New sexual harassment duties are coming

October 2026 will raise the bar for workplace prevention

From 30 October 2026, employers will face stronger responsibilities to prevent sexual harassment in the workplace.

Since October 2024, organisations have been under a proactive duty to take reasonable steps to prevent sexual harassment. From the end of October 2026, that expectation increases to taking all reasonable steps. Employers will also need to consider harassment involving third parties, including customers, clients, suppliers, contractors and members of the public.

For business owners, this means prevention needs to become part of everyday people management.

Responding appropriately after a complaint will remain important, but employers increasingly need to show what they did before an incident occurred.

Prevention needs to be practical, not just written down

Many businesses already include wording on harassment somewhere in their handbook or equality policy. That is useful, but it is unlikely to be enough on its own.

A stronger preventative approach means looking at how the organisation actually operates. Employers should consider where inappropriate behaviour could arise, whether employees know how to raise concerns, and whether managers understand how to respond if someone approaches them.

The key question is no longer simply:

“Do we have a policy?”

It is:

“Can we demonstrate the steps we have taken to prevent sexual harassment?”

That distinction is important.

Understand where your workplace risks sit

Every organisation will have a different risk profile. For one business, the main risk could arise from customer-facing employees dealing with members of the public. In another, it could involve business travel, networking events, conferences or social occasions where alcohol is present.

Employers should also consider power imbalances between senior and junior employees, lone working, online messaging platforms and environments where inappropriate comments have historically been dismissed as workplace “banter”.

The aim is not to assume that something will go wrong. It is to think realistically about where risks could arise and what reasonable safeguards can be introduced.

A documented risk assessment can help employers identify those areas and decide what preventative measures are appropriate.

Third-party behaviour can no longer be ignored

One of the particularly significant aspects of the October changes is the increased focus on third-party harassment.

Employees can encounter inappropriate behaviour from people who are not employed by the organisation at all.

That could be a customer making sexual comments to an employee, a client repeatedly behaving inappropriately during meetings, or a supplier crossing professional boundaries.

Businesses will need to think carefully about how these situations are handled. Employees should know that they are not expected to tolerate inappropriate behaviour simply because somebody is a valuable customer or commercial contact. Managers also need to understand what action they are authorised to take when a third party behaves inappropriately and when concerns should be escalated.

Managers will play a critical role

Formal complaints are often not how concerns first appear.

Instead, a manager might hear:

“Can I have a quick word about something that happened?”

That first conversation matters enormously.

Managers need to know how to listen, take the concern seriously and avoid immediately dismissing behaviour as humour, flirting or personality differences.

They should also understand when a concern needs escalating, how confidentiality should be handled and why they should never make promises that information can remain completely confidential before understanding what has happened.

The way a manager responds can determine whether an employee feels confident continuing to speak up.

Training should reflect real workplace situations

Training will form an important part of many employers’ preventative approach. But meaningful training should go beyond asking people to read a policy or complete an online module once. Employees need practical examples of what sexual harassment can look like. That might include inappropriate comments, messages, jokes, unwanted attention, behaviour at social events or conduct involving customers and clients. People should understand the boundaries expected within the workplace, how they can challenge inappropriate behaviour and how they can raise concerns.

Managers need additional training so that they understand their responsibilities when somebody reports an issue and can respond appropriately without creating further risk. Regular refresher training can also help demonstrate that prevention is an ongoing commitment rather than a one-off exercise.

Do not overlook the April 2026 whistleblowing change

There is another important development employers need to keep in mind. Since 6 April 2026, certain disclosures about sexual harassment can qualify for whistleblowing protection. That makes it even more important for employers to create safe reporting routes and ensure concerns are handled appropriately.

Employees should not feel discouraged from raising an issue or believe that speaking up could damage their position within the organisation. Managers therefore need to understand not only harassment procedures but also the potential risks of victimisation or detrimental treatment after a concern has been raised.

Policies need to reflect what happens in the real world

A strong sexual harassment policy should do more than say that harassment will not be tolerated. It should explain what inappropriate behaviour can look like, how employees can report concerns and what will happen after an issue is raised. There should also be alternative reporting routes where the employee’s usual manager is involved.

Third-party behaviour should be addressed clearly too, so employees understand that the same standards of respect apply when they are dealing with customers, suppliers and other external contacts.

Most importantly, the policy needs to be communicated. A document that was emailed to employees several years ago and never discussed again is unlikely to create meaningful awareness.

Culture still matters

Legal compliance is important, but culture ultimately determines whether employees feel confident speaking up.

If managers regularly dismiss inappropriate comments, senior leaders fail to model respectful behaviour or employees believe raising concerns will affect their careers, written policies will have limited impact.

Employers need to create an environment where respectful conduct is consistently expected. That may mean challenging behaviour from a high performer, a senior employee or an important customer. Those moments are often what demonstrate whether the organisation’s stated values are genuine.

What should employers be doing now?

With the October changes approaching, businesses should use the remaining time to review their current position.

Start by checking whether your policies are up to date and whether employees actually understand them. Consider when sexual harassment risks were last reviewed and whether third-party interactions have been properly included. Managers should receive practical guidance and training, while employees need clear information about expected behaviour and reporting routes. It is also worth keeping records of the steps the business takes. Risk assessments, training attendance, policy communications and actions arising from employee feedback can all help demonstrate a proactive approach. Waiting until a complaint arises is a much riskier strategy than preparing now.

How Haus of HR can support your business

At Haus of HR, we help SMEs translate employment law changes into practical actions that work for their business.

We can review or develop your Sexual Harassment Prevention, Dignity at Work and Equality policies, ensuring they reflect the stronger preventative duties and the increased focus on third-party harassment.

We can also support implementation, including workplace risk assessments, reporting processes, manager guidance and communications for employees.

Alongside policy development, Haus of HR delivers practical sexual harassment prevention training for employees and managers.

Our sessions focus on real workplace situations, helping employees understand boundaries and expected behaviour while giving managers the confidence to respond appropriately when concerns are raised.

Prepare before the law changes

The October 2026 changes should not simply be viewed as another policy update. They are an opportunity to check whether your organisation can genuinely demonstrate that it is taking sexual harassment prevention seriously. The businesses best prepared will be those that understand their risks, train their people, equip their managers and make expectations around respectful behaviour clear.

If your organisation needs support reviewing its current approach, developing or updating policies or delivering sexual harassment prevention training, Haus of HR can help you prepare for the changes ahead.

Get in touch with Haus of HR for your free HR consultation.

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