Are you up to date with the Sexual Harassment mandatory measures?
From October 2024, UK employers moved from a reactive to a proactive duty on sexual harassment and that duty is only going to get tougher in 2026 and 2027.
If you have not done so already, now is the moment to check whether your organisation’s policies, training and risk assessments are genuinely fit for purpose ahead of the upcoming changes.
What changed in October 2024?
To remind ourselves, The Worker Protection (Amendment of Equality Act 2010) Act came into force on 26 October 2024, which introduced the statutory duty on employers to take reasonable steps to prevent sexual harassment.
This duty is enforceable both through Employment Tribunals with potential compensation uplifts of up to 25%. Crucially, employers are expected to anticipate and assess harassment risks and put reasonable, preventative measures in place.
Recommended Steps
From an HR perspective, we are now urging our clients to start to proactively consider:
Reviewing and updating all dignity at work, anti-harassment and grievance policies so they explicitly cover sexual harassment, online conduct and third-party risks.
Implement a sexual harassment risk assessment, looking at roles, locations, work patterns and customer exposure, and identifying any hotspots that may be relevant to your organisation (for example, client events).
Roll out regular yearly, scenario-based training for all staff, with enhanced, behaviour-focused training for leaders and people managers, and clear expectations around bystander intervention.
Put in place safe, confidential and well-signposted reporting channels, track and log cases, and routinely analyse themes and hotspots.
Ensure investigations are prompt, with appropriate protections against victimisation and clear links to your disciplinary process.
Brief your Board and Executive Team on legal duties, organisational risk, and culture indicators, so there is visible top-down ownership.
Looking ahead: 2026 and 2027 – higher bar, wider risk
The direction of travel is clear: the duty will harden, and liability will widen.
From April 2026, Sexual harassment will also become a qualifying disclosure for whistleblowing protection, enabling workers to speak up about harassment without fear of retaliation.
From the same period, employers are expected to face explicit liability where employees are harassed by third parties (including clients, customers, contractors and even members of the public) and the organisation cannot show that it took all reasonable steps to prevent it.
From October 2026, the anticipatory duty is expected to be strengthened so that employers must now take all reasonable steps to prevent sexual harassment, moving beyond the previous standard of merely taking reasonable steps. This shift emphasises a more proactive approach to creating a safe work environment.
By 2027, the “stronger duty” under the Worker Protection regime is anticipated to be fully in force.
Across all industries and sectors, third-party risk management will become a core compliance issue rather than a “nice to have”.
How can we support you
Leaving this until claims, media scrutiny or regulator interest emerge is a high-stakes gamble. Investing now in robust policies, focused training and meaningful risk assessments not only reduces legal and financial exposure, but it also sends a clear signal to your people about the culture you expect at your organisation.
We can quickly and confidently review your current framework to close any gaps and support you in implementing any additional measures at pace. We have packages to suit all budgets, from reviewing policies and procedures to conducting more in-depth, comprehensive risk-assessments.
JourneyHR can support organisations to:
Audit existing policies against current and upcoming duties.
Design and deliver tailored training for Boards, leaders and staff. As well as ongoing e-learning modules for smaller employers, or to help capture any new starters.
Build practical sexual harassment risk assessments and third-party protocols.
If you are unsure whether your organisation is genuinely “up to date”, this is exactly the time to partner with a specialist HR consultancy and get ahead of the 2026–27 changes.
Contact us: enquiries@journeyhr.com