CDM client duties are the legal responsibilities placed on the person or organisation having construction work carried out. In UK construction, the client is not a passive buyer of building work. Under the Construction (Design and Management) Regulations 2015, the client must make sure suitable arrangements are in place so the project can be planned, managed and monitored safely. The client’s decisions can shape the whole risk profile of a project. Appointment choices, budget, programme, access to information, procurement route and time allowed for design and construction all affect whether the work can be delivered safely and properly controlled.
Quick answer: CDM client duties require the client to make suitable project arrangements, appoint competent dutyholders, provide pre-construction information, allow enough time and resources, ensure welfare is available and make sure construction work does not start until the correct planning arrangements are in place.
Who Is the Client Under CDM?
The client is the person or organisation for whom a construction project is carried out. On a commercial project, this may be a developer, landlord, asset owner, public authority, school trust, hospital trust, contractor-developer, managing agent or business commissioning refurbishment, maintenance or construction work. A commercial client carries full client duties because they influence how the project is procured and managed. They decide who is appointed, what information is released, how much time is allowed, how the work is funded and how project control is structured.
A domestic client is different. Where construction work is carried out for someone’s own home and not as part of a business, the client duties normally transfer to other dutyholders. This distinction matters because many small projects still need CDM control even where the person paying for the work is not expected to manage those duties directly. For a simple explanation of when the regulations apply, see When Do CDM Regulations Apply on a Construction Project?.
The Main CDM Duties for Clients
The client’s main duty is to make suitable arrangements for managing the project. That means the project must be set up so health and safety is considered during planning, design, procurement, construction and handover, not added later as a paperwork exercise.
In practical terms, a client should make sure the right people are appointed, the right information is available, sufficient time and resources are allowed, welfare arrangements are provided, and construction work does not start until the construction phase plan is in place. Where more than one contractor is involved, the client must also make sure a principal designer and principal contractor are appointed. These appointments are critical because multi-contractor projects create design, sequencing, access, welfare, temporary works and site coordination interfaces that need clear control.
| Client Duty | Practical Meaning | Typical Evidence |
|---|---|---|
| Make suitable arrangements | Set up the project so risk is planned, managed and monitored. | Project brief, procurement records, appointment letters and meeting records. |
| Appoint dutyholders | Appoint competent designers, contractors, principal designer and principal contractor where required. | Competence checks, appointment documents and scope confirmations. |
| Provide pre-construction information | Give designers and contractors relevant information about the site, structure, hazards and constraints. | Surveys, drawings, asbestos information, existing records and site constraints. |
| Allow time and resources | Avoid creating unsafe pressure through unrealistic programmes or under-resourced procurement. | Programme reviews, procurement strategy and evidence of realistic sequencing. |
| Check construction planning | Make sure construction does not begin before the construction phase plan and welfare arrangements are in place. | Construction phase plan, welfare confirmation, RAMS and mobilisation records. |
Why Client Decisions Create Construction Risk
Many construction risks begin before anyone arrives on site. A client who rushes design, withholds information, appoints late, compresses the programme or treats surveys as optional can create conditions where contractors are forced to manage unknown risk during delivery. This is why CDM places duties on clients. The client may not be designing the structure or installing the works, but the client normally controls the environment in which those decisions are made. If the project is badly set up, the site team inherits the consequences.
For example, if a refurbishment project starts without reliable existing-structure information, asbestos information, service records or access constraints, the contractor may only discover critical issues once intrusive work has begun. That can lead to unsafe changes, delay, cost escalation and weak evidence if the project is later challenged. The wider meaning of CDM is explained in CDM Meaning in Construction: What CDM Stands For and Why It Matters.
Pre-Construction Information Is a Client Responsibility
Pre-construction information is one of the most important parts of the client role. It helps designers and contractors understand existing hazards, known risks, site constraints and information needed to plan the work safely.
On a simple job, this may include access arrangements, existing drawings, service information, asbestos records and operational constraints. On a complex London project, it may include structural surveys, fire safety information, neighbouring property constraints, temporary works requirements, logistics restrictions, existing health and safety files and building safety evidence. The client does not need to personally produce every technical document, but they must make sure relevant information is obtained, assembled and provided to the right dutyholders. A contractor cannot properly price, plan or manage work if important risk information is missing at tender or mobilisation stage.
Client Duties and Appointment of the Right People
A client must appoint people with the right skills, knowledge, experience and organisational capability for the work. This does not mean simply choosing the cheapest tender or assuming a familiar contractor is suitable for every package. Competence should be judged against the actual work. A contractor who is suitable for minor repairs may not be suitable for structural alteration, façade remediation, temporary propping, high-risk access, intrusive investigation or complex occupied-building works without the right systems and experience.
Where more than one contractor is involved, the principal designer and principal contractor appointments should be made early enough to influence risk control. Late appointments can weaken design coordination, pre-construction information, temporary works planning and construction phase control. A broader dutyholder overview is set out in CDM Regulations Explained: What Construction Professionals Need to Know in 2026.
Common CDM Client Mistakes
The most common client mistake is assuming CDM belongs to the contractor only. Contractors have important duties, but the client still influences how the project is set up before construction begins.
Other common failures include appointing dutyholders too late, not checking competence properly, issuing incomplete information, forcing unrealistic programmes, failing to clarify who is principal designer or principal contractor, not checking that a construction phase plan exists, and treating welfare as a site problem rather than a project requirement. On higher-risk or technically complex projects, these weaknesses can also create a poor evidence trail. If the project later faces delay, dispute, safety review or regulatory scrutiny, the absence of clear client-side decisions can become a serious problem.
Practical Example: Refurbishment Client Duties
A landlord planning structural alterations inside an occupied building should not simply appoint a contractor and wait for works to start. The client should make sure relevant existing information is gathered, designers understand the constraints, any required surveys are commissioned, access and occupation risks are considered, and the contractor has enough time to plan the work.
If temporary propping is required, the client should expect the dutyholders to coordinate design information, sequencing, inspections and sign-off. If intrusive works are required, the client should make sure the contractor receives relevant information about services, asbestos, structure and building operation. The client is not expected to become the structural engineer or site manager. But the client is expected to create the conditions in which competent people can manage the risks properly.
Evidence-Based Summary
CDM client duties matter because the client controls many of the early decisions that shape construction risk. While clients often assume safety is mainly a contractor issue, the project can already be unsafe before work starts if appointments, information, time, resources and planning arrangements are weak. The safest client approach is to treat CDM as a project setup duty: appoint the right people, provide the right information, allow realistic time and make sure construction does not begin until the site arrangements are genuinely ready.
FAQ: CDM Client Duties
Who is the client under CDM?
The client is the person or organisation for whom a construction project is carried out. On commercial projects, the client has full CDM client duties.
What are the main CDM duties of a client?
The main duties are to make suitable project arrangements, appoint competent dutyholders, provide pre-construction information, allow enough time and resources, ensure welfare arrangements and check that construction planning is in place before work starts.
Does the client need to prepare the construction phase plan?
The contractor or principal contractor normally prepares the construction phase plan, but the client must make sure construction work does not start until suitable arrangements are in place.
Does a domestic client have the same duties?
Domestic client duties normally transfer to other dutyholders, such as the contractor, principal contractor or principal designer, depending on the project structure.
Can a client be responsible if they appoint the wrong people?
Yes. A commercial client must take reasonable steps to appoint people with suitable skills, knowledge, experience and organisational capability for the work being carried out.
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Expert Verification & Authorship: Mihai Chelmus
Founder, London Construction Magazine | Construction Testing & Investigation Specialist |
