Do I need a Legionella risk assessment with a combi boiler?
"I have a combi, so I do not need an assessment" is one of the most common misunderstandings in landlord Legionella advice. The reasoning is half right: no stored hot water genuinely removes the classic breeding ground.
The duty, though, is to assess the water system — not the boiler. This guide explains what is left to look at, and why it usually takes very little time.
The short answer
Yes. A combi boiler heats water instantaneously and removes the stored hot-water cylinder, which usually reduces Legionella risk considerably — but it does not remove the duty to assess the water system.
Risk in a combi property comes from what remains: stagnant water in little-used outlets and dead legs, shower heads and hoses, any cold-water storage, pipework running warm, and the exposure created by showering.
The good news is that the assessment for a typical combi property is short, and it is the situation guided self-assessment suits best.
General information, not legal advice. This guide describes the position in Great Britain. Northern Ireland is regulated by HSENI, and the Republic of Ireland has a separate legal framework — see the country pages.
Why a combi lowers the risk
Legionella bacteria multiply most readily in water held between roughly 20°C and 45°C. A stored hot-water cylinder, especially one running below its intended temperature or with a cool base and sediment, provides exactly that. A combi boiler heats mains water on demand, so there is no reservoir of warm water sitting between uses.
Combi properties also tend to have shorter, simpler pipe runs and no loft tank, which removes two more common problem areas.
What still creates risk
- Little-used outlets — a guest bathroom, an en-suite, a utility or outside tap that goes weeks without flowing
- Dead legs and capped pipework left behind after a bathroom or kitchen refit
- Shower heads and hoses, which hold water between uses, scale up and produce a breathable spray
- Cold water that does not stay cold, for example a run of pipe passing through a warm airing cupboard or a poorly insulated run alongside heating pipes
- Any cold-water storage tank still in place, including a redundant one that was never removed
- Void periods, where the whole system stagnates regardless of how the water is heated
- Occupants who are more susceptible to infection
What to check in a combi property
- 1
Confirm there really is no stored water
Check the loft, airing cupboard and under stairs. Redundant tanks and abandoned cylinders are common in properties converted to a combi.
- 2
List every outlet and how often it is used
Usage frequency matters more than anything else in a combi property, because stagnation is the main remaining risk.
- 3
Look for dead legs
Refits often leave capped pipe behind a panel or under a unit. Water in a dead leg never moves.
- 4
Inspect shower heads and hoses
Scale and biofilm are visible and easy to deal with. Descaling or replacing a head is a cheap, effective action.
- 5
Record hot and cold observations
Note whether the cold runs genuinely cold after a short run, and what the hot outlet reaches, remembering that a blended outlet reads differently.
- 6
Give the tenant simple advice
Run all outlets, including the shower, after a period away, and report any persistent problem with water temperature or appearance.
Combi versus stored hot water at a glance
- Stored hot water
- A cylinder holding warm water between uses. Storage temperature, sediment, cylinder condition and the temperature reaching outlets all matter.
- Combi / instantaneous
- No hot-water reservoir. Attention shifts to stagnation in little-used outlets and dead legs, shower head condition and any cold-water storage.
- Electric instantaneous shower
- Heats on demand at the point of use. The head and hose still hold water between uses and still produce a spray.
How long this takes with LegionellaWise
Describe the system as instantaneous with no storage and the workflow drops the prompts that do not apply, leaving the outlet register, the usage pattern, the shower checks and the observations that do matter.
You end up with a structured, versioned report specific to the property, rather than a generic form with the cylinder questions crossed out.
Questions landlords also ask
Is a combi boiler property automatically low risk?
It is usually lower risk, but not automatically low risk. A combi property that stands empty between short lets, or has a rarely used en-suite shower, can still present a real stagnation risk.
Do I still need to record temperatures with a combi?
Recording hot and cold observations at outlets is still useful evidence that the system behaves as expected. What you do not have is a cylinder storage temperature to record.
What about a combi with a separate cold-water tank?
Then the tank is the thing to look at: lid, insulation, cleanliness, temperature and whether it is actually needed. Many are redundant after a combi conversion and can be removed by a plumber.
Does an unvented cylinder count as a combi?
No. An unvented cylinder stores hot water under mains pressure. It is a stored system, and storage temperature and cylinder condition are relevant to the assessment.
See whether guided self-assessment fits your property
The free suitability check asks a short set of questions about the water system, the building and the occupants, then tells you plainly whether guided self-assessment looks appropriate or whether the property should go to a specialist.
Official sources
- HSE — Hot and cold water systems
- HSE — Legionella and landlords' responsibilities
- HSE — Identify and assess sources of risk
General information, not legal advice. Requirements and guidance differ between jurisdictions — check the country page that applies to your property.
Related reading
Water temperatures
Common HSE reference points for hot and cold water, what a reading does and does not prove, and how to record one properly with TMV and scalding caveats.
How to do the assessment
A step-by-step process for a simple domestic property, from competence and system description through to findings, tenant information and review triggers.
Empty properties and voids
Stagnation during voids, pre-tenancy checks, flushing without creating unnecessary spray, and what to document before a new tenant moves in.
Can I do it myself?
A decision guide built around competence and system complexity, with plain examples of when self-assessment fits and when to use a specialist.