Construction compliance guide
On domestic work, CDM client duties transfer automatically to the contractor. Here’s what that means, why it matters, and how to stay compliant without drowning in paperwork.
Under CDM 2015, a domestic client is someone who has construction work done on their own home, or the home of a family member, and the work is not connected to a business. This covers the vast majority of residential construction: extensions, loft conversions, kitchen refits, new bathrooms, rewiring, roofing work.
The distinction matters because domestic clients are treated differently under the regulations. They are not expected to understand CDM or manage health and safety on a construction project — so the law shifts those responsibilities to the people who do understand it: the contractors.
One common trap: if a landlord is having work done on a buy-to-let property, they are not a domestic client. That is a commercial client because the property is part of a business. The same applies to anyone having construction work done in connection with a trade, profession, or business activity. If in doubt, ask whether the property is the client’s own home and whether the work is entirely personal — if the answer to both is yes, they are a domestic client.
This is the key point most builders miss. Under CDM 2015 Regulation 7, domestic clients are not required to carry out client duties themselves. Instead, those duties transfer automatically:
All client duties pass to that contractor. If you are the only builder on a domestic project, those duties are yours by default.
If there is a principal contractor, the duties pass to them. If no principal contractor has been appointed, the duties transfer to the contractor in charge of the construction phase.
The domestic client can choose to appoint a principal designer or principal contractor in writing, and if they do, certain duties transfer to those appointees instead. But in practice, on the vast majority of domestic jobs, the builder ends up with client duties by default — because few homeowners know enough about CDM to make formal written appointments.
Once client duties transfer to you, you must:
You cannot blame the homeowner for not doing these things — the law says those duties are yours. This catches a lot of builders out. They assume CDM is something the client sorts out, or that domestic work is somehow exempt. On domestic work, it is not exempt — and the responsibility sits squarely with the contractor.
The good news is that the scale of what you need to do is proportionate. A small domestic job does not require the same level of documentation as a multi-million-pound commercial project. But you do need to have the basics in place.
A Construction Phase Plan for domestic work does not need to be a 20-page document. The HSE has said repeatedly that the plan should be proportionate to the project. For a kitchen extension or bathroom refit, a well-written 1–2 page plan covering the key risks, management arrangements, and welfare provisions is perfectly adequate.
What matters is that the plan is site-specific. A generic template that you use on every job without changing anything will not cut it if the HSE comes calling. The plan needs to reflect the actual risks of the actual project — the site, the work, the people involved.
The Site Book’s Lightweight CPP wizard is designed exactly for this. Answer four questions about your job — what the work is, where it is, who is doing it, and what the main hazards are — and it creates a proportionate, site-specific plan in minutes. No jargon, no 50-page templates, just a clear plan that does the job.
Even domestic projects can be notifiable if they meet the CDM thresholds:
The construction phase will last longer than 30 working days and have more than 20 workers on site at any one time.
The project will exceed 500 person-days in total.
In practice, most domestic jobs will not hit these thresholds. But larger projects — whole-house renovations, major extensions with multiple trades working over several months — sometimes do. If a domestic project is notifiable, an F10 must still be submitted to the HSE before the construction phase begins. The fact that it is a domestic project does not change the notification requirement.
When you select “domestic” as your project type in The Site Book, the system automatically adjusts to match your situation:
Instead of the full commercial CPP template, you get the streamlined domestic version. Four questions, created in minutes, proportionate to the work.
The plan includes domestic-specific welfare provisions — such as using the homeowner’s toilet and washing facilities by agreement — rather than assuming you will have portable cabins on site.
Your documentation clearly records that client duties have transferred to you under Regulation 7. This is important if you ever need to demonstrate compliance to the HSE or an inspector.
The Site Book checks your project details and tells you whether the job is notifiable. If it is, the F10 is pre-filled from your project data.
Common questions builders ask about domestic client duties under CDM 2015.
Technically, domestic clients still have a general duty to appoint competent contractors. However, the formal CDM client duties — producing the Construction Phase Plan, ensuring welfare facilities, managing health and safety — transfer automatically to the contractor under Regulation 7. In practice, the homeowner’s main responsibility is choosing a competent builder. Once work starts, the legal obligations sit with you.
A domestic client can choose to appoint a principal designer or principal contractor in writing. If they do, certain client duties transfer to those appointees instead of to the contractor by default. This is more common on larger domestic projects where an architect is already involved. If the homeowner makes this appointment, it must be in writing, and the appointee must be competent and willing to take on the role. If there is no written appointment, the duties remain with the contractor.
CDM 2015 does not specifically require a written contract between you and the domestic client. However, having a written agreement is strongly recommended for practical and legal reasons. It clarifies the scope of work, confirms who is responsible for what, and provides evidence of your arrangements if anything goes wrong. A written agreement also helps demonstrate that you have planned the work properly, which is one of your core duties under CDM.
You must ensure adequate welfare facilities are available for everyone working on the project. On domestic jobs, this often means agreeing with the homeowner to use their toilet, washing facilities, and somewhere to take breaks. This arrangement should be confirmed before work starts and recorded in your Construction Phase Plan. If the homeowner’s facilities are not available or not suitable, you must make alternative arrangements — for example, a portable toilet and hand-washing station.
In practice, it is extremely unlikely. Because client duties transfer automatically to the contractor under Regulation 7, the HSE would look to the contractor — not the homeowner — if something went wrong. The domestic client retains only a very limited duty to appoint competent people. The HSE has never, to our knowledge, prosecuted a domestic client. The enforcement focus is firmly on contractors and, where appointed, principal contractors and principal designers.
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