Several provisions of the Employment Rights Act 2025 are taking effect during October 2026. For healthcare employers, the immediate task is to establish what has changed and check whether existing policies remain accurate. The more difficult question is whether those policies are reflected in everyday working practices.
On 1 October, the time limit for bringing most Employment Tribunal claims increased from three to six months. For breach-of-contract claims, the change applies from 1 October in England and Wales and from 9 November in Scotland. Employers should therefore check policies and employee handbooks that still refer to the previous three-month period.
Further changes are scheduled for 30 October. Employers will be required to take “all reasonable steps”, rather than “reasonable steps”, to prevent sexual harassment. Employers could also be liable for harassment by third parties unless they have taken all reasonable steps to prevent it. The same date brings changes affecting trade union access, recognition and protections, although future implementation dates remain subject to parliamentary processes and may change.
What the changes mean for healthcare employers
The third-party provision is particularly relevant to healthcare organisations because workers regularly come into contact with people outside their direct employment relationship. This can include patients, relatives, visitors, contractors, consultants and other members of the public, with harassment potentially taking place in person or online.
That widens the practical question employers need to consider. A harassment policy may explain expected behaviour between colleagues, but it should also account for situations involving patients, service users and other third parties encountered through work. Workers need to know how to report those situations, while managers need to understand what should happen when a concern is raised.
The appropriate response will depend on the organisation’s size, working environment and type of services. Employers may need to assess the risks present in different settings, review policies, monitor incidents, provide suitable training and make sure staff understand how and where to raise concerns. The arrangements used in a large healthcare provider may differ considerably from those needed in a smaller organisation, so preparation should reflect how the organisation actually operates.
Employment-law changes are often treated as an HR matter once someone has joined an organisation. In practice, some of the relevant controls begin much earlier. Recruitment information helps establish what people should expect from a role and its working environment, while induction provides an opportunity to explain policies, reporting routes and required training. Managers then need enough information and preparation to respond consistently if an issue arises.
This does not mean turning every recruitment process into a legal briefing. It means checking that the expectations set during hiring are supported by the processes a new starter encounters afterwards. Someone joining the organisation should know the expected standards, how to recognise and report a concern, and where to go for support. Managers, team leaders and HR staff may require additional preparation so they can receive, record and escalate reports appropriately.
A policy change needs to work in practice
For healthcare employers, the review should extend beyond the staff handbook. Recruitment, induction, training, line management and reporting arrangements need to operate as one connected process.
Employers should check that policies use the correct Employment Tribunal time limits and that harassment policies address interactions with third parties. It is also worth reviewing whether different working environments have been considered when assessing risk, whether workers have clear ways to raise concerns, whether relevant expectations are covered during induction and whether managers understand how reports should be handled.
Not every possible preventative measure will be reasonable for every employer. Available resources, organisational size and the nature of the work all matter. The important point is that decisions should follow a considered review of the organisation’s actual risks and working arrangements, rather than relying on a general policy that may not reflect what happens in practice.
Updating a document is necessary where the law or guidance has changed, but it does not by itself show that workers understand what to do, managers can respond properly or risks involving third parties have been considered.
The practical test is whether someone joining the organisation can understand the expected standards, complete the relevant training, identify a concern and know how to report it. The corresponding test for managers is whether they know what to do when that report arrives.
For healthcare employers reviewing the October changes, that may be the most useful place to start.