On 30 October 2026 two changes to workplace harassment law are due to take effect in Great Britain: a higher standard for employers on preventing sexual harassment, and a new liability for harassment by people from outside the organisation. This article explains what is changing, what the official guidance says about “all reasonable steps”, and what it means for people at work.
What exactly changes on 30 October?
Both changes come from the Employment Rights Act 2025. According to the government’s timeline update, last updated on 14 October 2026, the measures that take effect on 30 October 2026 include “requiring employers to take ‘all reasonable steps’ to prevent sexual harassment of their employees” and “introducing an obligation on employers not to permit the harassment of their employees by third parties”.
The date is fixed in law. The Employment Rights Act 2025 (Commencement No. 6 and Transitional and Saving Provisions) Regulations 2026 were made on 1 October 2026. They bring sections 20, 21 and 22 of the Act into force on 30 October 2026. Those sections cover, respectively, the employer duty on sexual harassment, harassment by third parties, and a power to make further provision about what counts as “reasonable steps”.
In short, there are two separate changes:
| Change | Before 30 October 2026 | From 30 October 2026 |
|---|---|---|
| Preventing sexual harassment | Employers must take “reasonable steps” | Employers must take “all reasonable steps” |
| Harassment by third parties | Employer liability covers harassment by other workers | Employer can also be liable for harassment by third parties, unless it took all reasonable steps to prevent it |
Why does one word matter?
The shift from “reasonable steps” to “all reasonable steps” looks small, but Acas, the workplace advisory service, is clear that it changes the approach. In its guidance, Acas says employers must take all the steps that are reasonable for their organisation, not just some of them. The focus is on preventing harassment rather than only reacting once something has happened, and steps should apply across the whole organisation rather than only to the people involved in a past incident.
That distinction matters in practice. An employer that investigates a complaint carefully but has done little to stop the behaviour arising in the first place is responding, not preventing. The new wording points firmly towards the second.
Acas also stresses that the duty is not identical for everyone. Appropriate steps depend on factors such as organisation size, sector and the type of work done, and larger or more complex organisations will likely need to take more steps. The duty covers sexual harassment online as well as in person.
What counts as sexual harassment?
Acas describes sexual harassment as “unwanted behaviour of a sexual nature”. To count, the behaviour must either violate someone’s dignity or create an intimidating, hostile, degrading, humiliating or offensive environment for them. It can count even if it was not intended to have that effect.
Examples given by Acas include:
- sexual remarks about someone’s body, clothing or appearance;
- questions about someone’s sex life;
- sexually offensive jokes;
- displaying or sharing sexual or pornographic images, including AI-generated images;
- unwanted touching, such as hugging;
- sexual assault or rape.
It can happen in person or online, and it can be a one-off incident or a pattern. Acas is explicit that “banter” or workplace culture does not excuse it. The Equality Act 2010 protects employees and workers, contractors and self-employed people hired to do the work personally, and job applicants. Individuals who harass someone can also be named in discrimination complaints and employment tribunal claims, not just employers.
What might “all reasonable steps” look like in practice?
The detail of what is expected is partly still to come. Acas says the law will later define what “all reasonable steps” means for preventing sexual harassment, and section 22 of the Act gives a power to make provision on the point. Until then, Acas lists examples of steps an employer might take:
- reviewing and updating existing policies, and considering a standalone sexual harassment policy;
- giving workers more than one way to report harassment;
- providing training suited to the organisation, using specialist delivery where needed;
- putting prevention measures in place rather than only responding to incidents;
- at induction, sharing the policy, requiring training, stating that harassment will not be tolerated and explaining how to recognise and report it;
- giving additional training to senior leaders, team leaders, managers, fair treatment contacts, HR staff and trade union representatives so they can handle complaints.
These are examples, not a checklist that guarantees compliance. Whether an employer has done enough will depend on its circumstances.
Who counts as a third party?
The second change is likely to be the most visible in customer-facing jobs. According to Acas, a third party is anyone a worker is in contact with through work, including people who do not work for the employer. Examples include customers, clients, service users such as school students or healthcare patients, self-employed contractors, people at events and members of the public. Harassment can occur online or in person.
