Too many people still ask where the law says they need a solar cleaning certificate. That is the wrong question. If one of your staff is electrocuted, falls from height, causes injury or causes a fire, could you prove to HSE, to a client, to a court and to an insurer that they were properly trained and competent for the work?  With at least 4 documented deaths of solar panel cleaners during 2025, this is a relevant consideration.

The industry needs to stop asking: “Where does the law say I need a solar cleaning certificate?”
That is the wrong question.
The laws already exist.
If the work involves electrical danger, competence and training are already on the table.

Solar panel cleaning is not ordinary cleaning

This is the biggest mistake in the market.

Solar panels are not just dirty surfaces that need washing. They are part of a live electrical system. Anyone cleaning them may be working around electrical equipment, cables, connectors, isolators and other hazards, often while also working at height.

That changes everything.

UK government guidance on incidents involving photovoltaic systems states that even when a system has been isolated at the inverter or fuse box, it may remain live between the panels and the isolation point, creating a shock hazard. The same guidance notes that PV panels can continue generating electricity even in low-light conditions. The 2nd Edition of the Building Research Establishment guidance on installing solar panels also verifies this.  That is why solar panel cleaning cannot honestly be treated like ordinary window cleaning or façade cleaning.

Once work is taking place on or near a live electrical system, ordinary cleaning logic is no longer enough.

The law already requires training and competence

The first layer is the Health and Safety at Work etc. Act 1974, Section 2. It places a duty on employers to ensure, so far as is reasonably practicable, the health, safety and welfare of employees, including the provision of information, instruction, training and supervision. That duty is broad, and it does not disappear just because the task is called “cleaning.”

The second layer is the Management of Health and Safety at Work Regulations 1999, Regulation 13. Regulation 13 says employers must take employees’ capabilities into account when entrusting them with tasks and must provide adequate health and safety training when they are recruited or exposed to new or increased risks. In plain English, it is not enough to say a worker is generally good on roofs or has “done a few solar jobs before.” The question is whether they have actually been trained for the specific risks involved.

The third layer is the Work at Height Regulations 2005. Most solar cleaning work is done at height, and the Regulations require that work at height is properly planned, appropriately supervised and carried out in a manner that is safe so far as reasonably practicable. They also require competence for those organising, planning, supervising or carrying out such work.

The fourth layer is The Provision and Use of Work Equipment Regulations 1998, Regulation 9. Regulation 9 of the Provision and Use of Work Equipment Regulations 1998 requires that people using work equipment receive adequate training for health and safety purposes, including training in methods of use, risks and precautions. That matters directly where solar cleaners use poles, access systems, fall protection equipment and other site gear.

Then comes the most important layer of all: the Electricity at Work Regulations 1989, Regulation 14. Regulation 14 restricts work on or near live conductors where danger may arise unless strict conditions are met. Regulation 16 says no person shall be engaged in work where technical knowledge or experience is necessary to prevent danger unless they possess that knowledge or experience, or are under appropriate supervision. That is the heart of the issue. Solar panel cleaning places people on or near a live PV environment. Once that is accepted, competence is no longer optional.

Competence is not something you claim — it is something you prove

This is where many contractors become vulnerable.

It is not enough to say, “My lads know what they’re doing.”

It is not enough for a worker to say, “I’ve been doing this for years.”

It is not enough to rely on common sense after the event.

HSE’s electrical guidance says people working on electrical equipment, machinery or installations must be competent, and that competence should be judged by training to an appropriate level, relevant experience and the ability to achieve a suitable standard in similar work. HSE also says people who cannot demonstrate competence should not be allowed to work unless supervised by someone who is competent.

That means competence must be auditable.

In practical terms, that usually means training records, certificates, assessments, risk assessments, method statements, refresher training records and supervision records. Whether that evidence comes from ISCA or another competent provider is not the main legal point. The point is that a contractor sending people into a live PV environment needs to be able to prove those people were trained for it.

No other electrical industry would accept this standard

There is a simple common-sense test here.

