CDM 2015 client duties checklist
Clients influence the time, information, appointments and resources available to a project. This checklist helps commercial clients turn those CDM 2015 duties into visible project actions.
Reviewed 24 August 2026 · By Lloyd GodsallBefore design and procurement move too far
- Define the project outcome, foreseeable constraints and how health and safety will be included in key decisions.
- Allow sufficient time and resources for design, planning, mobilisation and delivery.
- Identify whether the work will involve, or is likely to involve, more than one contractor.
- Check the organisational capability of designers and contractors before appointment, using proportionate evidence.
- Start assembling relevant pre-construction information rather than waiting for the construction team to ask.
The client’s arrangements should be suitable for the project and maintained throughout it. The duty is not discharged by appointing other parties and stepping away.
Make the right written appointments
Where more than one contractor is involved, or is reasonably foreseeable, the client must appoint a principal designer to control the pre-construction phase and a principal contractor to control the construction phase. Appointments should be made in writing and as soon as practicable. Confirm the organisation has the skills, knowledge, experience and organisational capability for the role—not just the right words in a proposal.
If the client does not make the required appointments, the regulations can place the associated duties back on the client. Keep the scope and timing of each appointment clear when design and construction phases overlap.
Provide useful pre-construction information
- Existing drawings, surveys, asbestos information and health and safety files
- Known services, ground conditions, structures and previous use
- Site access, occupation, security, public and operational interfaces
- Client standards, permits, shutdowns and working restrictions
- Design assumptions, significant residual risks and planned sequencing constraints
Provide information as soon as practicable and make sure it reaches every designer and contractor who needs it. The information should be relevant, proportionate and clear enough to influence design and planning. See the full pre-construction information checklist.
Before construction starts
- Ensure a suitable construction phase plan has been prepared.
- Confirm the principal contractor’s proposed management arrangements match the project.
- Ensure suitable welfare facilities will be available from the start and maintained.
- Resolve obvious information gaps, interfaces and design decisions that could undermine safe mobilisation.
- Check whether the project is notifiable and, if it is, ensure the notice is submitted and kept up to date.
A project is generally notifiable where work is scheduled to last longer than 30 working days with more than 20 workers working simultaneously at any point, or exceeds 500 person-days. Notification does not create or remove the other CDM duties.
During construction
Use proportionate assurance, not day-to-day control of the principal contractor. Ask whether the agreed arrangements remain effective, whether key appointments and resources are still suitable, whether information is reaching the right people and whether significant changes are being managed. Client decisions on programme, scope and budget can introduce risk, so record material decisions and their consequences.
At handover and completion
- Ensure the health and safety file is prepared, reviewed and handed over.
- Confirm the file is understandable and useful for future work, not simply a document dump.
- Retain the file and provide it to anyone who needs it for later construction work.
- Capture unresolved restrictions, maintenance needs and residual risks.
Evidence that the arrangements are working
Keep clear appointment letters, competence checks, information issue records, meeting actions, design-risk decisions, construction phase plan assurance and handover records. The aim is not paperwork for its own sake; it is showing that the client created and maintained suitable arrangements.
Read the official HSE client duties guidance and the Construction (Design and Management) Regulations 2015. For project-specific help, see our CDM support service.