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GB EMPLOYMENT LAW CHANGES: KEY MEASURES COMING INTO FORCE 2025–2027

The Government in Great Britain has now clarified the implementation dates for a wide range of employment law changes due to come into force over the next two years.  These have been set out in a Policy Paper entitled “Plan to Make Work Pay and Employment Rights Act: timeline update”.

Position in Northern Ireland

Note that these changes apply to Great Britain only (with the exception of changes to Statutory Sick Pay and the establishment of the Fair Work Agency which do extend to Northern Ireland). Employment law in Northern Ireland is devolved, and the Executive has not yet published the draft Employment Rights/ Good Jobs Bill (“the Bill”). The expected date for publication of the Bill has now been moved to April 2026.

Many of the proposals in Northern Ireland mirror the developments in Great Britain and are largely focused on bringing Northern Ireland up to the current GB position, rather than going further. However, only in Northern Ireland will changes to legislation for miscarriage leave and pay and domestic abuse leave will apply. It is likely that Northern Ireland will also have different mechanism for zero hour contracts to Great Britain.

It is also worth noting that Northern Ireland never implemented the Trade Union Act 2016, meaning that Great Britain’s forthcoming repeal of most of that Act will, in some respects, bring GB back into closer alignment with the existing Northern Ireland position.

As both jurisdictions move forward with their respective reform programmes, employers operating across the UK will need to keep a close eye on the differing timelines and requirements. We will continue to keep businesses up to date as this area develops.

GB Implementation Dates

  1. Measures that took effect at Royal Assent, December 2025:
  • Repeal of the Strikes (Minimum Service Levels) Act 2023.
  1. Measures that will take effect on 18 February 2026:
  • Repeal of a large majority of the Trade Union Act 2016, simplifying requirements on trade unions, including in relation to industrial action and political funds.
  • Removal of the 10‑year ballot requirement for trade union political funds.
  • Simplification of industrial action notices and industrial action ballot notices.
  • Strengthened protections against dismissal for taking industrial action.
  • Employees newly eligible for Day 1 Paternity Leave and Unpaid Parental Leave can give notice.
  1. Measures that will take effect on 6 April 2026:
  • Collective redundancy protective award: doubling of the maximum protective award period.
  • Day 1 Paternity Leave and Unpaid Parental Leave.
  • Strengthened whistleblowing protections for workers who disclose sexual harassment.
  • Bereaved Partners’ Paternity Leave (non‑MWP measure), enabling bereaved fathers and partners to take up to 52 weeks of paternity leave if the mother or primary adopter dies within the first year.
  • Statutory Sick Pay (SSP): removal of the Lower Earnings Limit and waiting period (also applicable in Northern Ireland).
  • Voluntary action plans on gender equality and supporting employees through the menopause.
  • Menopause guidance.
  • Simplification of the trade union recognition process.
  1. Measures that will take effect on 7 April 2026:
  • Establishment of the Fair Work Agency (also will be applicable in Northern Ireland).
  1. Measures that will take effect no earlier than August 2026:
  • Introduction of electronic and workplace balloting for statutory trade union ballots.
  1. Measures that will take effect in October 2026:
  • Regulations establishing the Fair Pay Agreement Adult Social Care Negotiating Body in England.
  • Procurement two‑tier code.
  • Tightening of legislation in relation to tipping.
  • Duty to inform workers of their right to join a trade union.
  • Strengthening of trade unions’ right of access.
  • Requirement for employers to take “all reasonable steps” to prevent sexual harassment.
  • New obligation on employers not to permit harassment of employees by third parties.
  • Power to specify steps regarded as “reasonable” in determining whether an employer has taken all reasonable steps to prevent sexual harassment.
  • Measures addressing unfair practices in the trade union recognition process.
  • New rights and protections for trade union representatives.
  • Extension of protections against detriment for taking industrial action.
  1. Measures that will take effect no earlier than October 2026
  • Changes to employment tribunal time limits.
  1. Measures that will take effect in December 2026
  • Commencement of the Mandatory Seafarers’ Charter.
  1. Measures that will take effect in January 2027
  • Reduction of the unfair dismissal qualifying period to six months (for dismissals from 1 January 2027).
  • Uncapping of compensatory awards.
  • Strengthened fire and rehire protections.

COMMENTARY

Our sister Organisation MAKE UK has highlighted that the following are the changes between the original proposed dates and these updated dates:

  • Menopause guidance will be introduced in April 2026.
  • E-balloting and workplace balloting for statutory ballots will be introduced in August 2026 (instead of in April).  E-balloting and workplace balloting for recognition and derecognition ballots will follow in 2027.
  • Changes to employment tribunal time limits will take effect in October 2026.
  • Changes to the rules around fire and rehire (and fire and replace) will be introduced from January 2027 (instead of October 2026).

These revisions are in addition to the recently announced implementation date of 1 January 2027 for the UK Government’s changes to unfair dismissal rules (i.e. the reduction to six months of the qualifying period for ordinary unfair dismissal, and the removal of the statutory cap on the maximum unfair dismissal compensation).