Reference

Employment Rights Act 2025: what employers need to do and when

The ERA 2025 is being implemented in phases between 2024 and 2028. This page tracks every change with confirmed dates, employer obligations, consequences for non-compliance, and which policies are affected. Last updated April 2026.

Dates marked "announced" are government-stated intentions where the commencement order has not yet been published. We update this page within 48 hours of any SI publication.

Already in force

These changes are live. Employers should already be compliant.

Harassment prevention duty

Now in force

In force since October 2024

What changed

Employers must take 'reasonable steps' to prevent sexual harassment. Third-party harassment protections restored. Worker Protection Act 2023.

What employers need to do

Implement anti-harassment policy, conduct risk assessments, provide training, create reporting mechanisms. Document all steps taken.

Consequence of non-compliance

25% uplift on compensation awards. Uncapped tribunal compensation.

Anti-harassment policyDisciplinary policyWhistleblowing policy

Day-one flexible working

Now in force

In force since April 2024

What changed

Right to request flexible working from day one (previously 26 weeks). Two requests per year. Employer must consult before refusing.

What employers need to do

Remove any qualifying period from flexible working policy. Update refusal process to include mandatory consultation.

Consequence of non-compliance

Automatic unfair dismissal if request handling is procedurally defective. Up to 8 weeks' pay award.

Flexible working policy

Day-one written statement

Now in force

In force since April 2020, expanded

What changed

Written statement of employment particulars required from day one (previously 2 months). Expanded to include additional particulars.

What employers need to do

Issue compliant written statement before or on first day of employment.

Consequence of non-compliance

Tribunal may award 2-4 weeks' pay for non-provision. Weakens employer's position in any subsequent claim.

Written statement / contract of employment

Day-one paternity and parental leave

Now in force

In force since April 2026

What changed

Paternity leave and unpaid parental leave become day-one rights. No qualifying period.

What employers need to do

Remove any qualifying period from paternity and parental leave policies.

Consequence of non-compliance

Automatic unfair dismissal for denial. Discrimination risk.

Paternity leave policyParental leave policyFamily leave policies

Bereaved Partner's Paternity Leave

Now in force

In force since April 2026

What changed

New statutory right for bereaved partners following the death of a mother within 52 weeks of birth.

What employers need to do

Create or update bereavement/paternity leave policy to include this right.

Consequence of non-compliance

Automatic unfair dismissal for denial.

Bereavement leave policyPaternity leave policy

Fair Work Agency operational

Now in force

Operational since April 2026

What changed

New single enforcement body replacing separate agencies. Powers to inspect premises, issue penalties, and bring tribunal claims on behalf of workers.

What employers need to do

Ensure all employment rights documentation is in order. FWA can conduct proactive inspections, not just respond to complaints.

Consequence of non-compliance

Penalties up to 200% of underpayments. Public naming. Criminal prosecution for serious cases.

All policies (enforcement applies across all rights)

October 2026

These dates have been announced by the government. Commencement orders have not yet been published.

"All reasonable steps" harassment regulations

Date announced

Expected October 2026

What changed

Standard rises from 'reasonable steps' to 'all reasonable steps'. Regulations will define what this means in practice. Third-party harassment liability confirmed.

What employers need to do

Review harassment prevention policy and evidence of steps taken. Prepare for enhanced EHRC inspection powers. Consider the 8-step EHRC framework.

Consequence of non-compliance

Enhanced 25% uplift mechanism. Uncapped compensation. EHRC enforcement action.

Anti-harassment policyTraining recordsRisk assessments

Industrial action protections

Date announced

Expected October 2026

What changed

Enhanced protections for workers taking lawful industrial action. Restrictions on use of agency workers during disputes.

What employers need to do

Review industrial relations procedures. Update any policies referencing strikes or industrial action.

Consequence of non-compliance

Automatic unfair dismissal for detriment related to lawful industrial action.

