Employers Federation May June 2026 Public Training Events 1

As we close out the first quarter of 2026, several noteworthy legislative and regulatory changes have already taken effect, with more anticipated as the year progresses. Below is a summary of the main updates that Members should note.

LEGISLATIVE UPDATES 

Pension Auto Enrolment

From 1 January 2026, Ireland’s new Pension Auto‑Enrolment scheme (My Future Fund) officially launched. Eligible employees aged 23–60, earning €20,000+ and without an existing workplace pension were automatically enrolled.

Initial contributions started at 1.5% from employees, matched by 1.5% from employers, with an additional 0.5% State top‑up. The scheme is centrally administered by the National Automatic Enrolment Retirement Savings Authority (NAERSA) and is designed to improve retirement savings alongside the State Pension.

Employees must remain in the scheme for six months before they can opt out, with contribution rates set to increase gradually over time.

Employers who already operated a qualifying workplace pension before January 2026 were not required to auto‑enrol those members into My Future Fund.

• Employees actively contributing to an existing scheme were excluded from auto‑enrolment
• Existing schemes had to meet minimum contribution standards(including an employer contribution)
• Employers needed to assess their workforce, identifying which employees were covered and which were not
• Employees not in the existing scheme (or not eligible to join it) were auto‑enrolled into My Future Fund

As a result, many employers now operate dual arrangements: an existing pension scheme for some employees, alongside My Future Fund for others.

National Minimum Wage

From 1 January 2026, the National Minimum Wage increased to €14.15. This change signals the Government’s ongoing intention to move towards a living wage, and it carries immediate implications for both costs and compliance across all employers.

Employment Permit Salary Thresholds

Effective 1 March 2026, minimum salary thresholds for employment permits have risen. General Employment Permits now require a minimum salary of €36,605 (up from €34,000), while Critical Skills Employment Permits demand €40,904 (previously €38,000).

Remote Working

The Government’s public consultation on remote working closed on 9 December 2025, drawing over 8,000 submissions—primarily from employees. The statutory review that followed confirmed a 94% approval rate for employee requests (either in full or in part) and found the legislation is functioning well, contrary to some media reports. Employers report a manageable administrative burden, but the review highlighted low awareness and uptake, especially in rural areas. To address this, the Government will launch a targeted national awareness campaign. The Workplace Relations Commission has also been asked to revise and strengthen the Code of Practice, providing clearer guidance and practical templates. No legislative amendments are planned at this stage.

Employment (Contractual Retirement Ages) Act 2025

The Employment (Contractual Retirement Ages) Act 2025 will, when enacted, enable employees to formally notify their employer that they do not consent to retire at the contractual retirement age if it is below the State Pension Age (66).

The Act was signed into law on 16 December 2025. No commencement date has been set. It will only come into force once the government issues a commencement order. A Code of Practice is expected, and commencement is anticipated after its publication.

Employees will be entitled to notify their employer if they do not consent to retire at a contractual retirement age below 66, with employers required to objectively justify any lower retirement age and issue a reasoned written response within one month, failing which claims may arise before the Workplace Relations Commission and, in some cases, criminal penalties may apply.

Employers should prepare for new notification-handling procedures for employees wishing to work until 66, ensure they can objectively justify any contractual retirement age below 66, and update policies, contracts, and HR processes ahead of the Act’s commencement.

 Pay Transparency Directive

The Government has acknowledged that Ireland will miss the 7 June 2026 deadline for implementing the EU Pay Transparency Directive, opting for phased implementation instead.

The Department of Children, Equality, Disability, Integration and Youth has clarified that employers won’t be penalised for not having all elements in place by June. The General Scheme of the Equality (Miscellaneous Provisions) Bill 2024, published in January 2025, covers several recruitment-related aspects, such as salary ranges in job advertisements and restrictions on pay history questions. Further legislation will address outstanding obligations, including gender pay gap reporting. Meanwhile, the European Commission has issued updated guidance on gender-neutral job evaluation and classification to help employers prepare for future compliance.

Code of Practice on Access to Part-Time Working (2026)

On 22 January 2026, the Government approved a refreshed Code of Practice on Access to Part-Time Working, replacing the previous version. The updated WRC Code doesn’t create new legal duties but reinforces best practice for handling part-time work requests. It encourages consideration of part-time arrangements at all organisational levels—including senior roles—strengthens protections against penalisation, and underscores the importance of accommodating parents’, carers’ and employees’ medical needs. Employers should proactively assess whether roles can be performed on a part-time basis.

