Sexual harassment at work: the "all reasonable steps" duty from 30 October 2026

Last checked 17 Oct 2026. Dates can change. Great Britain only.

The commencement regulations (SI 2026/1065) bring three parts of the Employment Rights Act 2025 into force on 30 October 2026: section 20, section 21 and section 22. Together they tighten the law on preventing harassment at work.

What changes

• Section 20 amends section 40A of the Equality Act 2010. The employer duty to prevent sexual harassment of employees moves from taking "reasonable steps" to taking "all reasonable steps".
• Section 21 deals with harassment by third parties, such as customers, clients, contractors and suppliers. It is not limited to sexual harassment. An employer is treated as permitting third party harassment if it failed to take all reasonable steps to prevent it.
• Section 22 gives ministers a power to set out what steps count. GOV.UK describes this as a power to specify evidence based steps later.

We have not found regulations that list the specific steps yet. Until they appear, the legislation does not spell out what "all reasonable steps" means in practice, so records of what you actually do matter.

Who it affects

Every employer in Great Britain, whatever the size. Small employers have the same duty as large ones, although what is reasonable for a five person office may look different from a large site.

A checklist to help you prepare

• Write down what you already do to prevent sexual harassment: policy, training, reporting routes and how concerns are handled.
• List the people your staff deal with, such as customers, clients, visitors, contractors and suppliers, and note where the risk is higher, for example evening work, lone working, alcohol or client sites.
• Check that every manager knows how to take a report and who to pass it to.
• Check that staff know how to raise a concern and that there is more than one route, so nobody has to go through the person they are worried about.
• Keep dated records of what you do, who was told and when you reviewed it.
• Diary a review for when the regulations on specific steps appear.

Related

Since 6 April 2026, whistleblowing protection also covers workers who report sexual harassment. See changes already live from April 2026.

The Equality and Human Rights Commission and Acas both publish guidance on preventing harassment. This page is general information, not legal advice, and it does not guarantee that any step you take is enough.

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