CDM Client Duties: A Pre-Construction Checklist

Before construction begins, a commercial client should be able to show who the CDM client is, how the project will be managed, who has been appointed, why the duty holders are capable, what pre-construction information has been issued, that enough time and resources have been allowed, and that suitable welfare and a Construction Phase Plan will be in place.

The duties apply to commercial projects of every size. Whether a project needs an F10 notification is a separate question from whether the client must make suitable arrangements or appoint a Principal Designer and Principal Contractor.

Appointment is not delegation of the client role

A CDM adviser or Principal Designer can provide substantial support, but appointing them does not generally remove the commercial client's own regulation 4 duties. The client still controls the brief, appointments, programme and resources and must take reasonable steps to check that its arrangements are working.

1. Identify the correct CDM client

A client is anyone for whom a construction project is carried out. A commercial client is an individual or organisation commissioning the work in connection with a business, whether or not the business is run for profit.

There may be more than one client—for example a developer, funder, tenant or landlord with different levels of control. Regulation 4 allows one or more clients to agree in writing to be treated as the only CDM client or clients for most duties. Until that agreement is clear, the project risks leaving decisions, information and appointments between organisations.

The written agreement does not remove every obligation from the other clients. All clients still retain relevant cooperation and information duties. The project should record who controls the brief, budget, appointments, design decisions, programme and access to existing information.

A homeowner commissioning work that is not connected with a business is a domestic client. Most client duties then pass to the contractor on a single-contractor project, the Principal Contractor on a multi-contractor project, or the Principal Designer where there is a written agreement. Landlords, developers, housing associations and businesses working on residential property are not domestic clients merely because the building is a home.

2. Make suitable management arrangements

The client must make suitable arrangements for managing the project so that construction work can be carried out, so far as reasonably practicable, without risks to health and safety. The arrangements should be proportionate to the size, complexity and risks of the work, but they still need to be effective on a small project.

Client decision	What suitable arrangements should address	Useful evidence
Brief and scope	Intended use, project constraints, quality expectations, key risks and what success looks like.	Approved client brief, scope, surveys and decision log.
Time	Realistic periods for design, surveys, coordination, mobilisation and construction.	Programme showing design and pre-start activities, not only the construction duration.
Resources	Budget, competent people, surveys, welfare, temporary works, logistics and safety-critical controls.	Appointments, fee scopes, procurement allowances and mobilisation plan.
Communication	How information, design changes, residual risks, approvals and site feedback move between duty holders.	Responsibility matrix, meeting structure, information schedule and change process.
Assurance	How the client will take reasonable steps to check that the Principal Designer and Principal Contractor carry out their duties.	Progress reviews, action trackers, design-risk reviews and site-assurance reports.

The arrangements must be maintained and reviewed throughout the project. A credible client plan therefore includes review points when the scope, designers, contractors, programme or significant risks change.

3. Make the required appointments in writing

Where more than one contractor will work on the project—or it is reasonably foreseeable that more than one contractor will work—the client must appoint a Principal Designer and Principal Contractor in writing. The trigger is the contractor structure, not the number of designers and not whether the project is notifiable.

The appointments should be made as soon as practicable and before the construction phase begins. If the client fails to appoint, the client assumes the relevant Principal Designer or Principal Contractor duties rather than leaving the role vacant.

Before appointment, the client must take reasonable steps to satisfy itself that each organisation or individual has the necessary skills, knowledge and experience and, where relevant, organisational capability. The evidence should be proportionate to the role and project—not a certificate-only exercise.

A good appointment defines the project, role, authority, deliverables, interfaces, information required, reporting arrangements, duration and handover responsibilities. See the separate guide on when a CDM Principal Designer is required.

4. Prepare and provide pre-construction information

The client has the main duty to provide relevant pre-construction information as soon as practicable to every designer and contractor bidding for or already appointed to the project. It should be understandable, proportionate and relevant to the work—not an uncontrolled data dump.

The information may cover the client brief, existing Health and Safety File, surveys, drawings, structures, services, asbestos, ground conditions, adjoining land, previous use, access, occupied areas, logistics, existing arrangements and significant design or construction constraints.

The Principal Designer should help the client identify, assemble and distribute information on a multi-contractor project, but the client remains responsible for information in its possession and for commissioning proportionate surveys where gaps need to be resolved. Use the detailed guide to pre-construction information to structure this work.

5. Check the project is ready before construction starts

The client should not treat contract award or possession of the site as proof that construction can start. The pre-start review should confirm:

the required Principal Designer and Principal Contractor appointments are in writing and remain appropriate;
current pre-construction information has reached the people who need it;
design risks, missing information and significant assumptions have owners and deadlines;
a suitable Construction Phase Plan has been prepared before the construction phase begins;
suitable welfare facilities will be available from the start and maintained;
the programme and resources support the planned method, logistics and coordination; and
the client has checked whether the F10 notification thresholds are exceeded.

An F10 is only a notification. It is not HSE approval and it does not replace the appointments, information, plan or management arrangements required for the project.

6. Take reasonable steps during delivery

The client is not expected to control the site or duplicate the work of the Principal Contractor. It should, however, take reasonable steps to make sure the Principal Designer and Principal Contractor are carrying out their duties.

The level of checking should reflect the project. Useful evidence can include design-risk and coordination reviews, reports against the programme and information schedule, confirmation that the Construction Phase Plan is updated, action close-out, site-assurance reports and scrutiny of significant changes.

Warning signs include unresolved design information reaching site, appointments that no longer match who controls the work, repeated coordination failures, welfare or mobilisation gaps, safety-critical work proceeding without the required design or plan, and a programme that no longer provides sufficient time.

The client should ask for evidence and decisions, not direct the contractor's work methods. Where a review identifies a gap, responsibility and a realistic close-out date should be agreed and tracked.

7. Manage the Health and Safety File and handover

For a project involving more than one contractor, the client must ensure the Principal Designer prepares, reviews and updates the Health and Safety File. If the Principal Designer's appointment ends before the project finishes, responsibility for the file passes to the Principal Contractor.

At completion, the client should receive the file and keep it available for anyone who may need the information for subsequent construction work. If the client disposes of its interest in the structure, it must provide the file to the person acquiring that interest and explain its nature and purpose.

The file is not a general archive of every site record. It should contain information needed to plan and carry out future work safely. See what the CDM Health and Safety File should contain.

Pre-construction client checklist

Identify every potential client and record any regulation 4(8) agreement.
Approve a clear brief, responsibilities and proportionate management arrangements.
Allow sufficient time and resources for design, investigation, coordination and mobilisation.
Confirm the expected contractor structure and make Principal Designer and Principal Contractor appointments in writing where required.
Check duty-holder skills, knowledge, experience and organisational capability against the project.
Assemble and issue relevant pre-construction information; track gaps and assumptions.
Confirm design-risk management and cooperation arrangements are active.
Ensure the Construction Phase Plan and welfare arrangements are suitable before construction begins.
Complete the F10 where either notification threshold is exceeded and keep it current.
Define how the client will take reasonable steps to monitor the Principal Designer and Principal Contractor.
Set requirements for the Health and Safety File, handover and retention where the project involves more than one contractor.

CDM client duties: a pre-construction checklist.