The government’s timeline describes the obligation as one not to permit harassment of employees by third parties. Acas says employers can be liable for it unless they took all reasonable steps to prevent it. Its guidance on third-party harassment is not confined to sexual harassment: it refers to harassment more generally.
For people who work in shops, hospitality, healthcare, education, transport or events, this recognises something familiar: much of the unwanted behaviour they face does not come from colleagues.
Steps Acas suggests for third-party harassment
Acas lists a range of possible measures, noting that what is reasonable depends on size, sector and type of work:
- regular risk assessments, acted on;
- monitoring and recording incidents and the response to them;
- a policy, such as a bullying and harassment policy;
- training, for example in staff safety and de-escalation;
- reviewing contracts and terms, and telling customers the consequences of harassing workers;
- in higher-risk settings, adequate staffing such as security staff, safety equipment such as personal alarms, and body or security cameras.
Acas gives two illustrative scenarios. In one, a chain of shops dismisses threats and racist abuse as “part of the job” and threatens staff who complain; Acas says that employer is very unlikely to have taken all reasonable steps. In the other, a nightclub adds door supervisors, alarms, cameras, code words and safe areas, tracks incidents and reviews problems quickly; Acas says that employer is likely to have taken all reasonable steps.
Is every possible step required?
No. Acas says taking all reasonable steps means doing what is possible with the resources available, and that some steps will not be feasible for every organisation. It advises employers to record their reasons for not taking a step they judge unreasonable, including where a step is applied to only some workers.
That record-keeping point is a useful signal for employees too. An employer that can show it thought about risks, chose measures and wrote down its reasoning is in a stronger position than one that can only say it had no complaints.
How does this connect to whistleblowing and other rights?
Another change is already in force. According to the government timeline, protections for workers who “blow the whistle” on sexual harassment took effect on 6 April 2026. Acas explains that sexual harassment is now a “qualifying disclosure” under whistleblowing law. Whistleblowers are protected from detriment and, if they have employee status, from unfair dismissal; workers who are not employees cannot claim unfair dismissal but may be able to claim detriment. Acas adds that the protection applies even if the harassment or the disclosure happened earlier.
The government also lists regulations to prevent the misuse of non-disclosure agreements in cases of workplace harassment or discrimination among the measures expected to take effect in 2027. It adds that future dates “remain subject to parliamentary processes and may change”.
Harassment sits alongside other workplace protections covered elsewhere on this site, including what support can look like for menopause at work, what the Equality Act means for dress codes, how statutory maternity leave and pay work and what the gender pay gap figure does and does not measure.
What can employees and employers do now?
For employees, the practical position is that the standard employers are held to is rising, but the route for raising concerns is unchanged. Acas suggests that workers who have questions can contact its helpline, and that legal advice is sensible before taking further action. It is also worth finding out in advance what your employer’s policy says and who a concern can be raised with, since Acas lists multiple reporting routes as an example of a reasonable step.
For employers, Acas suggests starting early: reviewing existing policies such as lone working, identifying the third parties workers deal with, making sure staff know how to raise concerns, and assessing whether current measures are reasonable.
A higher bar, with detail still to come
The 30 October changes move workplace harassment law from reaction towards prevention, and extend employers’ responsibility to the customers, clients and visitors their staff meet. The final shape of “all reasonable steps” will emerge through guidance, any regulations and tribunal decisions, so details may develop over time. For now, the clearest signals come from Acas and the government’s own timeline.
This article is general information based on published guidance, not legal advice. For advice on a specific situation, contact Acas, Citizens Advice or a qualified adviser.
Sources: Acas (Harassment law changes: third party harassment); Acas (Sexual harassment law changes); Acas (Sexual harassment); GOV.UK (Plan to Make Work Pay and Employment Rights Act: timeline update); legislation.gov.uk (The Employment Rights Act 2025 (Commencement No. 6 and Transitional and Saving Provisions) Regulations 2026)
