CDM 2015 Domestic Clients: What You Actually Need to Know

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

The domestic client is the one part of CDM 2015 that trips up homeowners and small builders alike. A homeowner having an extension built assumes the regulations do not touch them, and a builder taking the job often has no idea that the client duties have quietly landed on their shoulders. This guide explains exactly who counts as a domestic client under CDM 2015, why their duties get transferred rather than removed, who ends up carrying them, and what that means in practice on a real domestic job.

Who is a domestic client under CDM 2015

A domestic client is someone who has construction work done on their own home, or the home of a family member, that is not connected to any business. If you are a homeowner having an extension, a loft conversion, a rewire or a refurbishment done purely for yourself, you are a domestic client. The key test is that the work has nothing to do with running a business. The moment the property is a buy-to-let, a business premises or anything commercial, the person commissioning the work becomes a commercial client instead, with the full set of duties that brings.

Do domestic clients have CDM duties at all

Technically yes, but in practice almost never. CDM 2015 does place client duties on domestic clients, then immediately transfers those duties to someone else on the project. The regulations recognise that an ordinary homeowner has neither the knowledge nor the position to manage construction safety, so rather than exempting them entirely, CDM moves the responsibility to the people who are actually running the work. The result is that a domestic client keeps almost nothing to do, while the contractor or principal contractor picks up the real obligations.

Where the duties go

The transfer follows a simple rule based on how many contractors are involved.

• One contractor on the job. The client duties pass automatically to that contractor. On the vast majority of domestic jobs, one builder doing the whole thing, the builder is the one carrying the client duties whether they realise it or not.
• More than one contractor. The duties pass to the principal contractor. This is the contractor in overall control of the construction phase, and CDM expects them to be appointed where more than one contractor is at work.
• A written agreement with the principal designer. The one exception. If the principal designer agrees in writing to take on the client duties, the responsibility sits with them instead of the principal contractor.

What this means for the homeowner

If you are the homeowner, the practical upshot is that you do not have to manage the safety paperwork yourself. You do not appoint duty holders, you do not write the construction phase plan, and you do not notify anyone. That does not make you invisible, though. You should still use a competent contractor, let them get on with managing the job safely, and avoid pushing an unrealistic programme or budget that forces corners to be cut. Choosing the right builder is the single most useful thing a domestic client can do.

What this means for the builder

If you are the contractor on a domestic job, this is where the surprise usually lands. On a single-contractor job you are not only responsible for your own work, you are also carrying the client duties that the homeowner shed. That means making suitable arrangements to manage the project, drawing up a construction phase plan before work starts, providing welfare, and making sure the job is planned and monitored properly. Plenty of small builders discharge these duties in practice without ever naming them, but if something goes wrong, the HSE will look for the evidence, and it needs to exist on paper.

When a domestic project is notifiable

Notification still applies to larger domestic jobs. A project is notifiable if the construction work is scheduled to last longer than 30 working days and have more than 20 workers working at any one time, or if it exceeds 500 person days. On a domestic project the duty to notify the HSE sits with whoever holds the client duties, normally the principal contractor. Most single-dwelling jobs never come close to the threshold, but a large or drawn-out project can, and missing the notification is an easy failure to be caught out on.

Common misunderstandings

The biggest myth is that CDM does not apply to domestic work at all. It does, the duties simply move. The second is the builder assuming the homeowner remains responsible for safety management, when the regulations have already handed that to the builder. The third is treating any job as domestic when the property is actually let out or used for business, which quietly turns the owner into a commercial client with the full duty set. Getting the client type right at the start decides who is responsible for everything that follows.

Frequently asked questions

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.