Support from an HR consultant in Ipswich to prepare your business for the tougher sexual harassment prevention duties arriving in October 2026.
I’ve been speaking with a lot of business owners lately who genuinely believe their harassment policy has them covered.
It doesn’t. Not anymore.
The legal standard for preventing sexual harassment at work is shifting in October 2026, and it’s a bigger change than most people realise.
If a claim is made against your business, having a policy on file won’t be enough to protect you.
Let me walk you through what’s happening and what you need to do about it.
How the law has shifted over time
The rules around employer responsibility for preventing sexual harassment have been tightening steadily.
Under the original Equality Act 2010, employers could generally defend themselves by pointing to a written policy. That was the baseline for years.
Then in 2024, the Worker Protection (Amendment of Equality Act 2010) Act 2023 came into effect. It placed a new proactive duty on employers to take “reasonable steps” to prevent sexual harassment.
From October 2026, that bar rises again. The requirement moves to “all reasonable steps.”
That single word, “all,” changes the expectation entirely. You’ll need to show that you did everything you reasonably could have done to prevent harassment. Not just something. Everything.
Third-party harassment is now your problem too
One of the most significant parts of the upcoming change is around liability for harassment by people outside your organisation.
If a customer, client, or contractor harasses one of your team members, and you can’t demonstrate that you took steps to prevent it, you could be held responsible.
Consider the roles in your business where staff regularly deal with people from outside. Sales teams visiting client premises. Staff working at events or in hospitality settings. Anyone interacting with the public on a daily basis.
Those roles now carry genuine legal exposure for your business. If you haven’t assessed the risk in those environments, you’re leaving yourself open.
What “all reasonable steps” looks like in practice
The phrase “all reasonable steps” sounds vague, but the expectations behind it are quite specific. Here’s what you should have in place before October 2026:
- An up-to-date policy that your staff have actually read and formally acknowledged. A document sitting in a shared drive that nobody has opened won’t count.
- Trained managers who understand how to respond when someone reports an issue. Knowing the policy exists isn’t the same as knowing what to do with it.
- Clear reporting routes that your employees are aware of and feel confident using.
- A written risk assessment that looks at the specific harassment risks in your business, especially where your people work alongside or interact with external parties.
- Evidence that you acted on your risk assessment. A completed form that led to no changes will not stand up if a claim is brought.
That final point is where I see businesses fall down most often. The risk assessment gets done as a tick-box exercise, filed away, and forgotten. If nothing changes as a result of it, it won’t protect you.
The financial cost of getting it wrong
Tribunals already have the power to add a 25% uplift to compensation awards where an employer hasn’t met the preventative duty.
That uplift is applied on top of the original award. So if the underlying claim is substantial, the additional penalty can be very significant.
It’s a real financial risk, and one that’s entirely avoidable with the right preparation.
Questions to ask yourself before October
Take a few minutes and honestly consider where your business stands on these points:
- Does your current policy specifically address harassment from third parties like clients or contractors?
- Could you produce records showing that your team has read and acknowledged your harassment policy?
- Have your managers received proper training on how to handle a harassment report?
- If a claim landed on your desk tomorrow, could you gather all of your evidence quickly and confidently?
If you’re unsure on any of those, there’s work to be done before the October deadline.
How we can help you get ready
We run sexual harassment prevention audits designed to measure where your business currently sits against the “all reasonable steps” standard. The audit reviews your existing policy, your reporting processes, and your exposure in situations where staff interact with people outside your organisation.
As part of our HR consultancy services in Ipswich, we also deliver practical manager training so that your team knows exactly how to respond when a report is made. Getting the initial response right matters enormously, both for the person involved and for your legal position.
Let’s have a conversation
October 2026 will come around quickly.
If you’d like to understand where your business stands and what steps you need to take, we’re happy to talk it through with you.
As an outsourced HR consultant in Ipswich, we work with businesses like yours every day to make sure the right protections are in place, without overcomplicating things.
Get in touch to book a discovery call. We’ll look at your situation and help you put a clear plan together.