These updates highlight the need for ongoing review of policies, pay structures, and working practices throughout 2026.

CASE LAW UPDATE

1. SK Biotek Ireland Ltd v Shannon Reina (SLD262)– Operation of Statutory Sick Pay 

Background 

The Complainant, a Quality Control Analyst at SK Biotek, worked from August 2023 until her resignation in July 2024. She had several certified sickness absences, including COVID-19 and a work-related injury. SK Biotek operated an internal sick pay scheme whereby after a six-month qualifying period, employees could receive full pay for up to four weeks per year, plus 50% for a further four weeks, subject to compliance with their Absence Management Policy. The Complainant received a verbal warning due to the level of absence and became disentitled to company sick pay.

In May 2024, the Complainant applied for sick pay again and was refused under the company scheme. She then lodged a claim with the Workplace Relations Commission (WRC) under the Sick Leave Act 2022, contending that she was entitled to statutory sick pay when she lost access to the company scheme.

WRC Decision

The adjudicator upheld the Complainant’s complaint. The AO found that she was entitled to statutory sick leave, despite the employer withholding sick pay under its own policy. The Respondent appealed to the Labour Court.

Labour Court Decision 

The Labour Court examined whether SK Biotek’s more generous internal scheme exempted it from statutory obligations under section 9(1) of the Sick Leave Act. The court confirmed that:

• Both parties agreed SK Biotek’s scheme was, as a whole, more favourable than statutory rights.
• Eligibility conditions or disciplinary disqualifications were not relevant to the exemption analysis.
• Section 9(1) provides an absolute exemption from statutory sick pay, even if the employee becomes ineligible due to disciplinary action.

The Labour Court overturned the WRC’s award and ruled that SK Biotek had no obligation to provide statutory sick pay, setting aside the €500 compensation.

Key Takeaways for Employers

This decision confirms that employers may lawfully apply conditions to their occupational sick pay schemes. Where an employee does not qualify for company sick pay, there is no obligation to pay statutory sick leave provided the company scheme is exempt under section 9 of the Sick Leave Act. While the outcome may be viewed as harsh (particularly given that the complainant’s absences were certified and gen) it aligns squarely with the statutory framework. The Act makes clear that contractual sick pay and statutory sick pay do not operate in parallel; entitlement is to one or the other. As the Labour Court stated, section 9 “admits of no exceptions to this exemption and does not confer any discretion on this Court to imply any such exception into it.”

1. Mick Kiely v Hyph Ireland Ltd (ADJ-00037708) – Constructive Unfair Dismissal. 

In a landmark decision, the Workplace Relations Commission (WRC) has made the highest unfair dismissal award in its history, granting compensation of approximately €464,000 to a former senior executive.

Background 

The Complainant , Mr Mick Kiely, the founder, CEO and chairperson of Hyph Ireland Ltd (formerly Xhail Ireland Ltd), was dismissed in November 2021 without notice or any disciplinary or dismissal procedure. His employment was terminated abruptly by email, and he was immediately locked out of company systems.

WRC Decision

The WRC found that the employer had failed entirely to follow fair procedures, amounting to a clear breach of the Unfair Dismissals Acts. The adjudication officer rejected the employer’s justification for the dismissal and accepted that Mr Kiely had been denied basic procedural fairness.

In assessing compensation, the WRC placed significant weight on:

• Mr Kiely’s senior executive role and high remuneration
• The absence of any warning or due process
• A restrictive non‑compete clause, which substantially limited his ability to mitigate his losses by obtaining alternative employment

The WRC awarded €440,000 for loss of earnings, and €24,000 in pay in lieu of notice, bringing the total award to €464,000.

The case has attracted considerable attention as it illustrates the potential scale of exposure for employers, particularly where senior employees are dismissed without due process. It also serves as a stark reminder that failures in procedure alone can justify substantial compensation, even where an employer believes there were substantive grounds for dismissal.

