Compliance Guide

CDM 2015 Client Duties: The Full Checklist

A practical guide for UK site managers, contractors and small builders.

Most people searching for a CDM 2015 client duties PDF want one thing: a clear, complete list of what the client is actually on the hook for, without wading through the regulations. This guide gives you exactly that. It walks through every client duty under CDM 2015 in plain English, explains why a printed checklist on its own will not keep you compliant, and shows how to turn each duty into something you can genuinely tick off on a real project.

Who counts as the client under CDM 2015

Under CDM 2015 the client is whoever has construction work carried out for them as part of their business, or the person for whom a project is done. If you commission the work, you are almost certainly the client, and the regulations put you at the top of the chain. The client is not a passive bill payer. CDM deliberately makes the client responsible for setting the tone of the whole project, because the decisions made at the very start shape how safely everything downstream is delivered.

The full list of client duties

Here is the complete set of duties CDM 2015 places on a commercial client. Treat this as your working checklist:

Make suitable arrangements for managing the project. Ensure the work is planned, managed and monitored so it can be carried out safely, and that those arrangements are maintained throughout.
Appoint the right duty holders in writing. Where there is more than one contractor, appoint a principal designer and a principal contractor, and do it in writing before the construction phase begins.
Provide pre-construction information. Give designers and contractors the relevant information you hold about the site and the project so they can plan their work safely.
Make sure a construction phase plan is in place. Ensure the principal contractor, or the contractor on a single-contractor job, has drawn up a construction phase plan before work starts.
Make sure welfare facilities are provided. Ensure suitable welfare arrangements are in place for the whole time the work is being done.
Make sure a health and safety file is prepared. On projects with more than one contractor, ensure the principal designer prepares the file, and that it is kept, updated and passed on.
Check that duty holders have what they need. Take reasonable steps to satisfy yourself that the people you appoint have the skills, knowledge, experience and organisational capability to do their jobs.
Notify the HSE where required. On notifiable projects, make sure the project is notified to the Health and Safety Executive.

When a project is notifiable

A project is notifiable to the HSE if the construction work is scheduled to last longer than 30 working days and have more than 20 workers working simultaneously at any point, or if it exceeds 500 person days. The client is responsible for making sure the notification, known as an F10, is submitted. Notifiable status does not change your other duties, it simply adds the notification step, but missing it is an easy and visible failure to fall foul of.

Domestic clients are treated differently

If you are having work done on your own home and it is not connected to a business, you are a domestic client. Your client duties do not disappear, but they normally pass to someone else. On a single-contractor job the duties transfer to that contractor. Where there is more than one contractor, they pass to the principal contractor, or to the principal designer if there is a written agreement for them to take them on. This is why a small builder working on a house often carries duties the homeowner never realises exist.

Why a PDF checklist is not enough

A downloaded PDF is a useful memory aid, but it does not make you compliant. The duties above are not things you tick once and forget, they are ongoing obligations that produce actual documents and decisions. A checklist cannot appoint your duty holders in writing, cannot generate your pre-construction information, and cannot produce the construction phase plan the law expects to see. When an HSE inspector visits, they do not ask for your checklist, they ask for the evidence that each duty has been discharged. The paperwork is the proof, and the paperwork is exactly the part a static PDF leaves you to do yourself.

Turning the duties into evidence

The practical way to meet your client duties is to make each one produce a record. Your written appointments become letters or emails naming the principal designer and principal contractor. Your pre-construction information becomes a document you hand over. Your check on capability becomes a note of what you saw. Your construction phase plan sits on file before work starts, and your health and safety file is compiled and handed on at the end. Done this way, compliance stops being an anxious guess and becomes a folder you can point an inspector at.

The rule in one line: Under CDM 2015 the client must make suitable arrangements to manage the project, appoint the principal designer and principal contractor in writing where there is more than one contractor, provide pre-construction information, ensure a construction phase plan and welfare are in place, make sure a health and safety file is prepared, check duty holders are capable, and notify the HSE where the project is notifiable.

Frequently asked questions

What are the client duties under CDM 2015?

The client must make suitable arrangements to manage the project, appoint a principal designer and principal contractor in writing where there is more than one contractor, provide pre-construction information, ensure a construction phase plan and welfare facilities are in place, make sure a health and safety file is prepared, check that duty holders are capable, and notify the HSE on notifiable projects.

Is a CDM 2015 client duties PDF enough to be compliant?

No. A PDF checklist helps you remember the duties, but compliance comes from actually discharging them and holding the evidence: the written appointments, the pre-construction information, the construction phase plan and the health and safety file. Inspectors ask for those records, not the checklist.

Do domestic clients have CDM duties?

Domestic clients have duties, but they normally pass to the contractor on a single-contractor job, or to the principal contractor where there is more than one contractor. A written agreement can pass them to the principal designer instead. In practice the builder often carries them.

The shortcut

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This article is general guidance for UK construction and is not legal advice. For requirements specific to your work, check current HSE guidance and your own duty holder obligations under CDM 2015.