How to evidence competence under CDM 2015

To evidence competence for a construction role, show that the people and organisation assigned to the actual project have the relevant skills, knowledge and experience, the resources and systems to do the work safely, and a plan for gaps. Match the evidence to the hazards and responsibilities of the appointment. A training card, prequalification certificate or policy may support the decision, but none proves by itself that a team can safely deliver this particular job.

Under the Construction (Design and Management) Regulations 2015 (CDM 2015), the language varies by dutyholder. HSE describes the required skills, knowledge and experience (SKE) and, for an organisation, organisational capability. Contractors must also check that workers they appoint have the appropriate skills, knowledge, training and experience or are in the process of acquiring them, with appropriate supervision. The evidence should be proportionate to the project's size, complexity and risk. HSE's principal contractor guidance and contractor duties set out these distinctions.

This is a guide to making and recording a real competence decision, not to buying a certificate or assembling the largest possible file. It applies to construction work in Great Britain. Check the precise CDM role and appointment before using the examples below.

Start with the role and the work, not a generic checklist

First write down who is being assessed: an individual worker, a contractor business, a designer, a principal designer or a principal contractor. Then state what they will actually do. A scaffolding subcontractor erecting a complex temporary structure needs different evidence from a decorating contractor on a small, low-risk job. A principal contractor must show its ability to plan, manage, monitor and coordinate the construction phase, not merely that one manager has attended a course.

An appointment record should therefore identify:

1. Scope: activities, locations, interfaces with other trades, relevant design or management responsibilities and the expected duration.
2. Material risks: height, lifting, excavations, electricity, substances, occupied premises or other hazards specific to the job.
3. Required people: the named lead, supervisors, specialists and workers who will perform or control the work.
4. Capacity: whether the organisation has enough competent people, equipment and management time for this project alongside its other commitments.
5. Decision maker: the client or appointing dutyholder who assesses the evidence, records any conditions and reviews changes.

HSE says a commercial client must appoint designers and contractors with the necessary SKE and organisational capability, and must make suitable arrangements for the project. A principal contractor must check those it appoints. These are duties of the appointing parties, so a supplier's self-declaration is an input to a decision, not the decision itself. HSE: commercial clients; HSE: principal contractors.

Build an evidence matrix for the appointment

A concise matrix is easier to test than a large, undifferentiated upload folder. Use one row per material requirement and keep the record that supports it.

The matrix is a practical management method, not a prescribed CDM form. Keep it proportionate. A short recorded rationale may be sufficient for a straightforward appointment; a high-risk package may need technical review, interviews, demonstrations, references and regular checks on site. Do not ask for documents that do not help answer whether the team can perform the work safely.

What counts as skills, knowledge and experience?

Skills are the demonstrated ability to carry out or manage tasks: for example, planning a lift, designing a temporary works scheme or supervising a multi-trade interface. Knowledge includes understanding the relevant hazards, methods, legal duties and limits of one's role. Experience shows the person has applied these in comparable conditions. Evidence can include project records, relevant qualifications, continuing professional development, references, interviews and observed work. HSE gives CPD, professional membership and construction references as examples for principal contractors; it does not say that any one example automatically qualifies an applicant.

Ask follow-up questions that expose the difference between a certificate and working competence: Who made the key risk decision on the cited project? What changed when conditions differed from the plan? Which control failed and how was it corrected? Can the proposed supervisor explain the method and stop-work trigger? Such questions should be adapted to the role; they are not a substitute for specialist technical assessment where one is needed.

Card schemes and registrations have different scopes. A card may identify occupation or training status, while a statutory registration can be a separate requirement for particular work. Verify the scheme's own rules and the task's legal requirements instead of treating “has a card” as a universal CDM pass. The decision remains whether this person is suitable for this work, with the information, instruction and supervision needed.

Organisational capability is more than one competent employee

An organisation should show how it will deliver safe work consistently. A convincing submission might include its relevant project record, reporting lines, availability of supervisors, equipment and resources, arrangements for selecting subcontractors, control of changes, and how incidents or failed controls lead to improvement. The scale should match the role. For a principal contractor on a complex multi-contractor project, the ability to coordinate, monitor and communicate across interfaces is central. For a specialist subcontractor, task planning, skilled workforce and coordination with the principal contractor may matter most.

HSE notes that third-party prequalification services such as SSIP members or self-assessment against the Common Assessment Standard can be examples of organisational capability evidence. They can save repetition at the general prequalification stage. They do not remove the need to assess project-specific risks, personnel, capacity and arrangements. Ask whether the assessment covers the relevant entity and scope, is current, and leaves material gaps that require separate review.

If the applicant is an individual rather than an organisation, avoid imposing corporate documents that do not fit. Assess their own SKE and how the appointment will be supported. For a business, assess both the organisation's system and the actual people allocated.

A six-step assessment process

1. Define the decision

Specify the CDM dutyholder role or package and the activities to be approved. Identify what safe performance would look like and any essential registrations, training or design competence for the scope. The work package is the unit of assessment, not an abstract “approved supplier” label.

2. Request proportionate evidence

Use the matrix above. Give the bidder or proposed appointee the relevant pre-construction information so the response can address real constraints. HSE requires commercial clients to provide pre-construction information to designers and contractors bidding for or appointed to the work. A request for generic policies without project context produces generic assurances.

3. Verify, rather than merely collect

Check the named person, document currency, scope and issuer where meaningful. Speak to a reference for critical work. Test whether the proposed method, resources and programme are plausible together. An expiry date in the future does not prove a card belongs to the person, covers the operation or reflects recent practice. Record who verified the material point and when.