3. O ‘Connell v National Council for Special Education (ADJ‑00042837) – Disability Discrimination, WRC Lifts Statutory Cap in Non- Appointment Case

In a recent Workplace Relations Commission (WRC) decision, Noel O’Connell v National Council for Special Education (ADJ‑00042837), the WRC found that the National Council for Special Education (NCSE) had indirectly discriminated against a deaf applicant in a recruitment process. The case is particularly noteworthy as the Adjudication Officer disapplied the statutory €13,000 compensation cap for access‑to‑employment discrimination claims, instead awarding €40,000 in compensation.

Background

In March 2022, the complainant—who is deaf and a native user of Irish Sign Language (ISL)—applied for the role of Advisor Deaf/Hard of Hearing (ISL) with the NCSE. Eligibility criteria included holding a formal ISL qualification and demonstrating excellent oral communication skills. As is common for native sign language users, the complainant did not hold a formal academic ISL qualification, and the application was rejected.

Following an internal review, the NCSE accepted that the complainant met the essential criteria for the role. However, the recruitment process for the role was not reopened and no remedy was offered.

Decision

The Adjudication Officer held that the NCSE’s requirements amounted to indirect discrimination and that the complaint was well founded. In considering redress, the Adjudication Officer examined section 82(4) of the Employment Equality Act 1998, which caps compensation at €13,000 in access‑to‑employment cases.

The Complainant successfully argued that this cap conflicted with EU law—specifically Article 17 of Directive 2000/78, which requires sanctions to be effective, proportionate and dissuasive. Reliance was also placed on Case C‑378/17 (Minister for Justice and Equality v Workplace Relations Commission), where the CJEU confirmed that bodies such as the WRC must disapply national provisions that are incompatible with EU law.

Applying these principles, the Adjudication Officer disapplied the national compensation cap and awarded €40,000.

Key takeaway for employers

This decision signals a clear willingness by the WRC to set aside domestic compensation limits where they fall short of EU law requirements. Employers should be prepared for robust challenges to the €13,000 cap in access‑to‑employment discrimination claims and, potentially, arguments seeking to disapply other statutory compensation caps where more effective and dissuasive remedies are deemed necessary.

Employers Federation Northern Ireland is celebrating 160 years of supporting employers across Northern Ireland, building on a long tradition of advice, representation and practical help for businesses and organisations.

The Federation was originally formed in May 1866 as the Belfast Engineers, Shipbuilders, Founders and Machine Makers’ Association. It was established by some of Belfast’s leading industrial employers at the time, including Harland and Wolff, to share information, provide mutual support and respond to employment relations challenges.

The milestone year also comes at a time of change for the Federation. It comes following the unexpected death of Peter Bloch, who led the organisation with commitment, integrity and deep care for members and staff for 35 years. Under Peter’s leadership, Employer Federation strengthened its legal support for employers—helping companies and organisations of all sizes, across every sector, to deal with complex and often sensitive workplace issues.

The Federation has now appointed its new Managing Director as Michelle McGinley. Michelle was previously Director of Legal & Policy and stepped into the role of Acting Managing Director following Peter’s death. She provided steady, thoughtful and highly effective leadership, ensuring continuity of service to members while supporting colleagues through significant change.  Michelle took up the role permanently in April 2026 and is the first female to hold the position in the Federation’s 160‑year history. She will work closely with Federation’s experienced team to build on the organisation’s values and continue delivering practical, trusted support for members.

Employers Federation will mark the 160^th anniversary throughout the year as we look forward to the future.

In discrimination claims, where a claim is successful, the Tribunal will assess compensation for the hurt, upset and humiliation caused by the discriminatory act(s).

These awards are known as Injury to Feelings awards, often referred to as Vento bands, following the case in which clear guidelines for assessing such compensation were established.

The Presidents of the Employment Tribunals in England and Wales and Scotland have now published their annual increases to Injury to Feelings awards in the 9th Addendum to the Presidential Guidance.

Although this Guidance does not formally apply in Northern Ireland, the updated bands are generally followed by the Industrial Tribunal and Fair Employment Tribunal.

NEW INJURY TO FEELINGS AWARD BANDS

Lower band

• £1,300 to £12,600

(previously £1,200 to £12,100)

Applies to less serious cases of discrimination.

Middle band

• £12,600 to £37,700

(previously £12,100 to £36,400)

Applies to cases that do not merit an upper band award.

Upper band

• £37,700 to £62,900

(previously £36,400 to £60,700)

Applies to the most serious cases of discrimination.

