Sexual Harassment Law Changes October 2026

Friday 30 October is a big day for every HR and L&D team in the country. That’s when the next stage of the sexual harassment rules comes into force under the Employment Rights Act 2025.

Back in 2024, I wrote about the new sexual harassment laws that introduced a duty on employers to take reasonable steps to prevent it. This next change goes further, and a lot of organisations aren’t ready.

An Acas-commissioned YouGov poll of 1,050 senior decision makers, carried out between 27 April and 6 May 2026, found that 41% weren’t aware of the changes coming. That’s two in five businesses about to be caught out.

Key Points:

From 30 October 2026, employers must take all reasonable steps to prevent sexual harassment
Employers will be liable when their staff are harassed by third parties such as clients, customers or contractors
Training for managers and staff is one of the clearest ways to show you’ve taken the steps required

What’s Changing?

On 30 October 2026 the duty to prevent sexual harassment gets tougher, and you become responsible for harassment your people face from anyone outside the business. Here’s what each one means for you.

From “reasonable steps” to “all reasonable steps”

Since October 2024, employers have had a legal duty to take reasonable steps to prevent sexual harassment of their workers. From 30 October, that becomes a duty to take all reasonable steps.

It sounds like a small tweak, but it raises the bar considerably. To meet the new standard, you’ll need to be able to show there was nothing more you could reasonably have done. A policy sitting in a handbook that nobody has read won’t cut it.

Liability for third-party harassment

This is the big one. Employers can now be held liable when their people are harassed by someone outside the organisation. That includes clients, customers, contractors, suppliers, guests and members of the public.

It covers harassment related to any protected characteristic under the Equality Act, so it goes beyond sexual harassment. The only way to protect yourself is to show you took all reasonable steps to stop it happening.

Think about the people in your business who deal with the public every day. Your receptionists, your customer service team, your sales people at client sites, your staff at events. They’re now firmly your responsibility.

What Happens If You Get It Wrong?

If an employee brings a successful sexual harassment claim and you haven’t met your duty to prevent it, a tribunal can increase the compensation by up to 25%. The Equality and Human Rights Commission can also take enforcement action against employers who aren’t complying.

Add the reputational damage that comes with a public tribunal case and the cost to staff morale, and it’s an expensive mistake to make.

What Do “All Reasonable Steps” Look Like?

The government hasn’t set out a definitive list yet, and further regulations are expected in 2027. What’s reasonable will depend on your size, sector and working environment. That said, the guidance from Acas and the EHRC points to a few things every employer should have in place.

An up-to-date policy. Make sure it covers third-party harassment and that people know where to find it.
A risk assessment. Look at where your people are most exposed, especially roles that deal with customers or work off site.
Clear reporting routes. People need to know how to raise a concern and feel confident they’ll be taken seriously.
Proper complaint handling. Investigate quickly, fairly and consistently.
Rules for third parties. Brief clients and contractors, put up signage where it makes sense and review your contracts.
Regular training. For everyone, and especially for managers.

Why Training Matters So Much

Of everything on that list, training is the one I’d prioritise. It’s how people learn what harassment looks like, what to do if they see it or experience it and how to handle a complaint properly.

Managers need it most. They’re usually the first person someone tells, and how they respond in that moment shapes everything that follows. A manager who brushes a complaint aside, or doesn’t know what to do with it, can undo the best policy in the world.

Training also gives you something you can evidence. If you ever need to show a tribunal that you took all reasonable steps, being able to point to completion records for every member of staff puts you in a far stronger position. It’s one of the benefits of employee training that often gets overlooked.

One-off sessions aren’t enough on their own though. People forget, staff change and new risks appear. Refresher training and short bursts of microlearning through the year keep it front of mind.

Our New Courses: One for Managers, One for Staff

If you’ve already got this covered, great. If you haven’t, have a look at your policy, check who’s been trained and fill the gaps.

To help organisations get ready, my team at Skillshub have built two new online courses on the changes.

For managers: how to prevent harassment in their teams, spot the warning signs and handle complaints properly, including harassment by third parties.
For staff: what harassment is, the new protections around third parties and how to raise a concern.

They’ll be available on our online learning platform alongside the rest of our course library.

If you’d like to see our courses or talk through what your organisation needs, book a free demo and we’ll get you sorted.

Sean McPheat

Sean is the CEO of Skillshub. He’s a published author and has been featured on CNN, BBC and ITV as a leading authority in the learning and development industry. Sean is responsible for the vision and strategy at Skillshub, helping to ensure innovation within the company.