HSE Enforcement: Over 190 Prosecutions
- Paul Scanlon
- Jul 30
- 1 min read
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% of those prosecutions have been brought against clients specifically, under Regulation 4.
Those are not abstract figures. They represent projects where commercial clients were investigated, prosecuted, and fined for failures in the management arrangements they were required to put in place. Not contractors. Not designers. Clients.
The pattern in CDM enforcement action is consistent. The failures that attract prosecution are not obscure technical breaches. They are fundamental: no written PD appointment, no pre-construction information provided, no Construction Phase Plan in place before work started, no welfare facilities verified. The basics.
In 2023, a client, principal designer, and principal contractor were all convicted following an incident in which a slating contractor fell through a fragile roof. The investigation found that no pre-construction information about the fragile roof had been provided by the client or PD before work began.
The message from the enforcement record is consistent: CDM 2015 treats the commercial client as an active participant in health and safety management — not a bystander. When things go wrong, HSE looks at the client's role in creating the conditions that allowed them to.
If it has been a while since you reviewed your CDM compliance position, we offer a structured gap analysis for commercial clients. Get in touch to find out more.
This post is general information, not legal advice.
Get your free Client Guide to CDM 2015 here: cdm2015.co.uk/resource-download
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