UK Workplace Harassment Reforms Explained

How Employers Should Prepare for the Upcoming Changes in October 2026

The UK is about to introduce a significant shift in workplace harassment law. From October 2026, employers will face stronger legal duties to prevent harassment, including harassment carried out by third parties, and expectations around culture, training and reporting will rise considerably. A key change is that employers must take all reasonable steps to prevent harassment to avoid liability, a clear strengthening of the previous requirement to take reasonable steps.

Below is a clear summary of what’s changing, what “all reasonable steps” really means, and how employers can prepare now to ensure compliance.

What’s Changing from October 2026?

A new duty to take “all reasonable steps” to prevent harassment

Employers will be legally required to take proactive, meaningful steps to prevent harassment of any kind. This goes far beyond having a policy as it means demonstrating that you have taken practical, proportionate action to reduce risk.

Third‑party harassment protections

If an employee is harassed by a customer, client, contractor or any other third party, employers may now be liable if they have not taken reasonable steps to prevent it. This is a major shift for sectors with high public interaction such as retail, hospitality, health and social care.

Greater scrutiny of culture, reporting routes and management capability

Tribunals will expect employers to show they have created an environment where concerns can be raised early, handled sensitively and resolved effectively. Poor culture or weak reporting processes will carry greater risk.

What This Means for SMEs

These reforms raise expectations around prevention and manager capability. Employers will need to ensure policies are up to date, reporting routes are clear and staff understand what behaviour is acceptable. Employee training, early intervention and consistent record keeping will become even more important.

What “All Reasonable Steps” Really Means

The October 2026 reforms place a clear duty on employers to take all reasonable steps to prevent harassment. The Equality and Human Rights Commission (EHRC) sets out an 8‑step framework that shows what good practice looks like in reality. For SMEs, these steps offer a practical roadmap for building a safe, respectful workplace.

1. Develop clear policies that people actually use

Policies should be easy to understand, accessible and regularly reviewed. They must explain what harassment looks like, how to report concerns and what employees can expect when they do.

2. Create multiple reporting routes

Employees need more than one way to raise concerns. This might include a named HR contact, a senior manager, an anonymous reporting tool or a clear escalation route. The key is choice and psychological safety.

3. Train your people

Training should help employees recognise unacceptable behaviour and understand how to respond. Managers need additional support to handle disclosures sensitively, act early and follow fair processes.

4. Assess workplace risks proactively

Look carefully at where harassment could occur. Consider lone working, customer‑facing roles, high‑pressure environments or areas with limited supervision. This is especially important now that third‑party harassment protections will be required.

5. Set clear standards for expected behaviour

Reinforce what respectful behaviour looks like through induction, training, team meetings, leadership messaging and everyday practice. Culture is shaped by what leaders tolerate and what they champion.

6. Encourage early intervention

Managers should feel confident addressing concerns at the earliest stage. Small issues can escalate quickly if ignored. Early conversations often prevent harm and build trust.

7. Respond consistently and fairly to concerns

When someone raises an issue, the response must be timely, sensitive and well‑documented. Employees should feel heard and supported throughout the process.

8. Review and learn from incidents

After concerns are raised, take time to reflect. Are there patterns? Do certain teams need more support? Are reporting routes working? Continuous improvement is part of taking reasonable steps.

Why These Steps Matter

Tribunals will increasingly look for evidence that employers have followed this kind of structured, preventative approach. A policy alone won’t be enough. Employers will need to show they have:

• trained staff

• assessed risks

• strengthened reporting routes

• acted early

• documented decisions

• reviewed outcomes

This is what “all reasonable steps” looks like in practice and it’s the standard employers will be judged against from October 2026.

How Employers Should Prepare Now

1. Review and update your harassment and conduct policies

Policies should clearly define unacceptable behaviour, outline reporting options and explain how concerns will be handled. They should also reference third‑party risks and set expectations for contractors, suppliers and customers.

2. Strengthen reporting routes

Employees need multiple, accessible ways to raise concerns. Ensure workers know how to report issues and feel safe doing so.

3. Train managers and employees

Training should cover recognising harassment, responding appropriately, supporting affected employees and understanding the organisation’s legal duties.

4. Assess third‑party risks

Identify where employees interact with customers, clients or external partners. Consider whether additional controls are needed, such as signage, customer behaviour policies, contractor agreements or incident reporting procedures.

5. Review culture and early intervention practices

A positive culture is one of the strongest preventative tools. Encourage open communication, reinforce expected behaviours and ensure concerns are addressed promptly and consistently.

6. Keep thorough records

With extended tribunal time limits also coming into force in October 2026, accurate documentation of concerns, conversations, decisions and training will be essential.

How Empower People HR Can Help

Empower People HR supports SMEs across Sussex and beyond to prepare for these changes with confidence. We can help you:

• Review and update policies

• Design and deliver practical training

• Strengthen reporting routes and investigation processes

• Assess third‑party risks

• Sense‑check your culture and early intervention practices

If you’d like support getting ready for upcoming legal reforms or want to understand what “all reasonable steps” look like in practice, Empower People HR is here to help. You can get in touch here or use our free HR health check form via our services page for a quick and easy way to assess your HR foundations.