On a Domestic Roof, the Client’s Duties Land on You

On a domestic re-roof the homeowner is the client in law, and then the regulations quietly move the client’s duties onto the roofer. Most homeowners have never heard of this. Almost no roofing website mentions it, which makes it one of the few genuinely checkable things a roofer can publish in a trade where nothing else can be checked.

This is a practical account of what the Construction (Design and Management) Regulations 2015 put on a contractor working for a householder, what is and is not notifiable, and what a roofing website can usefully say about any of it. It is written for roofing firms. It is not legal or health-and-safety advice. The HSE’s guidance and your own competent adviser govern how this applies to your work.

Who the client is, and who ends up carrying it

A householder having their own roof replaced is a domestic client. Regulation 7 of the CDM Regulations 2015 then does something most people outside the trade find surprising:

So on a single-contractor job, the roofer holds the client duties as well as their own. And on a job with more than one contractor (a roofer plus a scaffolding firm is the ordinary case) regulation 7(2)(b) settles who that falls to when the householder appoints nobody: “the contractor in control of the construction phase of the project is the principal contractor”.

In other words, the firm running the job is the principal contractor by default. Not by agreement, and not by anybody signing anything.

What actually transfers

Regulation 4 is the client duty being handed over. Two parts of it matter on a domestic roof.

Suitable arrangements. Regulation 4(1) requires “suitable arrangements for managing a project, including the allocation of sufficient time and other resources”, and 4(2) defines suitable as ensuring the work can be carried out “so far as is reasonably practicable, without risks to the health or safety of any person affected by the project”. Note any person affected. On a terraced street that includes the neighbours and whoever walks past the scaffold.

A construction phase plan. Regulation 4(5)(a) requires that “before the construction phase begins, a construction phase plan is drawn up by the contractor if there is only one contractor, or by the principal contractor”. Regulation 12(2) says the plan “must set out the health and safety arrangements and site rules” for the job.

This is the bit worth being clear about commercially: a construction phase plan is required for every project, including a two-day domestic re-roof. It is not the folder of paperwork that phrase suggests on a large site. For a small job it is a short, specific document about this roof, this access, this street. But it exists, or it does not.

Notifiable is a different question, and usually the answer is no

Notification gets confused with the plan, and they are separate. Regulation 6(1):

A domestic re-roof is almost never either. So the honest position on a roofing website is that the work is not notifiable, and that a plan is in place anyway, rather than implying a level of formality the job does not carry. Overstating this is the same mistake as understating it.

Why this belongs on the website

Our roofers page starts from the fact that nobody has ever seen their own roof: the work happens where the customer cannot go and is covered over by teatime. In that situation a homeowner is looking for reasons to believe you, and the firm that knocked their door last week will happily say the same warm words you do.

CDM is useful precisely because it is not warm words. It is a set of specific, checkable things a competent firm does and a door-knocker does not:

• Say that a plan is produced for every job, and in one sentence what it covers on a domestic roof: access, edge protection, the public below, deliveries, waste.
• Name the access method in the quote. Scaffold, tower or ladder is a safety decision with a price attached, and it is the single most common difference between two quotes a homeowner cannot otherwise explain.
• Say who arranges what. Pavement or road permits, skip permits, parking suspensions. The householder does not have to become a project manager, and saying so is reassuring.
• Explain the weather rule. A firm that writes down that it will not put a man on a roof in a gale is describing its arrangements, which is exactly what regulation 4 is about.
• Publish the concealed work. Photographs of membrane, battens and flashing before they are covered are the closest thing this trade has to an inspection.
• Keep the credentials honest. Public liability with the figure, employer’s liability, waste carrier registration, and any scheme you genuinely belong to, published as what they are.

Where scaffolding is subcontracted, the same logic runs down the chain, and our scaffolding page covers that side of it.

What we would not put on a roofing site

• “Fully CDM compliant” as a badge. It means nothing to a homeowner and invites the question of what the alternative was.
• Regulation numbers aimed at householders. Say what you do; keep the citations for the trade pages and the tender responses.
• A claim that a job is notifiable when it is not, or a notification implied to be an approval. Notice to the HSE is not a licence.
• Safety wording we drafted. What your arrangements are is your statement, checked by whoever advises you, published as given.
• Accreditation logos without numbers. A grey strip of badges is what every rogue copies first.

Sources and method

• CDM 2015, regulation 7: application to domestic clients, and the default principal contractor in paragraph (2).
• Regulation 4: client duties, including the construction phase plan requirement in paragraph (5)(a).
• Regulation 12: what the construction phase plan must set out.
• Regulation 6: the notification thresholds.

What this post does not do. Central Systems builds websites; we are not health-and-safety consultants and this is not legal or safety advice. It does not tell any firm what its arrangements should be, what a plan should contain for a particular job, or how the Work at Height Regulations, asbestos duties or building standards apply to the work. All of these sit outside it. It covers domestic clients; commercial and public-sector projects allocate these duties differently. Regulations are amended; the linked text is authoritative and this page is not.

Questions roofing firms ask us

Does a two-day repair really need a construction phase plan?

The requirement in regulation 4(5)(a) is not written with a size threshold, which is why the practical answer for most firms is a short standard document adapted per job rather than a bespoke file each time. What it contains is a question for your own adviser.

If we hire the scaffolder, are we the principal contractor?

Where there is more than one contractor and the domestic client appoints nobody, regulation 7(2)(b) makes the contractor in control of the construction phase the principal contractor. On most domestic re-roofs that is the roofing firm.

Should the website mention CDM at all?

Not by name to a homeowner. Say what you do: a written plan for every job, the access method in the quote, who arranges the permits. The regulation is the reason; it is not the sales message.

Is this worth putting on a page when competitors say nothing?

That is the argument for it. In a trade where the customer cannot inspect the product, the specific and checkable beats the reassuring every time, and it is precisely what the firms trading on the trade’s bad name will not write down.

Who is the client on a landlord’s property?

Work on a property for a business purpose is not a domestic client arrangement, and the duties sit differently. Worth establishing before quoting, not after.

Does any of this help us rank?

Indirectly, and not by itself. Pages answering real questions in your own words are what search engines and AI assistants quote. The more durable benefit is that the homeowner reading it arrives already believing you know what you are doing.