Essential CDM 2015 Regulatory Guides UK for Construction Projects

Most Clients Don't Realise… You are commissioning an office fit-out. No groundworks. No structural changes. No demolition. Is CDM 2015 relevant?

Under CDM 2015, the client is not a passive commissioner. They are a duty holder. That distinction matters. It means the client cannot simply hand the project to a contractor and step back.

When did you last properly check the competence of a contractor — not just their insurance certificates and CSCS cards? Regulation 8 of CDM 2015 requires every duty holder to take reasonable steps to verify the skills, knowledge, experience, and organisational capability of those they appoint.

One of the most common questions we get asked is: "We've appointed a CDM consultant — are we covered now?" The short answer is no.

Can the Principal Contractor just delegate the role and walk away from the liability? No. It is a question we hear from contractors and clients alike.

Since CDM 2015 came into force, there have been over 190 prosecutions under the regulations — resulting in more than £16 million in fines. More than 5% have been brought against clients specifically, under Regulation 4.

Pre-construction information is not a nice-to-have. It is a legal duty. Many clients treat it as paperwork the contractor sorts out. The regulations say the opposite.

When did you appoint your Principal Designer — at concept, or once the drawings were already done? Timing is where most client compliance gaps begin.

On a Design and Build contract, who is responsible for design compliance? Most clients get this wrong. The assumption is simple: the contractor takes the design, so the contractor takes the duty.

There is a new client duty under the Building Safety Act, and most clients have never heard of it. It is not enough to appoint a competent Principal Designer and Principal Contractor.

The job stopped at 9am. Not by choice — by order. A commercial client engaged a contractor for a phased refurbishment of an occupied building.

Don't appoint a Principal Contractor, and the role doesn't disappear. It lands on you. This is one of the least understood consequences in CDM 2015.

On a higher-risk building, there is a hard legal stop before you can start construction. Many clients don't know it exists.

A CDM breach is not a fine on a balance sheet. For individuals, it can mean prison. Compliance gets treated as a commercial risk. The regulations treat it as a criminal one.

Most clients receive the Health and Safety File at handover, file it, and never think about it again. That is the mistake.

When the Principal Contractor is on site, many clients assume their CDM exposure is covered. It is not.

"I didn't know I had any CDM duties." We hear it on almost every first call with a new client. If you commission construction work, CDM 2015 makes you a duty holder. There is no opt-out.

Welfare facilities on your construction site are not just the contractor's responsibility to sort out. Ensuring adequate welfare is a client duty under Regulation 4(4) of CDM 2015.