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Proposed Timeline for Employment Law Reform

On 1 July 2025, the Government published its Employment Rights Bill Implementation Roadmap, setting out the reform timeline and confirming consultations with employers, workers, and unions. It also pledged detailed guidance—developed with Acas—to support compliance.

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Published 4 July 2025

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On 1 July 2025, the Government published the Employment Rights Bill Implementation Roadmap detailing the expected timeline for the implementation of various areas of reform under the Employment Rights Bill.

The Roadmap highlights the importance of consultation in relation to the proposed legislative reforms and outlines how and when this will take place. Consultation will involve obtaining input from employers, workers, trade unions, and other relevant stakeholders. The Government acknowledges that the reforms will necessitate a period of preparation for employers, including updates to existing HR, IT, and payroll systems. To ensure clarity regarding the new obligations and to support compliance, the Government has confirmed that it will issue detailed guidance, developed in collaboration with Acas.

Full details of the anticipated implementation dates for different parts of the Bill are set out in the table below. Key points to note include:

April 2026 reforms

Statutory Sick Pay (‘SSP’) reforms

SSP will become payable for all eligible employees from the first day of sickness absence. Unpaid ‘waiting days’ will no longer apply and the lower earnings limit will be removed.

 ‘Day one’ paternity and unpaid parental leave

The current length of service requirements for paternity and unpaid parental leave will be removed, making these types of leave day one rights.

October 2026 reforms

Ban on fire and rehire practices

If an employee refuses to accept a contractual change to their terms and conditions of employment, and is subsequently dismissed with the option of being rehired on new terms (or replaced), the dismissal will be automatically unfair. There is expected to be a very limited exception for employers facing financial difficulties where this affects their ability to carry on the business as a going concern.

Duty for employers to take all reasonable steps to prevent sexual harassment

Employers will need to take ‘all’ reasonable steps to prevent sexual harassment in the workplace.

Liability for third party harassment of employees

Employers will be liable for third party harassment unless they have taken all reasonable steps to prevent this.

Extension to time limits for tribunal claims

The time limits for bringing most tribunal claims will be increased from three to six months.

2027 reforms

‘Day one’ unfair dismissal rights

Employees will have the right not to be unfairly dismissed from day one of their employment. It is anticipated that there will be a light touch procedure for dismissal during an “initial period” (likely to be nine months).

Changes to zero hours contracts

There will be a new right for zero and low hours workers to be offered guaranteed hours at the end of a relevant reference period (likely to be 12 weeks). There will also be new rights to reasonable notice of shifts (including notice of any change or cancellation of a shift) and payment for shifts cancelled or curtailed at short notice. These provisions will also apply to agency workers.

What do employers need to do now to prepare?

Despite the delay to certain areas of reform, the breadth of proposed changes means it would be advisable for employers to start taking steps to prepare now. In particular, businesses should consider formulating plans to:

  1. Update payroll systems to prepare for changes to SSP and paternity and unpaid parental leave
  2. Identify which policies will need to be updated and when. These will include policies relating to:
    • Sick pay
    • Paternity leave
    • Unpaid parental leave
    • Anti-harassment
    • Redundancy and collective consultation
    • Flexible working
    • Bereavement leave
  3. Identify any proposed variations to terms and conditions of employment that would fall foul of the fire-and-rehire ban
  4. Review onboarding and probationary processes and systems in anticipation of the day one unfair dismissal rights

Contact the Employment Team at Collyer Bristow for practical advice and assistance with reviewing, updating and implementing appropriate policies and procedures for your organisation.

Full List of Anticipated Implementation Dates

 

At or shortly after Royal Assent  

·       Repeal of the Strikes (Minimum Service Levels) Act 2023

·       Repeal of the great majority of the Trade Union Act 2016 (some provisions will be repealed via commencement order at a later date)

·       Removing the 10 year ballot requirement for trade union political funds

·       Simplifying industrial action notices and industrial action ballot notices

·       Protections against dismissal for taking industrial action

 
April 2026  

·     Collective redundancy protective award – doubling the maximum period of the protective award

·     ‘Day 1’ Paternity Leave and Unpaid Parental Leave

·     Whistleblowing protections

·     Fair Work Agency body established

·     Statutory Sick Pay – remove the Lower Earnings Limit and waiting period

·     Simplifying trade union recognition process

·     Electronic and workplace balloting

 
October 2026  

·     Fire and rehire

·     Bringing forward regulations to establish the Fair Pay Agreement Adult Social Care Negotiating Body

·     Procurement – two-tier code

·     Tightening tipping law

·     Duty to inform workers of their right to join a trade union

·     Strengthen trade unions’ right of access

·     Requiring employers to take “all reasonable steps” to prevent sexual harassment of their employees

·     Introducing an obligation on employers not to permit the harassment of their employees by third parties

·     New rights and protections for trade union reps

·     Employment tribunal time limits

·     Extending protections against detriments for taking industrial action

 
During 2027  

·     Gender pay gap and menopause action plans (introduced on a voluntary basis in April 2026)

·     Rights for pregnant workers

·     Introducing a power to enable regulations to specify steps that are to be regarded as “reasonable”, to determine whether an employer has taken all reasonable steps to prevent sexual harassment

·     Blacklisting

·     Industrial relations framework

·     Regulation of umbrella companies

·     Collective redundancy – collective consultation threshold

·     Flexible working

·     Bereavement leave

·     Ending the exploitative use of ZHCs and applying ZHC measures to agency workers

·     ‘Day 1’ right – protection from unfair dismissal

 

 

 

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Shorter Reads

Proposed Timeline for Employment Law Reform

On 1 July 2025, the Government published its Employment Rights Bill Implementation Roadmap, setting out the reform timeline and confirming consultations with employers, workers, and unions. It also pledged detailed guidance—developed with Acas—to support compliance.

