Ready for the October 2026 Employment Law Changes?

The October 2026 employment law changes introduce two important changes for employers. From 1 October 2026, the time limit for bringing most Employment Tribunal claims increases from three months to six months minus one day.

Then, from 30 October 2026, employers will have stronger duties to prevent workplace harassment. They will need to take all reasonable steps to prevent sexual harassment and may also be liable for harassment by third parties, such as customers, clients or contractors, unless appropriate preventive steps have been taken.

For employers, the practical response should include reviewing record keeping, harassment policies, employee reporting procedures, manager training and how risks involving customers and other third parties are handled.

What Employment Law Changes Are Happening in October 2026?

The main Employment Law Changes UK employers need to prepare for in October are:

These measures form part of the continuing implementation of the Employment Rights Act 2025.

Further employment law changes are expected during 2027, so employers should treat October as part of a wider programme of reform rather than a one-off update.

What Changes on 1 October 2026?

From 1 October 2026, employees will generally have longer to bring a claim to an Employment Tribunal.

For most claims, the normal time limit increases from approximately three months to six months minus one day.

This can affect claims involving issues such as:

• unfair dismissal;
• discrimination;
• unpaid wages;
• unlawful deductions;
• whistleblowing;
• holiday pay; and
• other employment disputes.

The change applies where the relevant date that starts the limitation period falls on or after 1 October 2026.

Cases where the relevant event occurred before that date may remain subject to the previous rules.

Why Does the Six-Month Tribunal Deadline Matter for Employers?

A longer claim period has practical consequences for businesses even where no claim is eventually brought.

Employment records may need to remain readily available for longer.

Important documents can include:

• employment contracts;
• disciplinary records;
• grievance correspondence;
• performance records;
• dismissal documentation;
• emails and messages;
• attendance records;
• payroll information;
• meeting notes;
• investigation records; and
• records of management decisions.

A dispute that previously appeared unlikely to progress after three months may now remain capable of becoming a Tribunal claim for considerably longer.

Does Acas Early Conciliation Still Apply?

Yes, The extension to Employment Tribunal time limits does not remove the normal role of Acas Early Conciliation.

In many cases, someone considering a Tribunal claim must first notify Acas.

The interaction between the Tribunal deadline and the conciliation period can affect the final date by which a claim must be submitted.

Employers should therefore avoid calculating claim deadlines casually.

Where a dispute could lead to proceedings, legal advice may be appropriate.

What Changes on 30 October 2026?

The second major set of October employment law changes takes effect on 30 October 2026.

The law will strengthen employers’ responsibilities concerning workplace harassment in two important ways.

Employers will:

1. have to take all reasonable steps to prevent sexual harassment of employees; and
2. face potential liability for harassment of employees by third parties unless they have taken all reasonable steps to prevent it.

This means employers need to think proactively about risks rather than dealing with inappropriate behaviour only after a complaint has been made.

What Does “All Reasonable Steps” Mean?

The current duty already requires employers to take reasonable steps to prevent sexual harassment.

From 30 October 2026, this becomes a requirement to take all reasonable steps.

The exact measures that are reasonable will depend on the organisation and its risks.

However, practical steps may include:

• assessing where harassment could occur;
• maintaining a clear anti-harassment policy;
• providing appropriate staff training;
• training managers separately;
• establishing confidential reporting routes;
• investigating complaints promptly;
• keeping accurate records;
• monitoring recurring issues; and
• taking action where inappropriate behaviour occurs.

Simply having an anti-harassment paragraph in a staff handbook may not demonstrate that an employer has done everything reasonable in practice.

What Is Third-Party Harassment?

A third party is someone who interacts with an employee through their work but is not another employee of that organisation.

Examples can include:

• customers;
• clients;
• contractors;
• suppliers;
• consultants;
• tradespeople;
• service users;
• patients;
• students; and
• people attending conferences or events.

From 30 October 2026, employers may be liable where an employee is harassed by a third party and the employer failed to take all reasonable steps to prevent it.

Which Businesses Face the Greatest Third-Party Harassment Risk?

Any employer whose staff regularly interact with people outside the organisation should consider the risk.

This can be particularly relevant to:

• hospitality businesses;
• retailers;
• healthcare providers;
• professional services firms;
• schools and education providers;
• transport businesses;
• leisure businesses;
• customer service teams;
• property businesses; and
• businesses using contractors on site.

For example, a hotel employee could face inappropriate behaviour from a guest, while an employee at a professional services firm could encounter harassment from a client.

The fact that the person responsible is not employed by the same business does not mean the employer can ignore the situation.

Does Third-Party Harassment Only Cover Sexual Harassment?

No.

The new third-party protections extend beyond sexual harassment.

They can also apply to harassment connected with protected characteristics covered by the Equality Act.

This makes it important for employers to review their broader anti-harassment arrangements rather than focusing solely on sexual harassment.

