22.07.2026
Before October 2024, it was all about reacting
Prior to October 2024, sexual harassment was unlawful under the Equality Act 2010. Employers could be held liable for harassment carried out by employees, but the legal focus was largely on what an organisation did after an incident occurred, which increased reliance on policy and grievance procedures.
October 2024 saw a major shift – It is now about being proactive
On 26 October 2024 when the Worker Protection (Amendment of Equality Act 2010) Act 2023 came into force, employers became subject to a new legal duty to take reasonable steps to prevent sexual harassment before it happens within the workplace; to include third parties, such as customers, suppliers, contractors and visitors.
What we have seen over the last two years
The biggest change has been cultural rather than procedural. Employers have increasingly focused on:
- Sexual harassment risk assessments.
- More robust reporting mechanisms.
- Manager and employee training.
- Regular policy reviews.
- Greater attention to workplace culture and behaviours.
- Monitoring risks at social events, customer sites and off-site activities
What happens next?
Further reforms under the Employment Rights Act 2025 are increasing expectations even further.
Since April 2026, disclosures relating to sexual harassment have gained additional protection through whistleblowing reforms.
Looking ahead to October 2026, employers will be expected to take "all reasonable steps" to prevent sexual harassment, raising the legal bar beyond the current requirement to take "reasonable steps" and employers are also expected to face wider liability for third-party harassment.
All reasonable steps
The steps specified in regulations will include (but will not be limited to):
• Carrying out assessments of a specified description (likely to cover risk assessments).
• Publishing plans or policies of a specified description (likely to cover action plans and sexual harassment policies).
• Steps relating to the reporting of sexual harassment.
• Steps relating to the handling of complaints.
Two years on, the message is clear
Preventing sexual harassment is no longer just an HR issue or a policy requirement. It is a fundamental part of workplace culture, leadership and risk management. Organisations that invest in prevention, training and culture are not only reducing legal risk but creating safer, more inclusive workplaces where people can thrive.