The Client: The Most Misunderstood Duty Holder
- Paul Scanlon
- Jul 30
- 1 min read
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.
Regulation 4 sets out what commercial clients must do:
Make suitable arrangements for managing the project — including allocating sufficient time, not just budget, at each stage.
Appoint a Principal Designer and Principal Contractor in writing, before the construction phase begins, wherever more than one contractor is involved.
Provide pre-construction information to designers and contractors at the earliest practical opportunity.
Ensure welfare facilities are in place before work starts on site.
Check that a Construction Phase Plan exists before the construction phase begins.
Ensure the Principal Designer prepares a Health and Safety File, and take possession of it at project completion.
None of these duties transfer to an advisor, consultant, or project manager by default. They sit with the client.
The most common failure we see is not deliberate non-compliance — it is a genuine misunderstanding of where the client's duties start and end.
If you are currently managing a construction project and are unsure which of these boxes you have genuinely ticked, we can help you check.
Get your free Client Guide to CDM 2015 here: cdm2015.co.uk/resource-download
Comments