In what other UK industry would people be allowed to work around live electrical danger with no formal training and no proof of competence?

Not mainstream electrical contracting. Not high-voltage work. Not industrial maintenance. Not utilities.

So why should solar panel cleaning be treated as a loophole sector where electrical risk is ignored because the task has historically been sold as “just cleaning”?

It should not.

In reality, solar cleaning can combine electricity, water, roof access, slip risks, fragile surfaces, exposed cables, live DC danger, changing weather and pressure to work quickly. That is not a casual add-on service. It is a specialist risk activity.

HSE enforcement shows exactly how this goes wrong

HSE enforcement does not need a regulation with the words “solar panel cleaning” in it before action can be taken.

The wider laws already do the work.

In March 2026, HSE announced the prosecution of two companies after one worker was fatally electrocuted and another seriously injured at a Devon biogas site when a cherry picker struck an 11,000-volt overhead line. HSE said there had been poor supervision, poor monitoring, an unsuitable risk assessment, and that one contractor lacked formal training provision and adequate supervision. One company pleaded guilty to an offence under the Electricity at Work Regulations 1989 by virtue of Regulation 14.

HSE case material on electrical incidents shows the same pattern again and again: weak planning, weak supervision, poor competence, no safe system of work, and serious injury or death. The industry label may differ from site to site, but the enforcement logic is the same. If work involves electrical danger, HSE will look at training, supervision, planning, risk assessment and proof of competence.

Insurance makes the issue even more serious

There is another side to this that contractors often overlook: insurance.

It would be too broad to say that every breach of health and safety law automatically makes every insurance policy invalid. That is not the correct legal position.

But it is correct to say that working outside health and safety law, using untrained staff, failing to take reasonable precautions, or presenting the risk inaccurately to the insurer can give insurers grounds to dispute, reduce, suspend or avoid cover depending on the wording and the facts. The Insurance Act 2015 requires a fair presentation of the risk before a non-consumer insurance contract is entered into, and gives insurers remedies where that duty is breached.

That matters because employers’ liability insurance is compulsory for most employers in the UK, but compulsory insurance does not magically solve everything after a serious incident. HSE explains that employers’ liability insurance exists to insure against liability for injury or disease suffered by employees arising out of their employment. It does not stop HSE prosecuting, and it does not prevent the business facing legal costs, rising premiums, reputational damage or contract loss.

Many liability policies also contain wording that ties cover to reasonable care, legal compliance and competent staffing. Zurich’s public and products liability wording, for example, says the insured must exercise reasonable care that only competent employees are employed and take all reasonable steps to prevent accidents and comply with statutory obligations. That kind of wording makes poor training and poor supervision an insurance issue as well as a safety issue.

At the same time, the Insurance Act 2015 also prevents insurers from relying on terms that are irrelevant to the actual loss in some situations. So the position is not “one breach and all cover disappears.” The real point is narrower and more dangerous: if a solar contractor is using untrained staff in a live PV environment, and a serious electrical or fall incident happens, insurance may become another battleground rather than a safety net.

The bottom line

UK solar panel cleaners need to stop asking:

“Where does the law say I need a solar cleaning certificate?”

That is the wrong question.

The right question is:

If one of my staff is electrocuted, falls from height, causes injury, or causes a fire, how will I prove to HSE, to a client, to a court and to an insurer that this person was properly trained and competent for the work?

If that cannot be answered clearly, and with documents, you’re exposed.

Solar panel cleaning safety training in the UK is not a nice extra. It is not just a marketing badge. It is not something to think about after an accident.

If you are cleaning solar panels, you are working around live electrical danger. UK health and safety law already requires training, competence, supervision, risk assessment and safe systems of work for that kind of activity. And when something goes wrong, poor training or no proof of competence can lead to prosecution, civil claims, insurance problems, lost contracts and life-changing injury or death.

No serious industry should allow live electrical work without formal training and proof of competence.

Solar panel cleaning should not be the exception.  For more information about training or to ask questions about this article, please email info@theisca.org