What Should Employers Do Before 30 October 2026?

Businesses should use the remaining time to review their actual workplace risks.

1. Review Your Harassment Policy

Check that the policy covers:

• sexual harassment;
• employee-to-employee behaviour;
• third-party harassment;
• reporting routes;
• investigation procedures; and
• consequences of unacceptable behaviour.

2. Carry Out a Risk Assessment

Consider where inappropriate conduct could realistically arise.

Examples might include:

• staff parties;
• business travel;
• late-night working;
• customer-facing roles;
• private client meetings;
• messaging platforms;
• conferences;
• hospitality events; and
• contractor interactions.

3. Review Reporting Procedures

Employees should know:

• how to raise concerns;
• who they can speak to;
• what happens after a complaint;
• how confidentiality is managed; and
• what protection is available against retaliation.

4. Train Managers and Supervisors

Managers are often the first people to receive a complaint.

They should understand:

• how to respond appropriately;
• what should be documented;
• when to escalate the matter;
• what not to promise;
• how confidentiality should be handled; and
• when HR or legal support is needed.

5. Consider Third-Party Risks

Review interactions with:

• customers;
• clients;
• contractors;
• suppliers; and
• service users.

Employers may need to make behavioural expectations clear to people outside the organisation as well as employees.

Why Is Record Keeping More Important After October 2026?

Both major October changes make documentation increasingly important.

The longer Tribunal time limit means records may need to support decisions many months after an event.

The stronger harassment duty also makes it important for employers to demonstrate what preventive steps they actually took.

Relevant records could include:

• completed training;
• policy updates;
• attendance records;
• risk assessments;
• complaints;
• investigations;
• management responses;
• workplace adjustments;
• warnings issued; and
• steps taken with customers or contractors.

The purpose is not simply to create paperwork.

Good records can help demonstrate that the business had functioning procedures and followed them.

Is Having an Employment Policy Enough?

No.

A written policy is useful, but employers should also consider whether it operates effectively in practice.

For example:

• Do employees know the policy exists?
• Do managers understand it?
• Are employees comfortable reporting concerns?
• Are complaints actually investigated?
• Is training updated?
• Are known risks addressed?
• Are repeated problems monitored?

A policy that exists only in a handbook but is not followed may provide limited protection.

How Should Small Businesses Prepare?

Smaller businesses may not have an internal HR department, but they still need workable procedures.

A practical approach could be:

1. review the staff handbook;
2. update harassment and grievance policies;
3. check employment record retention;
4. identify third-party risks;
5. train managers;
6. establish a clear reporting route;
7. document training and policy updates; and
8. seek professional advice on complex disputes.

The procedures do not need to be unnecessarily complicated.

They do need to be clear, understood and consistently applied.

What Other Employment Law Changes Are Coming?

The changes of employment law in October form part of the wider Employment Rights Act 2025 implementation programme.

Further reforms are expected during 2027.

Businesses should therefore maintain an employment-law review process instead of updating policies only when a major deadline approaches.

Areas likely to require continued attention include:

• dismissal procedures;
• worker protections;
• family-related rights;
• zero-hours and guaranteed-hours arrangements;
• trade union rights;
• workplace harassment; and
• other employment protections.

The commencement date for each measure should be checked before policies are changed.

October 2026 Employment Law Checklist for Employers

Before the changes take effect, employers should check:

• Employment Tribunal record-retention arrangements
• Disciplinary procedures
• Grievance procedures
• Harassment policies
• Sexual harassment prevention measures
• Third-party harassment risks
• Staff reporting channels
• Manager training
• Investigation procedures
• Training records
• Customer and contractor expectations
• Staff handbook wording

The priority should be making sure procedures actually work rather than simply updating documents.

CASE STUDY: Preparing a Farringdon Employer for the October 2026 Employment Law Changes

A professional services business contacted CIGMA Accounting’s Fulham after reviewing the upcoming October 2026 employment law changes and realising that several of its HR procedures had not been updated for some time.

The company employed a mixture of office-based and client-facing staff. Management was particularly concerned about the longer Employment Tribunal claim period and the stronger duties around preventing workplace and third-party harassment.

CIGMA Accounting reviewed the business’s existing employment records, grievance procedures, harassment policies and manager responsibilities. We identified that some records were not being retained consistently and that the existing harassment policy focused mainly on employee-to-employee conduct, with limited reference to risks involving clients, contractors or other third parties.

We helped the business strengthen its processes by introducing clearer record-retention procedures, documenting staff training, improving reporting routes and reviewing how managers should respond when concerns are raised.

The company also carried out a practical risk assessment covering client meetings, business travel, events and contractor interactions so that preventive steps could be documented before the 30 October 2026 changes took effect.

By preparing early, the employer was better placed to demonstrate that its policies were not simply written documents but part of a functioning workplace process.

The client left with a clearer understanding of their position, options, and next steps.