Responsibility for commercial exterior window cleaning sits in an uncomfortable middle ground for many businesses. It is not always clear whether the duty falls to the building owner, the facilities manager, the employer, or the tenant, and most organisations operate for years without finding out where they stand.
The legal framework does not limit liability to whoever is on the ladder. It extends to anyone who commissions, directs, or controls the work, and getting this wrong can lead to regulatory scrutiny, insurance complications, and real safety risks.
This guide sets out who is responsible, what the law requires, and what you must confirm before the next clean is due.
Legal Responsibility, Duty of Care & Who Owns the Risk
The Work at Height Regulations 2005 apply to employers and anyone who controls work at height. The Health and Safety Executive (HSE) is explicit that this includes facilities managers and building owners who contract others to carry out the work. The obligation to ensure that work is properly planned, supervised, and carried out by competent people sits with whoever commissions it [1].
The scope is broad. The duty falls on whoever is directing the activity, not only the person carrying it out.
Responsibility for a single-occupancy building clearly rests with the building owner or employer. Multi-tenancy buildings are more complex:
- Responsibility for the external structure typically sits with the landlord.
- Where a tenant manages their own facilities, the duty to arrange and oversee cleaning safely may transfer to them.
- Shared areas often create ambiguity, with responsibility split between a building management company and individual tenants.
The Health and Safety at Work Act 1974 adds a parallel obligation. Employers must ensure, so far as is reasonably practicable, the health and safety of anyone affected by their business activities, including commissioning window cleaning work, whether carried out in-house or by a contractor.
What Compliance Really Demands When Work Is at Height
The risk profile of window cleaning changes considerably depending on the building. Ground-floor glazing is low risk and straightforward. Once height is involved, the obligations become substantially more demanding.
HSE guidance on working at height sets out what compliance requires as legal requirements, not recommendations [2]:
- All work at height must be properly planned and organised.
- Those carrying it out must be competent and appropriately trained.
- Risks must be assessed and appropriate equipment selected, inspected, and maintained.
The regulations also cover work on or near fragile surfaces. This is relevant to any building with roof lights, non-reinforced fibre-cement sheets, corroded metal, or glass, all of which the HSE identifies as likely to be fragile.
For mid-rise buildings, mobile elevating work platforms (MEWPs) are a common access method. Operators must be competent, and the platform must be examined and maintained to the required standard, with checks covering ground conditions, operator training, overhead hazards, and whether restraint systems are needed. Whatever access method is used, a risk assessment and method statement must be in place before work begins.
For more on the specific challenges of high-level glazing, read our guide to cleaning high windows.
What Outsourcing Means for Your Accountability
Appointing a contractor does not remove your legal responsibility. Under the Construction (Design and Management) Regulations 2015, commercial clients must make suitable arrangements for managing health and safety risks. That includes appointing contractors while making sure they have the skills, knowledge, experience, and organisational capability for the work [3].
Signing a contract with a cleaning company transfers the task, not the compliance obligation. For businesses deciding between managing cleaning in-house and appointing a contractor, the practical and financial case for professional commercial cleaners is worth reviewing before making a decision. Just remember, the client retains contractual control and the duty to manage health and safety risk throughout, regardless of project size.
This applies equally to landlord-tenant situations. Where a lease imposes maintenance obligations on the tenant, the duty to arrange window cleaning correctly and to ensure any contractor meets the required standards rests with them. Review your lease to clarify any ambiguity about where exterior maintenance obligations lie.
When selecting a contractor, verify the following before any work is agreed:
- Valid public liability and employer’s liability insurance at appropriate cover levels.
- Written risk assessments and method statements are provided before work starts.
- Operatives trained and certified for the access method being used.
- Access equipment specified, maintained, and appropriate to the building type and height.
- Demonstrable experience of commercial window cleaning at the relevant scale.
For guidance on vetting providers, see our article on commercial cleaning certifications and standards.
Take the Right Steps Before Your Next Clean Is Due
If you have been assuming that appointing a contractor is enough, this should prompt a rethink. Responsibility for commercial exterior window cleaning services stays with you until you can demonstrate that the work was properly arranged, the contractor was qualified, and the legal requirements were met. Review your lease, determine whether the building requires specialist high-level access, and confirm that any contractor can provide evidence of compliance before starting.
Dorset Commercial Cleaning provides professional window cleaning services across the region, with specialist equipment for high-level glazing, fully trained and insured operatives, and written risk assessments provided as standard. With 20 years of experience serving offices, retail premises, industrial sites, and specialist environments across Dorset, the team takes compliance seriously.
Call 01202 986700 or request a free consultation to discuss your requirements and arrange a no-obligation site assessment.
External Sources
[1] GOV.UK, Health and Safety Executive (HSE), Work at Height, The Law: https://www.hse.gov.uk/work-at-height/the-law.htm
[2] GOV.UK, Health and Safety Executive (HSE), Work at Height, Frequently Asked Questions: https://www.hse.gov.uk/work-at-height/faqs.htm
[3] GOV.UK, Health and Safety Executive (HSE), Construction (Design and Management) Regulations 2015 (CDM 2015), Commercial Clients: Roles and Responsibilities: https://www.hse.gov.uk/construction/cdm/2015/commercial-clients.htm
