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Appointing a CDM Consultant Does Not Discharge Your Client Duties

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.

The role of CDM Coordinator — the old CDMC who sat between the client and the project team — was abolished when CDM 2015 came into force. It no longer exists as a legal role.

Under the current regulations, a CDM advisor can guide you through your obligations. But they cannot hold them on your behalf.

Regulation 4 is explicit: the commercial client must make suitable arrangements for managing the project, appoint competent duty holders, and maintain oversight throughout. Those duties belong to the client. They do not transfer to an advisor, a consultant, or anyone else.

Appointing good advisors is sensible. Assuming they have absorbed your legal exposure is a costly mistake.

We regularly meet clients who have been told — or have assumed — that a CDM advisor signing off documents means the client's duties are discharged. They are not. The client remains the duty holder.

If you are unsure what your CDM duties actually are on a current project, a gap review is the right starting point.

Get your free Client Guide to CDM 2015 here: cdm2015.co.uk/resource-download

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