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Part of our CDM 2015 series. See CDM Regulations 2015 explained for every duty holder and key document in one place.
Under CDM 2015 the client is the person or organisation for whom a construction project is carried out. Clients have more influence than anyone over how a project is set up: they choose the team, set the budget and decide the timescale. That is why CDM gives them real duties, rather than leaving safety to the contractors.
Commercial clients and domestic clients
| Type of client | Who it covers | What happens to the duties |
|---|---|---|
| Commercial client | Any client having work done as part of a business, whether for profit or not, including landlords, schools, charities and public bodies | Must carry out the client duties themselves |
| Domestic client | Someone having work done on their own home, or a family member’s home, not in connection with a business | Duties pass to the contractor on a single contractor job, or to the principal contractor. The principal designer can take them on by written agreement. |
Every client duty at a glance
| Duty | What it means in practice |
|---|---|
| Make suitable arrangements for managing the project | Set up the project so it can be carried out safely, including allowing enough time and resources. Keep the arrangements under review. |
| Appoint the right people | Make sure designers and contractors have the skills, knowledge, experience and organisational capability for the work. |
| Appoint a principal designer and principal contractor | In writing, as early as possible, wherever there is or is likely to be more than one contractor. |
| Provide pre-construction information | Give every designer and contractor the information you have, or can reasonably obtain, that is relevant to health and safety. See our pre-construction information guide. |
| Make sure a construction phase plan exists | The construction phase must not start until a construction phase plan has been drawn up. |
| Make sure welfare is provided | Toilets, washing, drinking water and rest facilities must be in place from the start of the construction phase. |
| Make sure the health and safety file is prepared | Where there is a principal designer, make sure the health and safety file is prepared, kept up to date and handed over. |
| Notify HSE where required | Submit an F10 notification for notifiable projects before the construction phase begins. |
| Take reasonable steps to check the principal designer and principal contractor are doing their jobs | Ask questions, attend meetings and act if things are going wrong. |
If you do not appoint a principal designer or principal contractor
A client who should appoint a principal designer or principal contractor and does not must carry out those duties themselves. For most clients that is a serious undertaking, so early written appointments are the safer route.
What suitable arrangements look like
- A realistic programme that allows time for design, planning and mobilisation
- A budget that covers welfare, temporary works and safe access, not just the permanent build
- Clear lines of communication and regular progress meetings that include health and safety
- A way of checking that the appointed team is competent and doing what it said it would
- Arrangements that are proportionate: a small refurbishment needs less than a major development
Common client failures
- Squeezing the programme so contractors cut corners to finish on time
- Withholding or not looking for information, such as asbestos surveys or drawings of existing services
- Choosing on lowest price without checking competence
- Not appointing a principal designer at all, so nobody coordinates design risk
- Treating CDM as the contractor’s problem
Clients and the Building Regulations
In England, clients also have dutyholder duties under the Building Regulations, including appointing a principal designer and principal contractor for building regulations compliance on projects with more than one contractor. These are separate from CDM, though the same firms are often appointed to both roles.
Training that helps
For company directors and senior managers who commission construction work, the CITB Directors’ Role for Health and Safety course explains leadership duties in plain terms. Our CDM awareness eLearning is a quick introduction for anyone managing projects, and the NEBOSH Health and Safety Management for Construction certificate goes into CDM in depth.
Where this fits in SMSTS and SSSTS
Client duties are one of the CDM topics covered on SMSTS and SSSTS. Our free SMSTS mock test and SSSTS mock test let you check your knowledge before the course or a refresher, and you can email yourself the results sheet at the end.
When you are ready, the five day SMSTS course is for site managers and the two day SSSTS course is for supervisors. If your certificate is due, the SMSTS refresher and SSSTS refresher keep it current.
Frequently asked questions
Who is the client under CDM 2015?
The person or organisation for whom a construction project is carried out. That includes businesses, public bodies, charities and householders.
Do domestic clients have duties under CDM?
Technically yes, but the duties pass automatically to the contractor or principal contractor. The principal designer can take them on instead by written agreement.
Can a client appoint someone to carry out its duties?
A client can get help, for example from a consultant, but the legal duties stay with the client.
What happens if a client does not appoint a principal designer?
The client must carry out the principal designer’s duties itself.
Read the source
The Construction (Design and Management) Regulations 2015, regulations 4 to 8; HSE guidance L153, Managing health and safety in construction, Part 1; HSE guidance on CDM for clients and domestic clients; and the Building Regulations etc. (Amendment) (England) Regulations 2023. Facts checked on 6 October 2026.
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