Two dates in October are about to reshape how much legal exposure UK employers carry, and both are close enough now that “get to it later” is no longer a safe plan. The Employment Rights Act’s staged rollout reaches its next major milestone on 1 October, with a second batch of changes landing on 30 October, and neither one is a distant 2027 problem like the headline unfair dismissal reforms. These are weeks away.
What changes on 1 October
The time limit for bringing most employment tribunal claims doubles, from three months to six, for any claim where the underlying incident happens on or after 1 October 2026. That sounds like a technical procedural tweak, but it has a real practical effect: employees now have twice as long to decide whether to bring a claim, which means disputes that might previously have quietly expired after three months stay live for twice as long. For employers, that makes the habit of documenting incidents, disciplinary conversations, and dismissal reasons properly at the time even more important, because you may need to defend a decision made six months earlier rather than three.
What changes on 30 October
Three weeks later, harassment obligations tighten in ways that affect almost every employer with customer-facing or public-facing staff. The existing duty to take “reasonable steps” to prevent sexual harassment becomes a duty to take “all reasonable steps”, a noticeably higher bar that will be judged on whether you can show a genuine, documented effort, not just a policy sitting unread in a staff handbook. Alongside that, the duty to protect staff from harassment by third parties, customers, clients, members of the public, expands beyond sexual harassment to cover other protected characteristics as well, such as race, disability, and religion.
For a retail, hospitality, or customer service business, this means a customer being abusive towards a staff member because of their race or disability now falls under the same employer duty as sexual harassment already does. Government guidance defining exactly what “all reasonable steps” looks like in practice is still to follow, but waiting for that guidance before acting is a risk in itself, since the duty applies from 30 October regardless.
What to actually do before these dates
Three practical steps cover both changes. First, review and refresh your harassment risk assessment now: identify where staff face the most contact with customers or the public, and document what you’re doing to reduce risk there, not just what your policy says in theory. Second, update your incident documentation habits ahead of the tribunal time-limit change, since claims tied to incidents from October onward will need to be defensible six months later, not three. Third, make sure your staff handbook and contracts reflect both changes rather than referencing the old three-month limit or the narrower “reasonable steps” standard.
If your employment contracts and policies haven’t been refreshed in a while, this is a natural trigger point to do it properly rather than patching individual clauses as each new law lands. A service like Smallprint can help keep template contracts and staff handbooks current, so that when the next Employment Rights Act milestone arrives, you’re updating an existing, well-organised set of documents rather than starting from scratch under time pressure.
The takeaway
1 October and 30 October bring a longer tribunal window and a genuinely higher harassment-prevention bar. Refresh your harassment risk assessment, tighten your incident documentation, and update your contracts and policies before the month is out, not after a claim lands on your desk. Neither change requires new legislation to be passed or new guidance to be published first, both apply automatically on their commencement date, so “waiting to see what the guidance says” is not a safe reason to delay the basic preparation.
