The Construction (Design and Management) Regulations 2015 (CDM 2015) remain the primary legislative framework governing health and safety in construction, but updated HSE guidance published in early 2026 has clarified several areas of duty holder responsibility that had been subject to inconsistent interpretation.

Key Changes in the Updated Guidance

The revised guidance places particular emphasis on the responsibilities of Principal Contractors during the construction phase, and Principal Designers during the pre-construction phase. The HSE has made clear that these roles carry significant personal accountability and cannot be delegated without proper oversight.

Principal Contractor Obligations

Principal Contractors must now demonstrate they have:

  • A documented Construction Phase Plan that is actively maintained and reviewed
  • Formal arrangements for managing and monitoring contractor competence
  • Systems for ensuring workers receive appropriate site induction and ongoing safety briefings
  • Procedures for reporting and investigating near misses, not just reportable incidents
  • Evidence of regular safety tours and documented findings
"The CDM regulations are not a paperwork exercise. They require active, ongoing management of health and safety risks throughout the project lifecycle." — HSE Construction Division

Competence Requirements

The guidance reaffirms that all duty holders must be able to demonstrate both the skills and knowledge appropriate to their role. For Principal Contractors, this typically means having qualified health and safety professionals involved in project management, with formal qualifications such as NEBOSH Construction Certificate or equivalent.

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Enforcement Trends

The HSE's construction inspection programme in 2025 resulted in 2,847 enforcement notices being issued on construction sites, with falls from height, unsafe excavations, and inadequate welfare facilities being the most common reasons for intervention. Several Principal Contractors received Improvement Notices specifically for failures in their Construction Phase Plans.

Employers and duty holders who are uncertain about their obligations under CDM 2015 are strongly advised to seek specialist advice and ensure their workforce has access to up-to-date health and safety training.