UK employers face tougher sexual harassment prevention duties from 2026

From October 30, 2026, UK employers will be required to take all reasonable steps to prevent sexual harassment, including harassment by third parties such as customers and clients, according to HR Grapevine. The changes stem from the Employment Rights Act 2025 and mark a significant shift in employer obligations.

The new duty will extend beyond direct employees to cover conduct by individuals outside the organization, including customers, clients, and service users. Employers will need to demonstrate that they are actively identifying and addressing workplace harassment risks before incidents occur.

What the new duty requires

Under the reforms, organizations must move from a reactive approach to a proactive one. Instead of responding to harassment after it happens, employers will be expected to anticipate and mitigate risks. HR Grapevine reported that the duty to prevent harassment will require employers to show they have taken all reasonable steps, though the legislation does not define precisely what those steps are.

The extension to third-party harassment means employers could be liable if they fail to protect workers from harassment by customers, clients, or other non-employees. This represents a notable expansion of employer responsibility.

Practical implications for HR teams

HR departments will need to review and update their policies, training, and risk assessment processes well before the October 2026 deadline. According to HR Grapevine, training is essential to help staff understand the new expectations and to demonstrate compliance.

Employers should consider conducting regular risk assessments to identify situations where harassment could occur, such as customer-facing roles or off-site work. Clear reporting channels and robust investigation procedures will also be important. However, the specific measures required will vary by jurisdiction and workplace context, and employers should seek legal advice tailored to their circumstances.

Shift from reaction to prevention

The new duty signals a cultural shift in how workplace harassment is managed. Rather than focusing on responding to complaints, employers will need to build prevention into their everyday operations. HR Grapevine noted that for many organizations, the reforms will require a fundamental change in approach.

This could involve more frequent training, better supervision in high-risk areas, and stronger policies that explicitly address third-party harassment. Employers may also need to engage with clients and customers to set expectations about acceptable behavior.

Preparing for compliance

With the October 2026 date set, employers have time to prepare, but early action is advisable. HR teams should begin by reviewing current harassment policies and identifying gaps in relation to third-party conduct. Training programs should be updated to cover the new duty and the concept of reasonable steps.

Documentation will be key. Employers should keep records of risk assessments, training completion, and any steps taken to address identified risks. This evidence will be important if an employer needs to demonstrate compliance with the new duty.

Sources: HR Grapevine