CDM 2015 Post-Implementation Review What the Ten Year Review Means for the UK Construction Industry

The Health and Safety Executive published its second Post-Implementation Review (PIR) of the Construction (Design and Management) Regulations 2015 which is commonly known as CDM 2015.

The review assesses whether the regulations remain fit for purpose and was a statutory requirement under Regulation 39 of CDM 2015, mandating a review every five years from the date the regulations came into force.

If you have been following industry developments, you might be wondering whether this review signals major changes on the horizon for how you manage health and safety on your construction projects?

The review does not recommend any legislative changes.

CDM 2015 remains fit for purpose and will continue as the regulatory framework for construction health and safety.

However, the review has identified several areas where industry understanding and practice could be improved, particularly around the Principal Designer (PD) role, Client obligations, and the management of project information.

In this blog, I want to look at what the PIR found, what it means for the UK construction industry, and how you can prepare for the regulatory expectations that lie ahead.

What Is the CDM 2015 Post-Implementation Review?

The Construction (Design and Management) Regulations 2015 came into force on 6th April 2015, replacing CDM 2007. The regulations were introduced to simplify the legal requirements, reduce regulatory burdens, and improve compliance and health and safety outcomes across the construction industry.

The first PIR was completed in 2020. That review found that the regulations were broadly beneficial for managing health and safety risks on construction projects and confirmed that they were considered effective in protecting workers on site.

However, it was originally intended as an interim review because it was unclear at the time what impact EU withdrawal, the Hackitt Review, and the Grenfell Public Inquiry would have on CDM 2015.

This second PIR, published in 2025, builds on the findings of the 2020 review and addresses comments made by the Regulatory Policy Committee.

It uses a mixed-method approach, combining qualitative group interviews with CDM duty holders and a quantitative survey of 100 employers from the Construction Industry Training Board's (CITB) panel.

The overall recommendation is clear: CDM 2015 should remain in place.

What Did the Review Find?

The evidence gathered for this PIR indicates that the overall objectives of CDM 2015 are still being met and that the regulations remain fit for purpose.

However, the review has identified several areas of concern that industry and regulators need to address.

1. Principal Designers Are Being Appointed Too Late

One of the most consistent findings across both the qualitative interviews and the quantitative survey was that Principal Designers (PDs) are not being appointed early enough in the construction process.

The survey found that only 27% of respondents said clients "always" appoint PDs at the outset or concept stage of a project, with a further 12% saying this happens "frequently".

That means nearly 40% of respondents indicated that PDs are only "occasionally", "hardly ever" or "never" involved at the earliest stages of a project.

This matters because the PD role was intended to ensure that safety is considered as early as possible in the life of a building project so that safety can be "designed in" rather than bolted on later.

When PDs are appointed too late, they cannot influence design decisions that could have eliminated or reduced risks at source.

The qualitative interviews reinforced this finding. Respondents noted that PDs tend to be appointed shortly before building work begins, often too late to make significant changes.

Part of this is due to the wording of CDM guidance, which says that the PD should be appointed "as early as possible" but before the construction phase starts leading some clients to appoint PDs "...just over a week before construction is about to start".

2. Competence of the Principal Designer Role Is a Concern

The review found significant issues with the competence of those taking on the PD role. The lack of prescriptive requirements within the associated guidance for CDM 2015 has meant that unqualified or inexperienced people are taking on or applying for PD roles.

Designers described a "drive to the bottom", citing that some organisations provide day courses on the role, which some individuals attend and then undercut established PD individuals and organisations. This results in individuals describing themselves as PDs, providing cheaper services to building project clients but ultimately producing poor work.

Contractors noted that surveyors are increasingly taking on the PD role, frequently offering their services as a package to clients and fulfilling the clients' legal duties to appoint a PD, but not really influencing the design aspects of the project.

The review also highlighted that a reliance on construction skills cards, competency scheme memberships and registrations has meant that "...it's become more tick-box than 'can you actually do the job?' ”

3. Clients Don't Always Understand Their Duties

The review found that many clients do not properly understand their duties under CDM 2015. The most prominent issue was around clients who are ill-informed and do not understand what their obligations are.

There are no competency requirements on clients.

Designers spoke about clients seeing the services of a PD as a "forced purchase", due to their failure to understand the necessity of the pre-construction planning process, with clients consequently engaging the cheapest principal design services available.

