Your school is the client: CDM 2015 duties on a building project

By Grayling Thomas Architects · November 2026

When a school or academy trust has building work done, it is the client under the Construction (Design and Management) Regulations 2015 (CDM 2015), and the client duties apply to it in full. The school must make suitable arrangements for managing the project, appoint designers and contractors with the right skills, and appoint a principal designer and a principal contractor where more than one contractor is involved. It must also allow enough time and resources, make sure welfare facilities are provided, give pre-construction information to every designer and contractor, see that a construction phase plan exists before work starts, and make sure a health and safety file is prepared and kept. Larger projects must also be notified to the Health and Safety Executive (HSE).

None of this can be handed to a contractor by default. The rest of this article explains what each duty means in a school, who in the school carries it, and what it does to a summer works programme.

Which body is the client

HSE's page on commercial clients' roles and responsibilities sets the test: "A commercial client is any individual or organisation that carries out a construction project as part of a business." A school commissioning a new classroom, a roof or a hall conversion meets it. The only other category is the domestic client, someone having work done on their own home, and for them "the duties normally pass to other dutyholders". That relief is not available to a school.

HSE defines a commercial client as "any individual or organisation that carries out a construction project as part of a business". Confirm which body that is for your school before the project starts. The DfE's advice on health and safety responsibilities and duties for schools says the employer or, in an independent school, the proprietor "is accountable for the health and safety of school staff and pupils". It adds that "The day-to-day running of the school is usually delegated to the headteacher and the school management team." That accountability for health and safety sits alongside the client duties.

In practice, governors or trustees need to know the duties exist and see them reported. The head and the business manager usually do the work: appointing the team, setting the budget and programme, and answering the questions the designers raise.

For the wider questions a board should ask before it approves a project, see what governors should check before approving a school building project.

What are a school's duties as client under CDM 2015?

HSE's reason for putting the weight on the client is control. "Whatever the project size, the commercial client has contractual control, appoints designers and contractors, and determines the money, time and other resources for the project." The client decides how much time and money the project gets, and so decides how safely it can be run.

For every project, however small, HSE says the client must "make suitable arrangements for managing their project, enabling those carrying it out to manage health and safety risks in a proportionate way." Those arrangements include:

• appointing designers and contractors while "making sure they have the skills, knowledge, experience and organisational capability";

• "allowing sufficient time and resources for each stage of the project";

• "making sure that any principal designer and principal contractor appointed carry out their duties in managing the project";

• "making sure suitable welfare facilities are provided for the duration of the construction work".

The client must also "maintain and review the management arrangements for the duration of the project". That last point matters in schools, where a project often stretches across a term change, a change of business manager or a change of scope after the bids come in.

Proportionate is the important word. A single classroom refit does not need a binder of procedures. It does need someone at the school who has checked the team is competent, given them the programme and information they need, and kept an eye on whether they are doing their jobs.

Do you need a principal designer for school building work?

Yes, whenever more than one contractor will work on the project. HSE lists the appointments as "the principal designer and principal contractor on projects involving more than one contractor". In a school that is the normal case. Even a modest toilet refurbishment often brings in a builder, an electrician, a plumber and perhaps an asbestos contractor.

The principal designer runs health and safety before work starts. HSE describes the role as a designer "appointed by the client to take control of the pre-construction phase of any project involving more than one contractor". Among other duties, the principal designer must "help and advise the client in bringing together pre-construction information". HSE says the principal designer is "an organisation or individual (on smaller projects)".

The principal contractor plans and manages the construction phase. With a single contractor, that contractor carries the construction-phase duties itself.

If no one is appointed

HSE's fallback for a missing principal designer covers domestic projects only: "On a domestic client project where the domestic client does not appoint a principal designer, the role of the principal designer must be carried out by the designer in control of the pre-construction phase." No equivalent appears for commercial clients, whose duties "apply in full". A school that does not make the appointment has not avoided the role; the duty, and the risk, stay with the school. Designers also have a duty to "make sure the client is aware of the client duties under CDM 2015 before starting any design work", so a good architect will raise this at the first meeting.

Information before the work and after it

Three documents carry most of the client's paperwork, and only one of them is written by the school.

