Employment Rights Act 2025: Your Month-by-Month Implementation Timeline (Updated September 2026)

The Employment Rights Act 2025 is the biggest shake-up of UK employment law in a generation. Rather than landing all at once, it’s being introduced in stages between April 2026 and 2027 — and the government has revised the schedule more than once along the way. With the next wave of changes now only weeks away, here’s where things stand as of September 2026, and what UK SME employers need to have in place before October.

What’s already in force

Several changes have now taken effect:

• Statutory Sick Pay expansion, giving workers access to SSP from day one of illness and removing the lower earnings limit (from 6 April 2026)
• Day-one parental leave rights and reformed paternity leave (from 6 April 2026)
• New holiday pay record-keeping requirements for employers (from 6 April 2026)
• Strengthened whistleblowing protections, including disclosures about sexual harassment now qualifying for protection (from 6 April 2026)
• Collective redundancy protective awards doubled for employers who fail to consult properly
• The Fair Work Agency, the new enforcement body, launched on 7 April 2026 and has since taken on enforcement responsibility for pay, holiday, employment agency and modern slavery/gangmaster compliance
• Trade union reforms, including the repeal of most minimum service level requirements and electronic and workplace balloting for statutory union ballots, which went live from 31 August 2026

What’s changing on 1 and 30 October 2026

This is the deadline employers should be focused on right now:

• 1 October 2026 — the time limit for bringing most employment tribunal claims doubles from three to six months (Scotland’s equivalent extension for breach of contract claims follows on 9 November 2026)
• 30 October 2026 — a bundle of measures lands together:
  • Employers must take “all reasonable steps,” not just “reasonable steps,” to prevent sexual harassment
  • Employers become responsible for preventing harassment of staff by third parties (customers, clients, contractors) across all protected characteristics except marriage/civil partnership and pregnancy/maternity
  • New trade union workplace access rights, restrictions on unfair practices during union recognition campaigns, workers’ right to be notified of union membership, and protection from detriment for taking part in industrial action

What’s coming after October 2026

• End of 2026 — the strengthened tipping law and Code of Practice, originally expected alongside the October changes, has been pushed back to the end of the year after union criticism of the draft Code
• December 2026 — Seafarer protection regulations
• January 2027 — unfair dismissal protection from day one, with the qualifying period dropping to six months; this applies retrospectively to anyone hired from late June 2026 onwards. Compensation cap changes and further restrictions on fire-and-rehire practices land at the same time
• Through 2027 (secondary legislation and consultation responses still to follow) — zero-hours contract reforms (guaranteed hours, reasonable shift notice, cancellation pay), stronger flexible working rights, expanded family rights (maternity returner protections, bereavement leave extended to cover pregnancy loss before 24 weeks), restrictions on NDAs covering harassment and discrimination disclosures, changes to collective redundancy consultation thresholds, and regulation of umbrella companies. Fair Work Agency enforcement of holiday pay has also slipped into 2027, and gender pay gap reporting changes remain tied to the not-yet-published Equality (Race and Disability) Bill

What UK SME employers should do now

With 1 October only a few weeks away, this isn’t a “get round to it” list any more:

1. Finalise your harassment policy and training before 30 October. “All reasonable steps” is a materially higher bar than the current standard, and tribunals will expect to see documented training, clear reporting routes and a genuine risk assessment — not just a policy sitting in a handbook.
2. Update your document retention practices ahead of 1 October. With tribunal time limits doubling, evidence and witness recollection need to survive for longer before a claim can be brought.
3. Audit onboarding and probation processes now. Anyone hired from late June 2026 will carry day-one unfair dismissal protection into January 2027, so your probation and performance-management processes need to be ready well before then.
4. Brief your managers this month, not in October. Front-line managers handling grievances, disciplinaries, exit conversations and third-party complaints are your first line of defence against tribunal risk.
5. Keep an eye on 2027. Zero-hours contracts, flexible working and family leave reforms are still going through consultation, but the direction of travel is clear enough to start scoping the impact on your workforce now.

The timetable has already shifted more than once since the Act received Royal Assent, and further fine-tuning of the 2027 measures is likely. The safest approach remains the same: treat each phase as a trigger to review policy and training, rather than waiting for the final deadline to arrive.

Contact us now, to see how YouManageHR can help you keep the evidence trail — training completion, policy sign-off, holiday pay records — ahead of the October deadlines?