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

From 30 October 2026, employers must take all reasonable steps to prevent sexual harassment of their employees. It is a small change in wording with a big effect, and it applies to every employer, whatever their size.

What is changing

The duty gets stronger. Since October 2024, employers have had a legal duty to take reasonable steps to prevent sexual harassment of their employees. From 30 October 2026, the Employment Rights Act 2025 raises this to all reasonable steps. If there was a reasonable step you could have taken and did not, you have not met the duty.

It is about prevention, not just reaction. The duty applies before anything goes wrong. Dealing well with a complaint is important, but on its own it is not enough. You need to have thought about the risks in your workplace and acted on them.

The consequences are real. If an employee wins a sexual harassment claim and the employer has not met the duty, a tribunal can increase the compensation by up to 25%. The Equality and Human Rights Commission can also take enforcement action, even where no one has brought a claim.

More detail may follow. The Act allows the Government to set out in regulations particular steps that count as reasonable. We will update this guidance if it does.

What counts as all reasonable steps

There is no fixed checklist, and what is reasonable depends on the size and resources of your business. But a tribunal will expect most employers to be able to show:

• A risk assessment. Think about where harassment could happen in your workplace, such as lone working, late shifts, work social events, alcohol, customer-facing roles, and messaging between colleagues. Write down what you will do about each risk.

• A clear policy. A harassment policy that names sexual harassment, gives examples, explains how to report it and says what will happen.

• Training. For all staff, so everyone knows what is not acceptable, and extra training for managers on how to respond to a report.

• More than one way to report. Including a route that does not go through the person's line manager, and a way to raise concerns confidentially.

• Prompt action on complaints. Take every report seriously, investigate fairly, protect the person who reported it, and take appropriate action.

• Regular review. Check that the steps are working, especially after any incident or change in how you work.

Related changes

Also from 30 October 2026, employers must not permit their employees to be harassed by third parties, such as customers and clients. And since April 2026, an employee who reports sexual harassment is protected as a whistleblower.

What to do before 30 October

• Carry out and write down a sexual harassment risk assessment.

• Update your harassment policy and share it with every employee.

• Book training for staff and managers.

• Check your reporting routes work, including one that avoids line managers.

• Keep a record of what you have done. If a claim is made, you will need to show the steps you took.

How SignalHR helps

SignalHR's Policy Builder includes a Bullying & Harassment Policy updated for the new duty. You can also ask SignalHR how to handle a harassment complaint, what a fair investigation looks like, or what steps suit a business of your size.