Exceptional cases

• Over £62,900

(previously over £60,700)

Reserved for the most exceptional circumstances.

When do the new bands apply?

The updated Injury to Feelings award bands apply to Tribunal claims presented on or after 6 April 2026.

The Employment Rights Act 2025 (Commencement No.3 and Transitional Provisions Regulations 2026 update both the Statutory Sick Pay (SSP) rules in Great Britain (GB) and Northern Ireland (N.I.)

What is changing?

The Regulations amend the bringing into effect of two major changes:

• Statutory Sick Pay (General) Regulations 1982 (GB)
• Statutory Sick Pay (General) Regulations (N.I.) 1982

1. Removal of Waiting Days

Employees will now be entitled to SSP from Day One of sickness absence, rather than Day Four.

2. 2. Removal of Lower Earnings Limit

Employees will no longer need to earn above the Lower Earnings Limit to qualify for SSP. This means all employees, including lower‑paid and part‑time workers, will be eligible.

For lower earners, SSP will be paid at 80% of normal weekly earnings or the standard SSP rate, whichever is lower.

COMMENCEMENT DATE

These changes take effect on 6 April 2026 and apply in both Great Britain and Northern Ireland from this date.

TRANSITIONAL PROVISIONS

The Government has published Guidance: Sickness absences that start before and end on or after 6 April 2026 and more technical guidance that can be accessed here SSP-Transitional-Protections-Guidance-published (003)

The transitional arrangements will apply where sickness absence began before 6 April 2026 and continues on or after that date.

• If an employee is serving waiting days under the old rules when 6 April 2026 arrives:
• Waiting days before 6 April 2026 remain unpaid.
• From 6 April 2026 onwards, waiting days no longer apply.
• SSP becomes payable from 6 April 2026, even if the absence began earlier.

There is no back‑payment for waiting days that fell before 6 April 2026.

2. Employees previously excluded due to low earnings (below the Lower Earnings Limit)

If an employee started their sickness absence before 6 April 2026 and was not entitled to SSP under the old rules, because they earned below the Lower Earnings Limit:

They may become entitled to SSP from 6 April 2026, provided:

• The sickness absence started on or after 22 September 2025, or
• The absence started earlier, but the employee returned to work at some point between 22 September 2025 and 5 April 2026 (so the absence is not continuous).

In these cases:

• SSP is payable from 6 April 2026.
• SSP is payable for up to 28 weeks, calculated using average weekly earnings before the sickness absence.

3. 3. Long‑running continuous absences that began before 22 September 2025

An employee will not become entitled to SSP from 6 April 2026 if:

• Their sickness absence started on or before 21 September 2025, and
• The absence continued without any break up to 5 April 2026, and
• The absence (or a linked absence) continues on or after 6 April 2026.

In these circumstances:

• The employee must return to work for at least 8 weeks before a new SSP entitlement can arise.

4. 4. Employees already receiving SSP before 6 April 2026

Where an employee is already entitled to SSP before 6 April 2026, and the new rules would otherwise result in a lower rate of SSP (for example, due to the move to 80% of earnings):

• The transitional protection applies.
• SSP will continue to be paid at the uprated flat rate for the remainder of that continuous period of sickness, until:
• the employee returns to work,
• the 28‑week SSP limit is reached, or
• SSP entitlement otherwise ends.

KEY TAKEAWAYS FOR EMPLOYERS

There will be no retrospective payment for waiting days that fell before 6 April 2026. Some employees who were previously excluded from Statutory Sick Pay may become entitled part‑way through an ongoing sickness absence once the new rules take effect. However, long‑running continuous absences that began before 22 September 2025 will remain excluded until the employee returns to work. Employers should therefore check entitlement carefully before paying SSP in transitional cases.

As members will be aware, every April, Government confirms the annual increase of statutory payments to take into account factors such as inflation, cost of livings on economies conditions.

However, this year, in addition to those usual increases, there are two further significant changes coming into effect in Northern Ireland from 6 April 2026 namely to:

• Statutory Sick Pay
• Statutory Parental Bereavement Leave and Pay

We have summarised the main changes coming into effect below and identified those that will apply across the UK.

Other employment law changes are coming into effect in Great Britain only under their Employment Rights Act 2025, unless we have stated otherwise, these will not apply to Northern Ireland. In Northern Ireland we are currently awaiting the publication of the Good Jobs Bill and will keep Members updated.

