing fibres, the area may need to be evacuated and decontaminated. The register must be updated to record the change in condition and the action taken. If removal is required, it must be carried out by a competent contractor — licensed if the ACM type requires it — and a clearance certificate obtained before the area is reoccupied.
Is there a specific format required for the asbestos register?▾
CAR 2012 does not prescribe a specific format for the asbestos register. The register may be a paper document, a spreadsheet, a database, or a module within a building management system. What matters is that the register contains sufficient information for each ACM (location, type, condition, risk score, action, re-inspection date), that it is kept up to date, and that it is accessible to those who need it. HSE guidance (HSG264) provides examples of register formats. Whatever format is used, the register must be clear enough for a contractor or maintenance operative — who may have no prior knowledge of the building — to identify whether ACMs are present in their work area and what precautions apply.
How should the register be used during a removal project?▾
During an asbestos removal project, the register serves as the definitive list of ACMs to be removed. The removal contractor must work from the register (and the underlying survey report) to confirm the location, type, and extent of each ACM. As each ACM is removed, the register entry must be updated to record the removal date, the contractor, the method used, and the clearance certificate reference number. After the removal project is complete, the register should show a complete history — every ACM that was present, when it was identified, what action was taken, and when it was removed. Entries for removed ACMs should be retained in the register as historical records, not deleted.
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