I would agree you should provide owner with an EIC, but there is no law to say you must, remember BS7671 is not law.
So a non scheme member in England have two legal routes for notifiable work. A scheme member who has the authority to inspect and test third party work (Not permitted in Wales) or the LABC, if using the latter which is likely only way as most the scheme providers will not authorise third part testing and inspecting, either way the inspector can't issue an EIC as he has not done the work, the normal is to use an EICR form which is nearly the same as an EIC form, but this does NOT need to be passed to the owner, it is only given to the LABC and all the owner gets is a completion certificate.
Yes I see there is a problem as new landlord law says
obtain a report from the person conducting that inspection and test, which gives the results of the inspection and test and the date of the next inspection and test;
and the completion certificate does not give results, so a completion certificate is not enough, you would need an EICR doing if renting the property.
n installer who is competent to carry out inspection and testing should give the appropriate BS 7671 certificate to the building control body, who will then take the certificate and the installer’s qualifications into account in deciding what further action, if any, it needs to take. Building control bodies may ask installers for evidence of their qualifications.
So only when the installer is incompetent will the EIC not be completed, however I know when I did work in Wales I had problems getting the LABC to accept my qualifications, if the LABC does not accept the qualifications then the EIC will not be valid even if issued as the completion certificate is not issued using them.
My mother had some work done by social services in Wales, it was to mains power the door bell/intercom and they engaged an electrical firm to do the work. It involved fitting a new socket, and plugging in a wallmart unit to provide 12 volt DC to the door bell unit. The socket was next to consumer unit, and clearly a new circuit, and when complete I inspected it, and felt it was poor workmanship, so plugged in the RCD tester and realised the RCD did not trip.
At that time it was permissible to have a non protected socket if it was labelled as for some thing special, like a freezer, but no label on the socket, so I contacted social services asking for the minor works certificate, and they told me to contact the electrical firm direct, it was clear the socket had been connected to wrong side of CU, however a simply label would have resulted in it complying, however I could not get the minor works and in the end gave up. House was latter rewired.
However if the county council can't provide the owner with a minor works certificate or completion/compliance certificate, what chance is there of them forcing some one else to provide one?
are sold by electrical outlets for "These certificates are for use by electrical contractors not enrolled or registered with NICEIC or Elecsa and for Approved Contractors working outside of their scope of enrolment." but they have NICEIC and Elecsa written on the certificate which is misleading, and people think they are employing a scheme member and they are not.