Respondents also noted a rise in the use of third parties, or "client advisors", who work on behalf of the client and procure work, make planning decisions, etc. These external advisors were described as a "...dark area of the industry" operating quite "opaquely", especially in terms of legal duties which still sit with the actual client.

A client can novate a duty to a third party but it will always be the clients responsibility

4. Information Products Have Become Generic and Unwieldy

The review found that many of the information products within CDM such as Pre-Construction Information (PCI), Construction Phase Plans, and the Health and Safety File – have become too generic, large, and unwieldy.

Respondents highlighted that industry has "fallen into a trap" of producing generic information products in which only the projects' titles are changed.

Designers talked about information simply being "copied and pasted" between different documents and different projects. This has led to irrelevant material being collected, and new material simply being layered on top of older material.

The amount of information therefore grows and makes it more difficult to find what is needed.  As one contractor stated, "you end up having to search through a 'war and peace' sized document".

This issue is further exacerbated by system incompatibility between organisations, both IT and administrative, which makes integration cumbersome.

5. The Building Safety Act Has Created Some Confusion

The Building Safety Act 2022 (BSA) has introduced a separate Principal Designer role, which has created some confusion with the PD role in CDM 2015.

 While 80% of survey respondents felt they understood the roles and responsibilities under both BSA and CDM, the qualitative interviews revealed that there is confusion around the competency requirements for the two roles.

It should be noted that while a PD role is prescribed in both BSA 2022 and CDM 2015, these roles are separate and require different competencies. It may be possible for a single company or individual to undertake both these roles if they are able to demonstrate the relevant competencies for each regulatory regime.

That said, respondents indicated that there may be value in combining CDM 2015 and the BSA 2022 related requirements sometime in the future – this would provide a single set of requirements for all buildings.

Authors thought: It has been my view since 2023 that in the end, the CDM regulations and the Building Safety Act will at some point be combined into one regulation.

6. The Abolition of the CDM Coordinator Role Has Not Had a Major Cost Impact

One of the big changes in CDM 2015 was the abolition of the external CDM Coordinator (CDM-C) role. This was done to ensure that health and safety coordination was done by members of the active internal project team, rather than an external consultant.

The survey found that 74% of respondents said the removal of the CDM-C role "didn't change our costs". 

However, the survey also suggested that the PD role may have become like the former CDM-C role. Done by an external consultant rather than by the PD on the internal project team.

What the Review Means for Your UK Construction Companies

The PIR's overall recommendation is for CDM 2015 to remain in place and there will be no legislative changes. However, the review has identified several areas where HSE intends to take action through improved guidance. Here is what that means for the construction industry.

1. Expect Enhanced Guidance on the Principal Designer Role

The review recommends that guidance should be strengthened to "clarify the complexity of the pre-construction phase of the project and re-emphasise the need for early input from a competent PD".

This means you should expect clearer guidance on:

• When a PD should be appointed. At the concept stage, not just before construction

• What competence actually looks like for a PD. Moving beyond tick-box qualifications

• The difference between the CDM 2015 PD role and the BSA 2022 PD role

Companies that already appoint PDs early and ensure they are genuinely competent will find this a straightforward reinforcement of existing good practice. Companies that have been treating the PD role as a box-ticking exercise may need to review their approach.

2. Client Obligations Will Be Clarified

The review recommends providing "further clarity for all CDM 2015 duty holders on the obligations of the Client".

This is significant because the review found that many clients do not understand their duties and that opaque third-party "client advisors" are operating in a "dark area of the industry".

The HSE's feedback on this issue is clear: "Under CDM 2015 the client role cannot be delegated." This means that even if you use a client advisor, the legal duties still sit with you as the client.

You cannot outsource your responsibilities.

Expect guidance that clarifies:

• What clients must do to comply with their duties

• The limitations of using third-party advisors

• The importance of engaging a competent PD early

3. Information Management Will Come Under Greater Scrutiny

The review found that information products have become generic, large and unwieldy, with information being "copied and pasted" between documents. This is not what CDM intended.

The review recommends "encouraging the use of common digital systems for collating consistent project information and data so that it is accessible to all dutyholders".

The promotion of common storage systems as an approach also supports the "Golden Thread" principle of building information mandated by the BSA 2022.

