CDM 2015 Client: Who They Are and What They Must Do
The client is the most important duty holder under CDM 2015, and also the most misunderstood. Plenty of people commissioning building work have no idea the regulations put them at the top of the chain, and plenty of contractors end up carrying client duties without realising it. This guide explains exactly who the CDM 2015 client is, why the role carries so much weight, how commercial and domestic clients differ, and what the client is genuinely responsible for from the first decision to the final handover.
Who is the client under CDM 2015
Under CDM 2015 the client is any person or organisation for whom a construction project is carried out. If you are having the work done, you are the client, whether you are a developer, a business expanding its premises, a landlord refurbishing a property or a homeowner having an extension built. The regulations do not care what you call yourself. What matters is that the work is being done for you, because that is what puts you in the driving seat for how safely the project is set up.
Why the client role matters most
CDM deliberately loads the client with responsibility because the client makes the decisions that shape everything downstream. The budget you set, the time you allow, the people you choose and the information you hand over all decide whether the job can be done safely or whether corners get cut under pressure. An overtight programme or a squeezed budget forces risk onto the people on site. That is why the regulations treat the client as the party who sets the tone, not a passive bill payer who signs off at the end.
Commercial clients versus domestic clients
CDM 2015 splits clients into two types, and the difference is significant.
- Commercial clients have construction work carried out as part of a business. They carry the full set of client duties and cannot hand them off. This includes companies, developers, landlords, schools, councils and anyone else commissioning work in connection with a business or undertaking.
- Domestic clients have work done on their own home, unconnected to any business. They still have duties on paper, but in practice those duties pass to someone else, usually the contractor on a single-contractor job or the principal contractor where more than one contractor is involved.
What the commercial client is responsible for
If you are a commercial client, CDM 2015 makes you accountable for a defined set of things. You must make suitable arrangements for managing the project so it can be carried out safely. Where there is more than one contractor, you must appoint a principal designer and a principal contractor in writing. You must provide pre-construction information to the designers and contractors, make sure a construction phase plan is drawn up before work starts, ensure welfare facilities are provided, and make sure a health and safety file is prepared and kept up to date. You also have to satisfy yourself that the people you appoint are actually capable of the work, and notify the HSE on notifiable projects.
How the domestic client role passes on
When a homeowner has work done on their own house, they are a domestic client and the client duties normally transfer away from them. On a job with a single contractor, that contractor takes on the client duties. Where more than one contractor is involved, the duties fall to the principal contractor, unless there is a written agreement for the principal designer to take them instead. This is why a small builder working on someone's home often carries responsibilities the homeowner has never heard of, and why understanding the client role matters just as much for contractors as it does for the people paying the bill.
Common client mistakes
The most frequent failing is treating the client role as purely financial and assuming everything safety related is the contractor's problem. Others include never making the written appointments, handing over no pre-construction information, allowing work to start before a construction phase plan exists, and forgetting the F10 notification on a notifiable project. None of these are difficult to avoid, but each one is a clear breach that an HSE inspector can spot immediately, because each one should have produced a document that simply is not there.
Frequently asked questions
Who is the client under CDM 2015?
The client is any person or organisation for whom a construction project is carried out. If the work is being done for you, whether you are a developer, a business, a landlord or a homeowner, you are the client under CDM 2015.
What is the difference between a commercial and a domestic client?
A commercial client has work done as part of a business and carries the full set of client duties. A domestic client has work done on their own home unconnected to a business, and their duties normally pass to the contractor or principal contractor.
Can a client pass their CDM duties to someone else?
Commercial clients cannot hand off their client duties. Domestic clients do not choose to pass them on; the regulations automatically transfer the duties to the contractor, the principal contractor, or the principal designer under a written agreement.
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.