Does CDM Apply to Maintenance Work? Clear Guidance (2025)

Does CDM Apply to Maintenance Work?

Maintenance work is a routine part of managing buildings and equipment — but what many don’t realise is that it can fall under construction law.

The Construction (Design and Management) Regulations 2015 (CDM) do apply to many types of maintenance — including repairs, redecoration, and general upkeep — because these tasks are explicitly listed in the definition of “construction work.”

However, this is where things can get unclear.

The HSE hasn’t changed the definition of construction work since CDM 2007. Under CDM 2015, the scope remains broad and open to interpretation.

When Does CDM Apply to Maintenance Work?

So, when does CDM apply to maintenance work? The answer lies in how the task is carried out — and whether it involves construction processes, skills, or materials.

CDM applies if the activity:

🔨 Involves construction processes

👷 Requires construction skills

🧱 Uses construction materials

This can include things like:

Repairs to building fabric

Repainting and upkeep

Servicing fixed systems like HVAC or electrical wiring

High-pressure or chemical-based cleaning

But not everything is covered. The HSE clarifies:

“General maintenance of fixed plant – like lubrication or replacing small parts – is unlikely to fall under CDM.”

Still unsure if CDM applies to the maintenance work you're undertaking?

There are two key steps to decide if CDM applies:

👉 Step 1: Does the activity fall under building, civil engineering, or engineering construction?
👉 Step 2: If yes, does the work include any of the listed activities such as repair, upkeep, or maintenance of a structure or service?

And if you’re managing maintenance through long-term contracts (like with a facilities provider), the client decides whether to treat the work as a single project or multiple ones — but a Construction Phase Plan is still needed for each project.

📌 Key takeaway: If you’re planning or managing maintenance work, it’s essential to check whether CDM applies to maintenance work. If it does, make sure you’re meeting your legal duties. Otherwise, if you’re unsure, review the task against the official definition of construction work under CDM 2015.

🔗 More info:
👉 HSE CDM 2015 Overview
📘 Download L153 Guidance PDF