For the construction industry, this means:

• Moving away from generic, template-based information products

• Ensuring that project information is project specific, not copied from other projects

• Considering how you store and share information across the project team

• Keeping information up-to-date and in a central, accessible location

4. SMEs Will Receive Proportionate Guidance

The review recommends ensuring "that SMEs are provided with proportionate and targeted CDM 2015 guidance, directly relevant to the issues they are likely to face on a day-to-day basis, in an easy-to-understand and concise manner".

This is important because the construction industry is dominated by small and micro businesses. 80% of the survey respondents came from organisations with fewer than 10 employees.

If you are an SME, expect guidance that is tailored to your scale and the types of projects you typically undertake.

5. The Link Between CDM and the Building Safety Act Will Be Clarified

The review acknowledges that the BSA 2022 and CDM 2015 "sit well together" and are "part of the same vehicle".

However, there is confusion around the separate PD roles and competency requirements.

Expect guidance that clarifies:

• The difference between the CDM 2015 PD role and the BSA 2022 PD role

• The competency requirements for each role

• How the two regimes work together on projects

What Hasn't Changed

It is worth being clear about what the review does not recommend:

• No legislative changes. CDM 2015 will remain in place.

• No changes to the notification threshold. The conditions for notifying projects to the HSE remain unchanged

• No changes to domestic client duties. The industry does not suggest that there is a problem with the current enforcement approach to this requirement

Authors thought: I fundamentally disagree with is point. Domestic construction projects largely remain unregulated in the UK.

• No changes to the fundamental principle – those who create risk must take responsibility for controlling it.

The survey also found that 77% of respondents believe that legislation such as CDM 2015 is necessary to ensure health and safety on construction projects. Overall, 56% of respondents said the impact of CDM 2015 on health and safety in the industry has been positive.

Practical Steps to Prepare Your Construction Firm

While no legislative changes are imminent, the review signals where regulatory expectations are heading. Here are some practical steps you can take now:

1. Review When You Appoint Your Principal Designer

Are you appointing your PD at the concept stage of the project, or are you leaving it until just before construction begins? The review is clear that early appointment is essential for designing out risk. Review your project timelines and ensure PDs are involved from the earliest possible stage.

2. Assess the Competence of Your Principal Designer

Are you confident that your PD has the right skills, knowledge, and experience for the specific project? The review found that unqualified and inexperienced people are taking on PD roles. Do not rely on tick-box qualifications and assess genuine competence based on the complexity and nature of your project.

3. Review Your Client Duties

If you act as a client, are you clear on your obligations under CDM 2015? Remember that the client role cannot be delegated. If you use third-party advisors, ensure you understand that the legal duties still sit with you. Review your processes for appointing duty holders and managing health and safety throughout the project.

4. Improve Your Information Management

Are your Pre-Construction Information, Construction Phase Plans, and Health and Safety Files genuinely project-specific, or are they generic templates with the project name changed?

The review found that generic information products are a significant problem. Move towards project-specific, accessible, and up-to-date information management.

5. Consider Digital Systems for Information Sharing

The review recommends the use of common digital systems for collating consistent project information. Consider whether your current systems allow all duty holders to access the information they need when they need it. This also supports the "Golden Thread" principle under the Building Safety Act.

6. Stay Informed About Updated Guidance

HSE intends to update its guidance to address the issues identified in the review. Keep an eye on HSE publications and ensure your team is familiar with any new or revised guidance when it is published.

Final Thoughts

The CDM 2015 Post-Implementation Review is good news for the construction industry. The regulation remains fit for purpose and will continue to provide the regulatory framework that 77% of industry respondents believe is necessary for protecting workers on construction sites.

However, the review has identified areas where industry practice needs to improve, particularly around the early appointment of competent Principal Designers, client understanding of their duties, and the management of project information.

These are not new requirements; they are existing duties that are not being fully understood or implemented.

The review does not recommend legislative change, but it does signal that HSE expects industry to do better. Firms that take the findings seriously and improve their practice will be better positioned for inspections, client relationships, and project success.

The three year transition window that followed the 2020 PIR has passed, and the regulatory landscape has evolved with the Building Safety Act 2022. Now is the time to review your CDM 2015 compliance and ensure your firm is ready for the expectations of the next decade.

If you require further assistance with any of the topics raised in this post whether that is reviewing your CDM compliance, assessing the competence of your Principal Designer, understanding your client duties, or preparing for the interface between CDM 2015 and the Building Safety Act. please get in touch: Yorkshire Health and Safety