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CDM 2015 in 2026: Why the Principal Designer Role Still Matters

By Monika Pashias | Senior CDM Consultant & Principal Designer, Complete CDM

The Construction (Design and Management) Regulations 2015 have now been in force for more than 11 years. Yet the role of the Principal Designer remains one of the most important and frequently misunderstood roles within a construction project.

In 2026, construction professionals are also working within a wider regulatory environment, including the Building Safety Act and the Building Regulations duty holder regime.

This has increased the importance of competence, coordination, design risk management and effective information management.

The Principal Designer therefore has an important role in helping clients and design teams understand not only what information needs to be produced, but how that information should influence the project.

What does the Principal Designer actually do?

Where a project involves, or is reasonably foreseeable to involve, more than one contractor, the client must appoint a Principal Designer and Principal Contractor in writing.

The Principal Designer is the designer appointed by the client who has control over the pre-construction phase.

Under CDM 2015, the Principal Designer must plan, manage and monitor the pre-construction phase and coordinate health and safety matters during that phase.

They must also identify foreseeable risks and ensure that risks are eliminated, reduced or controlled so far as reasonably practicable.

This is why the Principal Designer should not be viewed simply as the person responsible for producing the PCI, risk register and Health and Safety File.

The role is about influencing the project.

The Principal Designer should be involved early

One of the biggest opportunities for effective CDM is early involvement.

HSE guidance states that the Principal Designer should be appointed as early as possible in the design process and, where practicable, at the concept stage.

This is important because decisions made during the early design stages can determine how safely a project can ultimately be constructed, maintained and used.

At concept and developing design stages, the Principal Designer should be asking questions such as:

Can a significant hazard be designed out?

Can access for construction or maintenance be improved?

Are work-at-height requirements being created unnecessarily?

Are demolition and temporary works implications understood?

Is asbestos information available?

Are structural alterations understood?

Have fire safety considerations been incorporated?

Are existing services and utilities understood?

Will future maintenance create foreseeable risks?

By the time a project reaches detailed design or construction, some opportunities to eliminate or reduce risk may already have been lost.

Good CDM therefore starts before construction starts.

RIBA Stage 2 — where the PD can add real value

The concept design stage is particularly important.

This is when the project team is developing the fundamental design approach and making decisions that can influence construction, maintenance and future use.

The Principal Designer can contribute by reviewing emerging design information and challenging significant foreseeable risks before solutions become fixed.

This does not mean that the Principal Designer has to be the technical expert in every discipline.

Rather, the PD needs sufficient competence to understand the risks, coordinate the relevant designers and ensure that appropriate issues are identified and addressed.

That is where the PD becomes a coordinator and influencer of design risk, rather than simply a document producer.

Pre-Construction Information should be useful not just paperwork

Pre-Construction Information is one of the most important tools available to the project team.

The Principal Designer assists the client with the provision of PCI and must provide relevant information to designers and contractors within their control.

For refurbishment and alteration projects, this can include:

existing drawings;

asbestos information;

structural information;

fire safety information;

existing services and utilities;

previous Health and Safety Files;

surveys and investigations;

information about the existing building;

site constraints;

known hazards; and

significant foreseeable risks.

But PCI should not simply become a large folder of documents.

The important question is:

What does the information tell the design team about the risks associated with this project?

For example, an asbestos survey is not simply an attachment to PCI. Its findings may affect the design, sequencing, access arrangements, demolition strategy and construction methodology.

The same principle applies to structural information, fire safety information, existing services and other site constraints.

Design risk management should be practical

A risk register containing hundreds of generic hazards does not necessarily demonstrate effective CDM management.

The focus should be on significant and foreseeable risks arising from the project and the design.

The Principal Designer should coordinate designers and encourage the application of the general principles of prevention.

A useful design risk review should ask:

Can the hazard be eliminated?

If not:

Can the risk be reduced?

If it cannot reasonably be eliminated or reduced:

What information needs to be communicated to those who will construct, maintain or use the building?

This approach turns the risk register into a design management tool rather than a spreadsheet that is simply updated at meetings.

Competence matters

The Building Safety reforms have also reinforced the importance of competence across the construction industry.

The Building Regulations duty holder regime requires individuals to have the necessary skills, knowledge, experience and behaviours, with organisations requiring appropriate organisational capability.

Although the Building Regulations Principal Designer and CDM Principal Designer are different legal roles, the principle of competence is important to both.

A client should therefore consider whether the person or organisation being appointed has the appropriate competence for the actual project.

This means looking beyond a job title.

A Principal Designer should have the knowledge, experience and capability necessary to coordinate the role effectively for the type, scale and complexity of project involved.