Pre-construction information. The client must "provide pre-construction information to every designer and contractor either bidding for the work or already appointed to the project". For a school this means what the school already knows: the asbestos register, existing drawings, any previous health and safety file, where services run, how the site is used at drop-off and pick-up, and which areas stay occupied. Schools usually hold more of this than they realise, spread between the site manager, the business manager and old project files.

Construction phase plan. The client must "ensure that the principal contractor or contractor (for single contractor projects) prepares a construction phase plan before that phase begins". The contractor writes it. The school's job is to see that it exists and that work does not start until it does. In a school the plan should deal with segregation from pupils, deliveries, keys and site access.

Health and safety file. The client must "ensure that the principal designer prepares a health and safety file for the project and that it is revised as necessary and made available to anyone who needs it for subsequent work at the site". The school keeps it. When the next project comes along, that file becomes part of the pre-construction information, and a school that can hand it straight over saves the next design team time.

When a project must be notified to HSE

Some projects must also be notified. HSE defines notifiable projects as those "where planned construction work will last longer than 30 working days and involves more than 20 workers at any one time; or where the work exceeds 500 individual worker days". For those, the client must "notify HSE in writing with details of the project" and "ensure a copy of the notification is displayed in the construction site office".

A new teaching block or a large refurbishment will usually pass the threshold. Smaller summer projects often will not, but notification is a separate duty. Every other client duty applies whether or not the project is notifiable.

How does CDM apply to summer works?

Summer works compress everything the regulations care about into a few weeks. The duty to allow "sufficient time and resources for each stage of the project" applies to the design and tender stages as much as to the weeks on site. A school that confirms funding in June and expects a contractor on site in late July has squeezed the pre-construction phase, and the principal designer and contractor have less time to plan the work safely.

Where the work runs on into term time, our guide to building work on a live school site covers phasing, site separation and safeguarding around contractors.

Practical steps for a summer works programme:

• Appoint the design team in the spring term, so surveys, design and tender are done before the summer holiday begins.

• Gather the pre-construction information early, especially the asbestos register, since asbestos discovered once work has started can stop it.

• For each project, check whether more than one contractor is involved and whether it passes the notification threshold.

• Plan for staff and pupils on site. Summer schools, holiday clubs, lettings and staff coming in to prepare classrooms are all part of how the site is used.

• Agree before work starts how the school will judge the site safe to hand back for September, and who will sign it off.

• Ask for the health and safety file at handover, not months later.

Our guide to choosing an architect for a school capital project covers procurement and appointment more broadly.

What our projects show about the client role

At Mendlesham SEN, a community hall was converted into "2 SEN Specialist Classrooms, Group Rooms, Offices and Toilets". "The project was valued at £470,000 and was constructed in 16 weeks." It was "limited to a tight timeframe to enable students to move in to the building at the start of term". The practice provided "support for Planning, Building Regulations and Project Management of the scheme through to handover". A fixed start of term is exactly the kind of deadline where the client's decisions on time and resources determine whether the work can be done safely.

Our modular and small works for schools are planned around the school year. The aim is "strategically planning and scheduling these projects during school holiday periods" so teaching is not disrupted, while the practice coordinates "regulatory compliance, health and safety standards, and any necessary planning approvals". For a school client, that coordination is what leaves the head and business manager free to carry out their own duties properly.

At Dorothy Goodman School, a new building for an existing special school, the practice was CIF bid writer, lead consultant and architect. It was completed in September 2018. The team "worked alongside the headteacher, business manager, teaching staff, and pupils". That is the client side of CDM in practice: the school bringing its knowledge of the site and its users into the design stage.

Related guides

• School Estate Management Standards: what the annual return will ask trusts to show

• Asbestos, RAAC and CIF 2027 to 2028: what the fund will and will not pay for

• Refurbishing a school science block: lab layouts, services and phasing

CDM 2015 client duties at Grayling Thomas Architects

Grayling Thomas Architects is a RIBA Chartered Practice working with schools and trusts on new buildings, extensions, refurbishments and summer works. We explain the client duties at the start of a project, help the school assemble its pre-construction information, and plan programmes that leave time for each stage. See our design and construction service and our education and SEN architecture work. To talk about a project, contact Grayling Thomas Architects.