UK employers must now take "all reasonable steps" to stop harassment — and clients count

From 30 October 2026, employers must take "all reasonable steps" to prevent sexual harassment of their staff, and must not permit staff to be harassed by third parties such as clients and customers. The UK government's employment-changes guidance, updated on 2 November, sets out both duties. The Equality and Human Rights Commission published an updated 8-step guide for employers on 30 October, and Acas updated its guidance the same day.

"The first hour after someone discloses harassment to a manager is where trust is built or lost," said Nick Henderson-Mayo, Head of Compliance at VinciWorks, which polled 985 UK HR and compliance professionals in July 2026. "If that manager is not equipped for the moment, then neither is the business standing behind them."

The numbers, and the caveat

That poll found the training layer thin: only 30% give managers dedicated training on handling a disclosure, 32% fold it into general staff sessions and 21% give managers none at all. 34% have never run a harassment risk assessment and another 17% last did so more than a year ago. Fourteen per cent provide no harassment training whatsoever, and 47% describe what they have as needing improvement. Only 8% had made significant changes before the deadline; 45% had made none.

The caveat: the survey predates 30 October, and there is still no statutory checklist of steps. Acas states there is "no set list of steps that all employers must take", so what counts as reasonable will be judged case by case. Training is one step, not the defence: the Employment Appeal Tribunal upheld a finding that harassment training had gone stale (Allay (UK) Ltd v Gehlen, 2021). Where a harassment claim succeeds and the duty was breached, compensation can rise by up to 25%.

What changed beyond training

"Third party" covers clients and customers, among others. The duty covers all types of harassment under the Equality Act 2010, not only sex. The sectors most exposed are those where workers regularly deal with the public: retail, hospitality, care services, professional services and transport. A related change raises the stakes: since 1 October 2026 most employment tribunal claims can be filed within six months instead of three (breach-of-contract claims excluded).

What this means for L&D teams

The standard has moved from compliance to evidence: not "we assigned a module" but "here is the risk we identified, the session we ran, who attended and how we reviewed it". That makes the delivery format part of the argument: live, role-specific sessions with a record behind them, refreshed on a cycle you can point to.

This week

• Rebuild the session around your own risk assessment: client-facing roles, lone working, travel and overnight stays, events where alcohol is served.
• Give managers their own session, separate from the all-staff one: recognising a disclosure, responding, documenting.
• Fix the records: who attended, when, what was asked, and the date of the next refresh.

Training is now evidence: run it live, keep the record

The new standard asks L&D teams to show who was trained, when and what changed, not that a module was assigned. vcity hosts those sessions as live webinars, on a web page or in an immersive 3D room. It is not a compliance tool and gives no legal guarantee; it is where the training happens.

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Stay ahead: one short read like this, about two minutes, whenever a rule changes how you train.

Sources

• GOV.UK / business.gov.uk: workplace sexual harassment and third-party harassment (primary: government guidance, updated 2 Nov 2026; both duties from 30 Oct 2026; EHRC 8-step guide published 30 Oct)
• Acas: steps for employers to prevent sexual harassment (primary: updated 30 Oct 2026; "no set list of steps"; training and risk assessment)
• VinciWorks: all reasonable steps (harassment) (survey: 985 UK HR and compliance professionals, July 2026; all survey figures and the quote)
• Skadden: UK employment flash, new harassment prevention duties (coverage: six-month tribunal limit from 1 Oct 2026; up to 25% compensation uplift)
• TLT: October 2026 harassment reforms (coverage: exposed sectors, training evidence)
• Blake Morgan: EAT upholds finding that harassment training was stale (case: Allay (UK) Ltd v Gehlen, EAT 2021)