Domestic Client Obligations Under CDM 2015: What Homeowners Need to Know

Introduction

The Construction (Design and Management) Regulations 2015 (CDM 2015) impose health and safety obligations on all parties involved in construction projects, including clients. As a homeowner commissioning works on your home, you are a "domestic client" under CDM 2015, a status that limits your direct obligations compared to commercial clients but does not remove them entirely. Understanding what a domestic client must do, and what automatically transfers to others where they don't act, protects both the homeowner's legal position and the health and safety of everyone working on the project.

What Is a Domestic Client?

CDM 2015 defines a domestic client as an individual who commissions construction work on their own home, or a home of a family member — for a purpose not connected to any business or commercial undertaking. This covers the vast majority of homeowner-commissioned extension and renovation projects.

Domestic clients have different (more limited) obligations from commercial clients because they are typically not construction professionals and the regulations recognise that placing full commercial client duties on private individuals would be disproportionate.

What Domestic Clients Do NOT Have to Do

Unlike commercial clients, domestic clients are NOT required to:

• Appoint a Principal Designer (though they can)
• Appoint a Principal Contractor (though they should ensure one is in place)
• Prepare a client brief for health and safety purposes in the formal commercial sense
• Notify the project to the Health and Safety Executive (HSE) where notification thresholds are met — this transfers to the Principal Contractor

What Domestic Clients MUST Do

Even as a domestic client, there are minimum obligations:

• Not prevent duty-holders from meeting their obligations: You must not prevent the architect (as Principal Designer) or the contractor (as Principal Contractor) from fulfilling their CDM duties. For example, you must provide access for pre-construction information gathering (asbestos surveys, structural condition information).
• Provide pre-construction information you hold: You must share any information you have about the health and safety of the site — known asbestos, buried services, structural information, previous works — with the Principal Designer and Principal Contractor so they can plan the works safely.
• Allow Principal Contractor to prepare the Construction Phase Plan: The contractor is required to prepare a Construction Phase Plan before construction starts. You must allow them to do so and not begin construction before this is in place.

Default Transfer of Obligations

Where a domestic client does not appoint a Principal Designer, the CDM duties of the PD transfer automatically to the designer carrying out the largest proportion of design work — in almost all residential cases, the architect. This means the architect becomes the de facto Principal Designer by default, even if the appointment agreement does not expressly state this. The same logic applies to the Principal Contractor role where multiple contractors are involved.

In practice, a well-structured appointment agreement with the architect will explicitly state that the architect accepts the Principal Designer role, removing the default transfer ambiguity.

The Pre-Construction Information Pack

The most practical domestic client obligation is the provision of pre-construction information. Before construction starts, the Principal Designer (architect) compiles a Pre-Construction Information Pack from:

• Information provided by the homeowner — previous asbestos surveys, structural reports, as-built drawings, information about known services or ground conditions
• Information gathered by the design team — topographic surveys, soil investigations, CCTV drain surveys, asbestos management surveys
• Publicly available information — building regulations history, planning history, environmental constraints

The pack is then made available to the Principal Contractor and all other contractors before they start work. The homeowner's contribution is simply to share any relevant information they hold — the design team assembles the rest.

The Health and Safety File

At practical completion, the Principal Designer prepares and hands to the client a Health and Safety File — a record of the project including key health and safety information for future maintenance and works. As the domestic client, you must retain and store this file safely. If you sell the property, the file must be passed on to the new owner.

The H&S File typically contains:

• As-built drawings showing the locations of services (drainage, electrical, gas, water)
• Details of hidden structural elements and materials
• Operating and maintenance manuals for all installed equipment
• Test and commissioning records for services
• Details of any residual risks (e.g. remaining asbestos management areas)

Conclusion

CDM 2015 obligations for domestic clients are deliberately limited — you are not required to become a CDM expert to commission a home extension. The key actions are: provide pre-construction information you hold, do not obstruct the architect and contractor from meeting their CDM duties, ensure the Construction Phase Plan is in place before work starts, and store the Health and Safety File you receive at completion. An architect accepting the Principal Designer role will manage the CDM framework on your behalf, ensuring that all required documents are prepared and that the project is managed safely from design through to completion.