CDM Principal Designer and Building Regulations Principal Designer

This distinction is increasingly important.

The CDM Principal Designer operates under CDM 2015 and has responsibility for planning, managing, monitoring and coordinating health and safety during the pre-construction phase.

The Building Regulations Principal Designer operates under the Building Regulations duty holder regime and has duties relating to ensuring that design work complies with the relevant Building Regulations requirements.

The same organisation or individual may potentially undertake both roles, but the appointment should be clear, and the person must have the appropriate competence for each role.

For clients, the question should therefore not simply be:

“Who is my Principal Designer?”

It should be:

“Which Principal Designer role am I appointing them to perform, and do they have the competence required for that role?”

This distinction becomes particularly important on projects involving higher-risk building work.

Building Safety, Gateway 2 and information management

Where the Building Safety regime applies, the design team may also have additional information and approval requirements.

For relevant higher-risk building work, Building Regulations approval from the Building Safety Regulator is required before work can start. The approval process includes detailed information concerning the proposed work, competence, construction control, change control and compliance.

This reinforces the importance of getting design information right before construction begins.

Change control is also important. Where approved information is changed on an HRB project, the change needs to be assessed and recorded in accordance with the applicable regime.

The golden thread is another important part of the Building Safety regime.

It is not simply a digital filing system.

It is about ensuring that relevant building safety information is accurate, trustworthy, accessible and maintained throughout the building’s lifecycle.

For the design team, this reinforces a principle that has always been important under good CDM practice:

The right information needs to reach the right person at the right time.

The Principal Designer and Principal Contractor must work together

CDM does not create two completely separate processes for design and construction.

The Principal Designer must liaise with the Principal Contractor throughout the Principal Designer’s appointment and share information relevant to planning, managing and monitoring the construction phase.

This becomes particularly important when:

designs change;

unforeseen conditions are discovered;

construction sequencing changes;

additional work is introduced;

site conditions differ from the information originally provided; or

new risks emerge.

A strong relationship between the PD and PC allows information to flow between design and construction rather than creating a gap between the two.

CDM compliance is not a paperwork exercise

One of the biggest misconceptions about CDM is that compliance can be demonstrated simply by producing documents.

A project can have a PCI document, risk register and Health and Safety File and still have poor risk management.

The real test is whether the project has been properly planned, coordinated and managed.

HSE describes the Principal Designer as having an important role in influencing how health and safety risks are managed throughout the project and in coordinating significant and foreseeable risks during design.

That is the difference between document production and effective CDM management.

What should a client expect from their Principal Designer?

A competent Principal Designer should be able to:

1. Become involved early

Ideally at concept stage, so that design decisions can be influenced before they become fixed.

2. Understand the project

Understand the brief, existing building, constraints, programme and proposed construction.

3. Review available information

Identify gaps in PCI and ensure important information is obtained.

4. Coordinate designers

Ensure health and safety is properly considered across the design team.

5. Challenge significant design risks

Ask whether foreseeable risks can be eliminated or reduced through design.

6. Maintain meaningful risk information

Ensure significant residual risks are recorded and communicated clearly.

7. Liaise with the Principal Contractor

Ensure relevant information is transferred into construction planning.

8. Understand the wider regulatory environment

Where applicable, recognise the relationship between CDM and the Building Regulations duty holder regime.

9. Maintain the Health and Safety File

Ensure relevant information is collected and maintained for future use.

Final thoughts

CDM 2015 remains highly relevant in 2026.

The regulations may have been introduced more than a decade ago, but the principles behind them remain fundamental:

competence, planning, coordination, communication and effective risk management.

The Principal Designer should not simply be the person who produces a PCI document, risk register or Health and Safety File.

The role is about influencing the project before risks become problems on site.

It is about asking the difficult questions early.

It is about challenging design decisions where necessary.

It is about making sure information is understood rather than simply stored.

And it is about ensuring that health and safety remains part of the design process from the earliest stages through to construction.

Good CDM is not about creating more paperwork.

It is about preventing harm through better planning, better design and better communication.

Author

Monika Pashias is a Senior CDM Consultant and Principal Designer and founder of Complete CDM, providing CDM 2015 and Principal Designer consultancy services across London and the UK.

Why principal designers matter - Revision history

Designing Buildings at 07:25, 8 October 2026

Complete CDM - Principal Designer Services: Created page with "CDM 2015 in 2026: Why the Principal Designer Role Still Matters By Monika Pashias | Senior CDM Consultant & Principal Designer, Complete CDM The Construction (Design and Ma..."