Disciplinary policyIndustrial relations procedures

January 2027

The most significant changes. Day-one unfair dismissal rights, uncapped compensation, and fire-and-rehire restrictions.

Unfair dismissal: day-one right with initial period

Date announced

Expected January 2027

What changed

Qualifying period for ordinary unfair dismissal drops from 2 years to day one, with a statutory initial period (expected 9 months) during which a lighter-touch process applies.

What employers need to do

Review dismissal procedures. Ensure documentation from day one. Update probationary period policy to align with the statutory initial period.

Consequence of non-compliance

Every employee can bring an unfair dismissal claim from their first day. Cost of poor process increases dramatically.

Probationary period policyDisciplinary policyPerformance management policy

Compensation cap removed

Date announced

Expected January 2027

What changed

The statutory cap on compensatory awards for unfair dismissal (currently £115,115 or 52 weeks' pay, whichever is lower) is being removed entirely. Awards will be based on actual financial loss with no upper limit.

What employers need to do

Review all dismissal-related procedures. The financial consequence of procedural failures becomes potentially catastrophic for senior employees.

Consequence of non-compliance

Uncapped liability. A poorly managed dismissal of an £80,000/year employee aged 45 could result in an award reflecting years of lost earnings.

Disciplinary policyRedundancy policyPerformance management policy

Fire-and-rehire: automatically unfair

Date announced

Expected January 2027

What changed

Dismissing an employee for refusing to accept changes to their contract of employment becomes automatically unfair dismissal. No qualifying period.

What employers need to do

Review any plans to change employment terms. Ensure consultation processes are robust. Update contracts policy.

Consequence of non-compliance

Automatic unfair dismissal. Enhanced compensation. No defence based on business needs alone.

Contracts and terms policyRedundancy policyTUPE procedures

2027 and beyond

These changes are in the ERA 2025 but do not yet have confirmed implementation dates.

Statutory bereavement leave

Awaiting commencement order

Expected 2027, awaiting consultation

What changed

A new statutory right to bereavement leave for all employees. Currently bereavement leave exists only for parents of children under 18.

What employers need to do

Review bereavement leave policy. Prepare to extend entitlement beyond parental bereavement once the right is commenced.

Consequence of non-compliance

Automatic unfair dismissal for denial once commenced. Discrimination risk in the interim.

Bereavement leave policyAbsence policy

Mandatory menopause action plans

Awaiting commencement order

Expected 2027

What changed

Large employers expected to publish menopause action plans. Details subject to secondary legislation and consultation.

What employers need to do

Consider developing a menopause policy and workplace adjustments framework now, ahead of mandatory requirements.

Consequence of non-compliance

To be defined by secondary legislation. Failure to publish may result in enforcement action.

Menopause policyHealth and wellbeing policyAbsence policy

Mandatory gender pay gap action plans

Awaiting commencement order

Expected 2027-2028

What changed

Employers required to publish action plans alongside gender pay gap reports. Currently only reporting is mandatory.

What employers need to do

Begin developing action plans alongside existing gender pay gap reporting if applicable.

Consequence of non-compliance

To be defined by secondary legislation.

Equal pay policyRecruitment policy

Zero-hours contract protections

Awaiting commencement order

Awaiting secondary legislation

What changed

Workers on zero-hours and low-hours contracts will gain rights to guaranteed hours based on hours regularly worked. Details subject to secondary legislation.

What employers need to do

Review use of zero-hours contracts. Prepare for potential obligation to offer guaranteed hours.

Consequence of non-compliance

To be defined by secondary legislation. Financial penalties expected for non-compliance.

Contracts policyWorking time policy

Check whether your policies are ready

The free compliance audit checks your employee handbook against all of these requirements. Upload your handbook and see where you stand before the next deadline.

This page is maintained by the Pedantic team and updated within 48 hours of relevant statutory instruments being published. It is not legal advice. For the definitive text of the Employment Rights Act 2025, see legislation.gov.uk. For official implementation guidance, see gov.uk/employment. Last updated: April 2026.