Do You Know Your CDM Responsibilities? Why Clients Can’t Afford to Get It Wrong

Why Client Responsibility Matters

On any construction project where there is more than contractor on-site (including ‘man in a van’), three key roles carry legal duties under the CDM Regulations:

  • The Client

  • The Principal Designer

  • The Principal Contractor

But here’s something we see far too often: clients not fully realising how much responsibility they hold!

From allocating enough time and resources, to ensuring safety procedures are followed on site, the Client’s role is absolutely critical:  These duties cannot be delegated away - although you can utilise professionals to undertake the role and associated tasks 

Common Misunderstandings

Common confusion is the difference between the Client and Principal Designer roles. While both involve oversight, coordination, and communication, they’re not the same—and mixing them up can lead to gaps in responsibility, or worse, safety failures.

Many clients also assume that reviewing the Construction Phase Plan, submitting the F10 form, and checking health and safety performance is the Principal Designer and/or Principal Contractor’s role.  However, these are all client duties.  While it is common for the Principal Designer role to be extended to deliver the aforementioned, these items are not part of their statutory role.

Real Risks on Short Projects

This is especially important for short-duration work, like school refurbishments during the holidays. The shorter the timeline, the easier it is for people to cut corners or become complacent. Unfortunately, that’s exactly when accidents tend to happen.

We’ve seen first-hand the confusion over duties that can arise on these types of jobs:  We’d much rather ask the awkward questions up front than be in the meeting afterwards asking whose fault it was that someone got hurt.

Abridged Overview of Key Duties

Client Duties (abridged):

  • Appoint competent duty holders (Principal Designer and Principal Contractor)

  • Ensure sufficient time and resources are allocated

  • Ensure health and safety arrangements are in place and maintained

  • Provide pre-construction information

  • Ensure a Construction Phase Plan is prepared

  • Ensure welfare facilities are provided

  • Ensure that the Health and Safety File is prepared and handed over

Our Role as Client CDM Advisors:

  • Administer and support the CDM role and duties noted above process

  • Review pre-construction and construction phase plans

  • Issue the F10 form (as applicable)

  • Carry out site inspections to ensure duty holders meet their obligations

  • Provide ongoing advice and practical support to clients throughout the project

Principal Designer Duties:

  • Plan, manage and monitor the pre-construction phase

  • Identify and eliminate or control foreseeable risks

  • Coordinate health and safety among designers

  • Prepare pre-construction information

  • Contribute to the Health and Safety File

Final Thoughts

Understanding your responsibilities as a client isn’t just about compliance—it’s about protecting everyone involved. If you’re unsure what your role involves, we’re here to help.

We can support you with straightforward, no-nonsense advice and keep your project safe, legal and well-managed from day one.

👉 Get in touch with our team to talk about your next project.


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Inclusion Isn’t a Bolt-On: Why Inclusive Design Must Start from Stage 0