Published 4 July 2025

Associated sectors / services

  • Employment law for employees
  • Employment law for employers

Authors

On 1 July 2025, the Government published the Employment Rights Bill Implementation Roadmap detailing the expected timeline for the implementation of various areas of reform under the Employment Rights Bill.

The Roadmap highlights the importance of consultation in relation to the proposed legislative reforms and outlines how and when this will take place. Consultation will involve obtaining input from employers, workers, trade unions, and other relevant stakeholders. The Government acknowledges that the reforms will necessitate a period of preparation for employers, including updates to existing HR, IT, and payroll systems. To ensure clarity regarding the new obligations and to support compliance, the Government has confirmed that it will issue detailed guidance, developed in collaboration with Acas.

Full details of the anticipated implementation dates for different parts of the Bill are set out in the table below. Key points to note include:

April 2026 reforms

Statutory Sick Pay (‘SSP’) reforms

SSP will become payable for all eligible employees from the first day of sickness absence. Unpaid ‘waiting days’ will no longer apply and the lower earnings limit will be removed.

 ‘Day one’ paternity and unpaid parental leave

The current length of service requirements for paternity and unpaid parental leave will be removed, making these types of leave day one rights.

October 2026 reforms

Ban on fire and rehire practices

If an employee refuses to accept a contractual change to their terms and conditions of employment, and is subsequently dismissed with the option of being rehired on new terms (or replaced), the dismissal will be automatically unfair. There is expected to be a very limited exception for employers facing financial difficulties where this affects their ability to carry on the business as a going concern.

Duty for employers to take all reasonable steps to prevent sexual harassment

Employers will need to take ‘all’ reasonable steps to prevent sexual harassment in the workplace.

Liability for third party harassment of employees

Employers will be liable for third party harassment unless they have taken all reasonable steps to prevent this.

Extension to time limits for tribunal claims

The time limits for bringing most tribunal claims will be increased from three to six months.

2027 reforms

‘Day one’ unfair dismissal rights

Employees will have the right not to be unfairly dismissed from day one of their employment. It is anticipated that there will be a light touch procedure for dismissal during an “initial period” (likely to be nine months).

Changes to zero hours contracts

There will be a new right for zero and low hours workers to be offered guaranteed hours at the end of a relevant reference period (likely to be 12 weeks). There will also be new rights to reasonable notice of shifts (including notice of any change or cancellation of a shift) and payment for shifts cancelled or curtailed at short notice. These provisions will also apply to agency workers.

What do employers need to do now to prepare?

Despite the delay to certain areas of reform, the breadth of proposed changes means it would be advisable for employers to start taking steps to prepare now. In particular, businesses should consider formulating plans to:

  1. Update payroll systems to prepare for changes to SSP and paternity and unpaid parental leave
  2. Identify which policies will need to be updated and when. These will include policies relating to:
    • Sick pay
    • Paternity leave
    • Unpaid parental leave
    • Anti-harassment
    • Redundancy and collective consultation
    • Flexible working
    • Bereavement leave
  3. Identify any proposed variations to terms and conditions of employment that would fall foul of the fire-and-rehire ban
  4. Review onboarding and probationary processes and systems in anticipation of the day one unfair dismissal rights

Contact the Employment Team at Collyer Bristow for practical advice and assistance with reviewing, updating and implementing appropriate policies and procedures for your organisation.

Full List of Anticipated Implementation Dates

 

At or shortly after Royal Assent  

·       Repeal of the Strikes (Minimum Service Levels) Act 2023

·       Repeal of the great majority of the Trade Union Act 2016 (some provisions will be repealed via commencement order at a later date)

·       Removing the 10 year ballot requirement for trade union political funds

·       Simplifying industrial action notices and industrial action ballot notices

·       Protections against dismissal for taking industrial action

 
April 2026  

·     Collective redundancy protective award – doubling the maximum period of the protective award

·     ‘Day 1’ Paternity Leave and Unpaid Parental Leave

·     Whistleblowing protections

·     Fair Work Agency body established

·     Statutory Sick Pay – remove the Lower Earnings Limit and waiting period

·     Simplifying trade union recognition process

·     Electronic and workplace balloting

 
October 2026  

·     Fire and rehire

·     Bringing forward regulations to establish the Fair Pay Agreement Adult Social Care Negotiating Body

·     Procurement – two-tier code

·     Tightening tipping law

·     Duty to inform workers of their right to join a trade union

·     Strengthen trade unions’ right of access

·     Requiring employers to take “all reasonable steps” to prevent sexual harassment of their employees

·     Introducing an obligation on employers not to permit the harassment of their employees by third parties

·     New rights and protections for trade union reps

·     Employment tribunal time limits

·     Extending protections against detriments for taking industrial action

 
During 2027  

·     Gender pay gap and menopause action plans (introduced on a voluntary basis in April 2026)

·     Rights for pregnant workers

·     Introducing a power to enable regulations to specify steps that are to be regarded as “reasonable”, to determine whether an employer has taken all reasonable steps to prevent sexual harassment

·     Blacklisting

·     Industrial relations framework

·     Regulation of umbrella companies

·     Collective redundancy – collective consultation threshold

·     Flexible working

·     Bereavement leave

·     Ending the exploitative use of ZHCs and applying ZHC measures to agency workers

·     ‘Day 1’ right – protection from unfair dismissal

 

 

 

Associated sectors / services

  • Employment law for employees
  • Employment law for employers

Authors

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