How Employers Should Prepare for the Harassment Law Changes in October 2026
From October 2026, UK employers will face stronger legal duties to prevent workplace harassment. Expectations around policies, training, reporting procedures and workplace culture will increase, with a greater focus on prevention rather than simply responding to complaints after the event.
A key change is the requirement for employers to take all reasonable steps to prevent harassment. This raises the bar from the previous requirement to take reasonable steps and will require organisations to demonstrate a proactive approach to reducing risk.
What’s Changing?
A stronger duty to prevent harassment
Employers will be expected to take meaningful action to prevent harassment before it occurs. Having a policy in place alone will not be enough. Organisations will need to show they have assessed risks, trained employees and managers, and created effective reporting processes.
Third-party harassment protections
The reforms will also introduce employer liability for harassment carried out by third parties, including customers, clients, contractors and suppliers.
This means employers may be held responsible if employees experience third-party harassment and reasonable preventative measures were not taken. The change is particularly important for sectors such as retail, hospitality, healthcare and social care, where employees regularly interact with the public.
Greater focus on culture
Tribunals are likely to look more closely at workplace culture and how concerns are handled. Employers will need to show that employees can raise issues safely, managers are capable of responding appropriately and concerns are dealt with consistently.
What Does ‘All Reasonable Steps’ Mean?
The Equality and Human Rights Commission (EHRC) has outlined practical measures employers should take to prevent harassment. While the approach should be proportionate to the size and nature of the organisation, key actions include:
- Maintaining clear and up-to-date anti-harassment policies.
- Providing more than one route for employees to report concerns.
- Delivering regular training for both employees and managers.
- Assessing workplace risks, including third-party risks.
- Setting clear standards of behaviour.
- Encouraging early intervention when concerns arise.
- Responding to complaints promptly and fairly.
- Reviewing incidents and learning from outcomes.
The focus is on creating an environment where harassment is less likely to occur and where concerns are addressed effectively if they do arise.
Why This Matters for SMEs
Many SMEs already have harassment policies, but the new requirements will focus on whether those policies are actively embedded in the workplace.
Employers will increasingly need evidence that they have:
- Trained employees and managers.
- Assessed and managed workplace risks.
- Provided effective reporting routes.
- Investigated concerns appropriately.
- Maintained accurate records.
- Reviewed and improved processes where necessary.
Being able to demonstrate these steps could be critical if a claim is brought.
How Employers Can Prepare Now
Review policies
Ensure harassment and conduct policies are clear, up to date and reflect the risks within your organisation, including third-party interactions.
Strengthen reporting processes
Employees should have accessible, confidential ways to raise concerns and understand what will happen when they do.
Train managers and employees
Managers need to know how to respond appropriately to concerns, while employees should understand acceptable standards of behaviour and reporting procedures.
Assess workplace risks
Consider where harassment is most likely to occur, particularly in customer-facing roles, lone-working environments or high-pressure settings.
Focus on workplace culture
Clear leadership, open communication and early intervention remain some of the most effective ways to prevent harassment and build trust.
Keep accurate records
Document training, complaints, investigations and outcomes. Accurate records can help demonstrate compliance and support decision-making.
How Empower People HR Can Help
At Empower People HR, we help SMEs prepare for employment law changes with confidence. Whether you need support reviewing policies, strengthening reporting processes, delivering training or assessing workplace risks, we can help you take practical steps towards compliance before the October 2026 changes take effect.