The Employment Rights Act 2025: four dates down, three to go.

What changes are already in place?

Four commencement dates have already passed, and each one is easy to have missed if you weren’t watching closely.

18 December 2025: the Act received Royal Assent, and a handful of changes took effect immediately. Minimum service levels for strikes were abolished, the repeal of most of the Trade Union Act 2016 began, and the notice period for industrial action dropped from 14 days to 10.

18 February 2026: dismissal for taking part in industrial action became automatically unfair, ballot and notice requirements for trade unions were simplified, and employees became able to give notice for the day-one paternity and unpaid parental leave rights that then took effect in April.

6-7 April 2026: the single busiest date so far. On 6 April, statutory sick pay became payable from Day 1 and the lower earnings limit was scrapped, paternity leave and unpaid parental leave became day-one rights, the collective redundancy protective award doubled from 90 to 180 days, whistleblowing protection was extended to cover sexual harassment disclosures, and a new duty began requiring employers to keep holiday pay and annual leave records for six years, the dullest item on the list and probably the one that will trip most people up, because six years of records is a systems job rather than a policy one. The following day, 7 April, the Fair Work Agency launched, consolidating the Employment Agency Standards Inspectorate, the Gangmasters and Labour Abuse Authority, and HMRC’s National Minimum Wage enforcement into a single body, and enforcing holiday pay for the first time.

25 August 2026: trade unions gained the right to run statutory ballots, including industrial action ballots, electronically and in the workplace. Equivalent provisions for recognition and derecognition ballots don’t follow until 2027. It sounds purely administrative. It isn’t. Electronic balloting makes industrial action ballots faster to run, cheaper to run, and considerably easier to get over the turnout threshold.

If you haven’t reviewed your record-keeping, whistleblowing policy or redundancy processes against these changes yet, you’re already behind.

What’s landing between now and January?

Three more dates fall over the next four months. These are the ones to plan around:

1 October 2026

The time limit for bringing Employment Tribunal claims extends from three to six months. That covers every claim type except breach of contract, and only applies where the relevant date falls on or after 1 October. Doubling the window doubles the tail. Every difficult decision you take from October onwards stays live twice as long, so the file you expected to close in January stays open until April. A new duty to consult workers before setting a tipping policy is also expected around this point, though the exact date isn’t yet confirmed; some sources point to later in 2026.

30 October 2026

The sexual harassment duty is the headline here, and it is not a new one. Employers have been required to take reasonable steps to prevent sexual harassment since October 2024; from 30 October 2026 the standard is raised to “all reasonable steps”, and employers also become liable for harassment of their staff by third parties such as customers or clients. This is the one that needs the most work done before the date rather than after it. Risk assessments, updated policies and staff training should all be finished by 30 October. Having them booked in for November will be too late. Trade union access rights also expand around this point.

1 January 2027

The date most employers have circled. The unfair dismissal qualifying period drops from two years to six months, the statutory cap on compensatory awards is removed entirely, and new restrictions on fire-and-rehire practices take effect. Dismissing an employee for refusing a contract variation becomes automatically unfair, and the restriction reaches well beyond pay: pensions, hours and shift patterns are all caught. The only route through is a narrow exemption turning on whether the variation was unavoidable: the employer must show it was responding to financial difficulties affecting its ability to carry on the business as a going concern. The point that catches people out is this: anyone hired on or before 1 July 2026 will already have six months’ service by 1 January, and gains full unfair dismissal protection on day one of the new regime. If you’ve carried on hiring at a normal pace since last summer, the exposure is already sitting in your current workforce,

What’s still to come:

Then a second wave lands through 2027, and the government still hasn’t pinned dates on most of it: restrictions on zero-hours contracts, a right to reasonable notice of shift changes, mandatory gender pay gap and menopause action plans for larger employers, a new right to bereavement leave, changes to collective redundancy consultation thresholds, regulation of umbrella companies, and new restrictions on the use of NDAs. Separately, the first Fair Pay Agreement negotiations for adult social care are due to open in April 2027, in England, with the first agreement expected by April 2028.

Three of those are worth pulling out of the list, because they change day-to-day practice rather than paperwork. Flexible working moves from a process test to a substantive one: a request can be refused only on one of the existing statutory grounds and only where the refusal is reasonable, with the employer required to state the ground relied on and explain why it applies. Pregnancy and family leave protection is enhanced, extending dismissal protection through pregnancy and for a defined period after return from maternity, adoption or shared parental leave, with dismissal in that window prohibited except in tightly drawn circumstances. And the blacklisting rules are widened, catching a broader range of lists and uses relating to trade union membership and activities.

Worth flagging: the majority of the Act does not extend to Northern Ireland, where employment law is devolved. If you operate across the UK, that’s a jurisdictional gap that needs its own answer, not a footnote.

Why the timeline keeps moving

In fairness, this roadmap has already been revised more than once since it was first published in July 2025, most recently in August 2026. The harassment duty moved back a month. Fire-and-rehire restrictions moved from October 2026 to January 2027. Electronic balloting slipped from April to August 2026. None of that means the reforms are stalling. The detail is still being settled through consultation, so if you’re building a compliance timeline around the current dates, hold it loosely.

So where do you start?

Not every business needs to act on every date at once. The right starting point depends on what you’re most exposed to: how many people you’ve hired recently, whether you’re in a sector where third-party harassment risk is real, how your current policies handle tips, records and whistleblowing. That’s the conversation worth having now, while there’s still time to do it properly.

Acuity Law’s Employment team is tracking every stage of this rollout. If you’d like to work out what it means for your business rather than for employers in general, get in touch.

This article is for general guidance only and does not constitute legal advice. Correct as at 1 September 2026, based on the Government’s published implementation roadmap. Several 2027 dates remain subject to secondary legislation and may change.