Monthly Register — April 2025

The Construction (Design and Management) Regulations 2015 came into force on 6 April 2015. They turned ten this month, and as far as anyone on site could tell, nothing happened. No amending instrument, no ceremony, no letter. Somewhere a client's facilities manager was still waiting for a health and safety file promised at practical completion in February.

That gap is the interesting part of the anniversary. Ten years is long enough to stop calling anything transitional, so the question worth asking is not whether people still say CDM, but what the regulator has actually published, and what duty-holders actually do with the file.

What moved

Take the public record as it stood on 30 April 2025, because the anniversary did not add to it.

The instrument is S.I. 2015 No. 51. It replaced CDM 2007. HSE's Legal Series guidance L153, Managing health and safety in construction, was published with the regulations, and the 2007 Approved Code of Practice was withdrawn the same day. None of that has moved since.

The duty-holder map did move in 2015, and ordinary jobs have been living inside it for a decade. Client duties apply to commercial clients and, with a transfer arrangement, to domestic clients — the old exemption went. The CDM coordinator went with it. In its place the principal designer, a designer with control over the pre-construction phase, must plan, manage, monitor and coordinate health and safety before construction starts. A principal contractor remains for the construction phase where there is more than one contractor. A construction phase plan is required on every project, not only the notifiable ones. A health and safety file is required where there is more than one contractor: the principal designer prepares it in the pre-construction phase, keeps it current, and passes it to the client at the end of the project — or to the principal contractor if the appointment ends first. Notification to HSE, the F10, uses a higher threshold than 2007: more than 30 working days with more than 20 workers at the same time, or more than 500 person days.

HSE's standing public commentary is those pages and L153. The overview page was refreshed on 25 March 2025, which is a website date rather than a speech, and nobody should read more into it than that.

The last published statutory review remains the 2020 post-implementation review, PIR008. Regulation 39 requires a review at least every five years. The 2020 text said the regulations were progressing their objectives, recommended they be kept, and recorded that the cost savings assumed from removing the CDM coordinator had not been fully realised. Coordination had not, on that evidence, simply folded into the design team at no extra fee, and a market of external CDM advice carried on regardless. The same review recorded that only forty per cent of survey respondents felt the principal-designer role had become embedded completely or to a large extent. There is no 2025 replacement to report. If a later review lands, it will be news in the month it lands.

What HSE did publish, in June 2023, was research it funded on how the principal-designer role was working: RR1198. The report is explicit that the opinions are the authors' and do not necessarily reflect HSE policy, which is worth saying before anyone quotes it as a verdict. The findings that can be named without embroidery are these. Compliance with the functions in the regulations was variable. Principal designers were typically small or medium-sized enterprises. They undertook a differing subset of the activities the role implies. Respondents still rated the potential value of the role as high, which reads less like disillusionment than frustration. Late appointment — after the design decisions the role exists to influence — is not a 2025 discovery. It is the practice the anniversary made harder to treat as teething trouble.

Then the Building Safety Act 2022 arrived, and with the Building Regulations duty-holder amendments that commenced in England in October 2023, a second principal designer landed on a large share of the same jobs. A different appointment, about whether the design can be shown to comply, not a rename of the CDM role. Higher-risk buildings added the golden thread on top. Document controllers have spent a year and a half fielding emails that say “principal designer” and mean one of two things, with no way to tell from the signature block. The tenth anniversary of CDM did not resolve that collision. It only made the older name ten years old.

What actually changed in duty-holder practice, as information managers meet it on ordinary jobs, is narrower than the 2015 impact assessment hoped and rather broader than the cynics allow.

The names changed, and that is not nothing. Almost every multi-contractor job now has a principal designer and a principal contractor on the appointment list. Construction phase plans exist on small works that never saw a CDM coordinator. Clients who once treated CDM as a contractor problem now appear on the form. Domestic work is no longer outside the map. Those are real changes. They are also the cheap ones.

The objects, in the main, did not change. Pre-construction information is still, on a large share of jobs, a kick-off PDF issued once and never touched. Design-risk registers still say “working at height” and “services in the ceiling void”, in that order, in the same template. The health and safety file is still compiled at practical completion as a ring binder or a ZIP, weeks after the people who knew the residual hazards have moved to the next job. The F10 is still a notification ritual. The principal designer is still, often enough, a name plus a visiting adviser, appointed late enough that the design was already frozen. The fee bought the title. It did not buy the hours to keep the file current while the design moved, and nobody at the fee negotiation pretended otherwise.

That is the movement worth recording from ten years. Not a keynote, not a product. A decade in which the regulations named the information, and the job answered with a form and a binder.

What changed in the standards

Nothing in April. No statutory instrument rewrote S.I. 2015 No. 51 to mark the birthday, and L153 remains the HSE guidance most appointments still point at. The working text is still the 2015 regulations, the working guidance is still L153, and the last published HSE review of those regulations is still 2020.

The standards sentence that belongs beside this anniversary is not a CDM rewrite at all, but ISO 19650-6:2025, Health and safety information, published on 13 January 2025. December's issue recorded the part as under publication; it is now the published part. It specifies concepts and principles for classifying, sharing and delivering structured health and safety information through the project and asset life cycle. It is not a UK regulation, it is not L153, and it does not replace regulation 12. What it does is assume the health and safety file can be something other than a completion deliverable, and set out how to structure the information accordingly. Most BIM execution plans had not absorbed it by the last working day of April — a fact about adoption rather than a scoop about the clause.

In England, the Building Safety Act's information duties and the Building Regulations principal-designer role were already in force. They did not arrive in April. They sit beside CDM, and HSE has not published anything that collapses the two names into one.

One thing to watch

Two weeks from now the anniversary pieces will have gone quiet, and the test will not be whether anyone can still say “ten years of CDM”. It will be whether people are still arguing about what the regulations named: a live health and safety file, or a binder assembled for completion; a principal designer appointed while the design could still change, or a name added the week before the first induction; one appointment, or two identically titled duties sharing a single fee line.

So watch the file itself. Open it as though you were the facilities manager inheriting the building. If it cannot be opened by someone who was not on the original design team, and it does not name residual hazards against the parts of the building somebody will later cut into, the job has not moved as far as the appointment list suggests. If the pre-construction information went out once and was never revised when the design changed, the coordination the regulations asked for is a cover sheet with a date on it.

And if you are the client, price the second duty. Where the Building Regulations principal designer and the CDM principal designer sit on the same line in the cost plan, one of them is unfunded, and it will be the one that keeps the file current. Splitting that line costs money at appointment. Not splitting it costs a handover.