4. Assess gaps against risk

Classify a missing item by consequence. A missing administrative copy might be obtained before appointment. A missing specialist competence for high-risk work can require a different team, competent subcontractor, additional supervision or a scope change. Do not use a vague “approved with conditions” label: name the condition, owner and deadline and prohibit the affected work until it is satisfied.

5. Record the decision and share it

Record the scope approved, evidence considered, material limitations, conditions, reviewer and date. Share the relevant decision with the people managing access and work. The site team must know if a particular worker, task, piece of equipment or method is excluded. A procurement approval invisible to the principal contractor's supervisor will not control site risk.

6. Reassess when the work changes

Competence is not a one-off annual certificate. Revisit the decision if the appointed team changes, the programme accelerates, new hazards appear, a subcontractor is added or monitoring shows the proposed controls are not working. Contractor and principal contractor duties include planning, managing and monitoring work, so the evidence has to remain connected to the work as delivered. HSE contractor duties; principal contractor duties.

Example: appointing a roofing subcontractor

A commercial client is renovating an occupied building. Its principal contractor proposes a roofing firm. The firm presents a current prequalification assessment, a policy and worker cards. Those documents are a starting point. The actual job involves public access below the roof, fragile areas, temporary edge protection and a short weather window. The reviewer asks for the named supervisor, comparable occupied-site experience, a proposed access and rescue approach, the scaffolding or edge-protection interface, and evidence that the available crew can deliver safely within the programme.

Suppose the proposed supervisor has relevant experience but one worker's task-specific training is incomplete. The decision could approve the firm subject to a recorded restriction: that worker does not perform the affected task until competent assessment or training and appropriate supervision is confirmed. The site induction and work plan must reflect the restriction. A “pass” for the company must not silently override it. This is an illustrative decision process, not an assertion that a particular card is legally mandatory for all roofing jobs.

Principal designer and principal contractor appointments

For a principal designer, ask for evidence of ability to lead pre-construction coordination and manage foreseeable design risks, including design experience relevant to the project and capacity to work with other designers. HSE says that the principal designer must be a designer with the relevant SKE and, if an organisation, organisational capability. Do not assume a person is suitable merely because they hold a construction safety qualification.

For a principal contractor, test the proposed site leadership, planning, contractor-selection and coordination system, as well as the organisation's resources. HSE describes duties to plan, manage, monitor and coordinate the construction phase, prepare and review the construction phase plan, make suitable welfare arrangements and check those appointed. Previous work should resemble the new project's risk and complexity. Ask who will actually perform these functions, not just who signs the appointment letter.

The general CDM 2015 guide covers the full dutyholder structure. This guide's separate purpose is the evidence and assessment workflow. Keep introductory role explanations short on this URL so the two pages do not compete for the broad “CDM 2015 guide” query.

Common mistakes that weaken the evidence

• Treating a badge as a complete assessment. A scheme can cover only part of the work, or an organisation may have changed since assessment.
• Assessing the company but not the assigned people. The team proposed at tender may differ from the team mobilised.
• Collecting every file but checking none. Verification and a recorded judgement matter more than file count.
• Ignoring project interfaces. A contractor competent in its trade may be unprepared for simultaneous work with other contractors or occupied-site constraints.
• Using old experience without checking capacity. Past projects show experience; they do not prove enough current supervision or time.
• Leaving conditional approvals open indefinitely. State what must happen before the affected work starts and who confirms closure.
• Assuming software makes the decision. A system can organise evidence and reminders; competent people must judge suitability and control the work.

Where Complys may help

An operational system can make it easier to find a person's documents, track review dates, identify missing evidence and preserve a decision record. Complys has public pages for construction compliance software and contractor compliance software. A buyer can use the six-step process above as a demonstration script: create a real project and work package, attach evidence, record a restricted approval, change the assigned worker and show the decision history. Confirm in the current product and plan which of those steps Complys actually supports. Do not promise automated competence verification, scheme checks, legal sign-off or an integration based on a marketing description.

If you are deciding how to evidence a team for an imminent job, start with the matrix and record a proportionate, named decision. Then test whether your chosen system helps the team carry that decision through to mobilisation and monitoring.

Frequently asked questions

Does a CSCS card prove competence under CDM?

It can be useful evidence of a particular status, but it is not a complete assessment of ability to perform or manage a specific job safely. Check the card or scheme's scope, the person's actual SKE, experience and supervision, and the hazards of the work.

Is SSIP accreditation enough to appoint a contractor?

It may support the assessment of general organisational arrangements. HSE gives third-party prequalification as an example of organisational capability evidence, but a project-specific appointment still needs consideration of the work, people, capacity and risks. Check the assessment's scope and currency.

Must every worker already have finished every course?

HSE's contractor guidance says workers must have the relevant skills, knowledge, training and experience or be in the process of obtaining them. That does not authorise unsupervised work beyond a person's ability. Assess the task and put appropriate training, information, instruction and supervision in place.

How often should competence evidence be reviewed?

There is no universal CDM interval that makes all evidence valid for a year. Review before appointment and when the people, scope, methods or risks change; monitor performance during the project. Verify any document or scheme-specific expiry on its own terms.

Who makes the appointment decision?

The appointing party must take reasonable steps appropriate to its duty. The commercial client appoints designers and contractors with the required capability; a principal contractor checks those it appoints for construction work. Specialist advice can inform the decision, but an uploaded supplier declaration alone is not a recorded assessment.

Writer-side source, ownership and QA register — 5 October 2026

Final writer-side disposition: READY. Proposed copy is complete for the distinct evidence-assessment intent. No Complys page was created or published.