CDM Regulations: What Clients & Designers Need to Know.

Update 4 August 2025 Building Safety, Construction, Housing, Principal Designer, Safety

The Construction (Design and Management) Regulations 2015 (CDM 2015) place clear legal responsibilities on clients and designers to ensure health and safety is considered from the very start of a project. While much of the focus is often on Principal Contractors, clients and designers play a critical role in setting the foundations for safe and compliant construction work.

As we move forward in 2025, increased scrutiny from the Health and Safety Executive (HSE) means clients and designers must be more proactive than ever in fulfilling their duties. In this post, we break down the key responsibilities, common pitfalls, and how to stay compliant in an evolving construction landscape.

CDM Responsibilities for Clients

Under CDM 2015, the client is the driving force behind a project’s health and safety standards. Whether you are a commercial developer, housing association, or local authority, your role is to ensure that health and safety is considered from the outset and effectively managed throughout the project.

Key Client Duties Include:

Appointing the Right Duty Holders– You must ensure that competent Principal Designers and Principal Contractors are appointed in writing.

Providing Key Pre-Construction Information – Relevant safety information must be shared with the project team before work begins.

Ensuring a Suitable Construction Phase Plan (CPP) – The Principal Contractor must develop a robust plan, but the client must ensure it is in place before work starts.

Making Sure Health & Safety Is Managed – You must take steps to ensure that the Principal Designer and Principal Contractor are complying with their duties.

Ensuring a Health & Safety File Is Completed – The Principal Designer is responsible for compiling this, but the client must ensure it is handed over at project completion.

⚠ Failure to meet these duties can result in enforcement action, including improvement notices, prohibition notices, or even prosecution.

CDM Responsibilities for Designers

Architects, structural engineers, and other designers have a legal duty to ensure their designs consider health and safety risks. These responsibilities apply even if the designer has no direct involvement in construction work.

Key Designer Duties Include:

Eliminating and Reducing Risks at the Design Stage – The primary focus should be on designing out hazards rather than relying on risk controls during construction.

Providing Design Risk Assessments – Any residual risks that cannot be eliminated must be clearly documented and communicated to the Principal Designer and Principal Contractor.

Ensuring Designs Are Buildable and Maintainable – Consideration must be given to how structures will be constructed, maintained, and ultimately demolished in a safe manner.

Cooperating with the Principal Designer – Designers must share information and work collaboratively to ensure risks are effectively managed across disciplines.

⚠ HSE has issued penalties to designers who fail to consider construction risks in their work – non-compliance is not just a contractor issue.

Recent CDM Trends & HSE Enforcement

Increased Focus on Client Accountability

HSE has shifted its focus towards client accountability, recognising that a poor safety culture often starts at the top. Clients who fail to ensure adequate health and safety arrangements before work begins can no longer rely on contractors to take the blame.

More Stringent Expectations on Designers

In 2025, multiple designers faced enforcement action for failing to consider build ability and maintenance risks. HSE expects risk assessments to be more than a tick-box exercise – they must clearly outline real-world risks and how they are being mitigated.

Technology Driving Compliance

The use of digital risk registers, BIM-integrated safety planning, and automated compliance tracking is becoming more common. Clients and designers who embrace these tools can improve collaboration, reduce risk, and demonstrate compliance more effectively.

Common Pitfalls Clients & Designers Must Avoid

Even experienced clients and designers can fall into non-compliance traps. Some of the most frequent issues include:

Clients failing to appoint duty holders in writing – Without formal appointments, responsibility can become unclear, leaving clients exposed to legal consequences.

Insufficient pre-construction information – If hazards (e.g., asbestos, ground conditions, existing structures) are not identified early, the entire project is at risk.

Designers ignoring buildability and maintenance risks – A design that looks great on paper but creates unsafe working conditions is a major compliance failure.

Failing to check the Construction Phase Plan – Clients must not assume this document is in place – they have a duty to ensure it is adequate before work starts.

Not reviewing the Health & Safety File – The file must be useful for future maintenance and demolition. A poor-quality file increases long-term safety risks.

How to Stay Compliant & Improve CDM Management in 2025

Ensure Duty Holders Are Appointed Early

Don’t leave Principal Designer and Principal Contractor appointments until the last minute – early involvement improves safety planning.

Strengthen Pre-Construction Information

Invest in thorough site surveys and share all relevant information with the design and construction teams.

Enhance Risk Assessments in Design

Go beyond basic hazard listings – clearly document how risks have been designed out or reduced.

Use Digital Tools for Compliance

Consider using risk registers, digital forms, and BIM safety models to enhance coordination and tracking.

Proactively Engage with the Health & Safety File

Clients should actively review the file, ensuring it provides useful and accurate information for future building maintenance and decommissioning.

Final Thoughts

CDM compliance is not just a contractor responsibility. Clients and designers play a vital role in ensuring that construction projects are planned and delivered safely. With HSE ramping up enforcement, early engagement, thorough planning, and strong collaboration are key to avoiding legal issues and ensuring projects run smoothly.

Need CDM Support?

Whether you’re a client looking to strengthen compliance or a designer needing help with risk assessments, we can help. 

Get in touch to discuss how our expert health and safety consultancy can support your project.