The first update raises the legal standard for preventing sexual harassment from taking ‘reasonable steps to taking ‘all reasonable steps’. Relying solely on a written policy will no longer suffice. Employers must demonstrate clear evidence of prevention measures taken before any issue occurs.
The second update makes third-party harassment a standalone legal liability.
Employers become responsible for harassment carried out by clients, customers, or contractors unless clear evidence shows all reasonable steps were taken to prevent it. This applies across all protected characteristics.
A July 2026 poll of 985 HR professionals by VinciWorks revealed that 20% of UK businesses have not provided managers with sufficient training on these rules.
Being compliant with both duties requires six core elements:
Addressing these compliance gaps ensures full readiness before October. Reach out to discuss arranging a harassment prevention review for your business.
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