The Buck Stops With You — Until It Doesn't: CDM 2015 for Homeowners

You didn't ask to become a "client". You asked for a new kitchen, or a loft conversion, or a rear extension that finally makes the downstairs work. But the moment you start commissioning construction work, the law gives you a title and a set of duties attached to it. The good news is that for most homeowners, someone else picks those duties up. The catch is knowing precisely when that happens — and when it quietly stops.

First, the obvious bit: CDM applies to your house

CDM 2015 — the Construction (Design and Management) Regulations — gets talked about as if it belongs to big sites with cranes and gatehouses. It doesn't. It applies to construction projects full stop, and a domestic refurbishment is a construction project. What changes with a house is who carries the load.

What "domestic client" actually means

You're a domestic client if the work is being done on a property you live in, or will live in, and it isn't part of a business. Refurbishing your own home: domestic. Doing up a flat you rent out as part of a portfolio: probably not. Running the work through a limited company: definitely not.

The definition hinges on purpose and use, not on how big the job is or how much you're spending. A £200k basement under your own house is still domestic. A £30k refresh of a rented flat can fall outside it.

The handover nobody tells you about

Regulation 7 does something genuinely helpful. Where a project is for a domestic client, most of the client duties automatically transfer to the contractor — as long as you're not controlling the construction work yourself. Stripped of the legal fog, it works like this:

• One contractor doing the lot. Client duties pass to them. They're now responsible for the things a client would normally do.
• More than one contractor on site. Duties pass to the principal contractor, or if none has been appointed, the principal designer.
• You're directing and coordinating the trades yourself. The handover doesn't happen. The duties stay with you.

That third line is where most of the confusion lives, and we'll come back to it.

What actually moves across

The day-to-day things: notifying the project to the HSE where required, making appointments in writing, making sure there's a construction phase plan, and arranging welfare facilities on site. None of these vanish — they change hands. Which is the point. Somebody competent and paid should be doing them, not you on a Sunday night with a downloaded PDF and a growing sense of dread.

Where homeowners accidentally take the duties back

This is the bit worth reading twice.

You blur the line — and effectively reclaim the client duties — when you:

• Hire trades directly and tell them what order to work in.
• Buy the materials yourself and instruct people how to use them.
• Coordinate deliveries, scaffolding, skips and site access without a main contractor in charge.
• Make design changes verbally, on site, mid-build, with nothing written down.
• Step in as project manager because "honestly, it's easier if I just do it".

None of that is illegal. Plenty of competent homeowners run their own refurbishments and do it well. But if you're effectively in control of the construction phase, the law treats you as the one in control, and the automatic handover doesn't apply. You're the client with client duties — whether you wanted the title or not.

If you'd rather keep the handover, the fix is straightforward: don't do those things. Give one contractor clear responsibility, let them coordinate, and put changes in writing rather than pointing at a wall.

The handful of documents that keep it clean

You don't need a lever-arch file and a legal helpline. You need four or five things sorted before the first skip lands.

1. Who the contractor is — in writing. A signed contract, or at minimum a clear email confirming scope, price and who is responsible for what. If they're absorbing client duties, say so in plain words.

2. Who the principal contractor is, if there's more than one trade. The appointment should be in writing and they should know it's on them. "I assumed you were handling that" is not a defence anyone enjoys having.

3. The construction phase plan. On a domestic refurb this can be two or three pages: site setup, access, the key risks, who does what in an emergency. Ask to see it before work starts, not after the first near-miss.

4. Welfare. Somewhere to wash hands, a toilet, drinking water, somewhere dry to sit and eat. If the plan is your downstairs loo and a kettle, that's a conversation worth having early — particularly if you're living on site through the build.

5. A competence check. Insurance, references, and a sensible answer to "how will you manage this job?". Cheap is not a competence category.

F10: usually no, occasionally yes

Notifying the HSE is required on larger projects — more than 30 working days with over 20 workers on site simultaneously, or more than 500 person-days in total. Most home refurbishments never get near those numbers. A deep basement, a house split into flats, or a long extension with a big crew might. If it's notifiable, the contractor does the notifying. But you should know whether it applies, because "we didn't bother with that" is a useful red flag.

Asbestos: the thing you can't delegate by accident

In any property built before 2000, refurbishment or demolition work should begin with an asbestos survey, and if something turns up, a licensed contractor deals with it. The duty to manage asbestos in domestic premises sits differently from commercial buildings, but the practical rule is simpler than the regulation: don't let anyone drill, cut or smash into unknown materials. Ask for the survey before the quote, not after the dust has settled on the sofa.

The one-line version

You're the client. That means you commission the work, you pay for it, and you're entitled to expect it done properly. You're not the contractor, the designer or the site manager — unless you choose to be by running the job yourself. In which case the duties are yours, and the paperwork follows whether you like it or not.

Decide which of those two you are before anyone picks up a hammer. It's a lot less awkward than working it out afterwards.