SUMMARY OF CHANGES IN APRIL 2026:

1. Effective from Monday 6 April 2026 Increase in Limits to the maximum weekly rate of pay used for example to calculate redundancy pay and unfair dismissal awards

• Maximum Weekly Pay

Northern Ireland will increase from £749 to £783

Great Britain will increase from £719 to £751.

• Maximum compensatory award

Northern Ireland will increase from £118,455 to £123,785

Great Britain will increase from £118,223 to £123,543*

*The cap will be completely abolished from 1 January 2027 in Great Britain only (See our previous article here)

2. Effective from 6 April 2026 uprating of benefits such as:

• Statutory Sick Pay

Increases from £118.75 to £123.25

• Statutory Maternity Pay and other family friendly pay

Increases from £187.18 to £194.32

3. Effective from 1 April 2026 increase to the:

National Minimum Wage

• For 18 – 20 year, an increase from £10.00 to £10.85.
• For 16 – 17 year and apprentices, increases from £7.55 to £8.00

National Living Wage:

• For 21 year and upwards, increases from £12.21 to £12.71.

(See our article here)

STATUTORY SICK PAY

4. Changes to SSP to include the removal of the 3-day waiting period, removal of the lower earnings limit and  making it a Day 1 right for all.

This change is expected to come into force from 6 April 2026 but we are still awaiting sight of the separate Commencement Orders required to bring it into effect in both Northern Ireland and Great Britain. We previously informed you of the changes and impact on internal policies (See our article here) and will continue to keep you informed.

All of the changes (1- 4) above will apply across Great Britain and Northern Ireland – the only difference being that the maximum weekly rate of pay and maximum compensatory in Northern Ireland have historically been slightly higher than the rates in Great Britain.

STATUTORY PARENTAL BEREAVEMENT RIGHTS

5. Effective Monday 6 April 2026 significant changes to Statutory Parental Bereavement Leave and Pay extending statutory protections for employees who experience the loss of a child and introducing a new entitlement relating to miscarriage.

We previously circulated to members an updated Template Policy compliant with those changes that can be accessed in our Member area here

This change to Statutory Parental Bereavement Leave and Pay only applies to employees in Northern Ireland.

We have explained this right further below

EXTENSION OF PARENTAL BEREAVEMENT RIGHTS

Statutory Parental Bereavement Leave and Pay currently applies where an employee suffers the loss of a child under the age of 18, including stillbirth from 24 weeks of pregnancy.

From 6 April 2026, this right will be expanded to include miscarriage, covering both spontaneous pregnancy loss and specified medical interventions.

New Miscarriage Entitlement

Employees who experience a miscarriage — or who have a qualifying relationship to a woman who has experienced a miscarriage — will now be eligible for Parental Bereavement Leave and Pay, subject to the statutory criteria.

This entitlement will apply where the miscarriage is discovered on or after 6 April 2026.

Evidence Requirements

As with existing Statutory Parental Bereavement Leave and Pay arrangements, no medical evidence will be required.

To qualify for Statutory Parental Bereavement Pay, the employee must provide a Written Self‑Declaration confirming that they meet the eligibility requirements. This declaration must include:

• the employee’s name; and
• the date on which the miscarriage occurred or was discovered.

Day‑One Right to Statutory Pay

From 6 April 2026, Statutory Parental Bereavement Pay will become a day‑one right.

This means there will be no minimum service requirement and no minimum earnings threshold.

Employees may rely on either their actual earnings or their expected earnings, based on reasonable assumptions.

Key Points for Employers

Where entitlement arose before 6 April 2026, the existing rules will continue to apply. Therefore, miscarriage entitlement is not retrospective and will not apply where the miscarriage occurred or was discovered before 6 April 2026.

All existing rights under Parental Bereavement Leave and Pay will apply in full to miscarriage cases where eligibility arises on or after 6 April 2026.

Further Guidance

The Labour Relations Agency has published a webinar which is to help HR professionals, managers, understand how these new rights apply in practice. The LRA has said they will update their guidance on Parental Bereavement Leave and Pay to reflect these changes.

We will continue to keep Members Up to Date.

The GB Government has introduced new Code of practice on industrial action ballots and notice to employers reflecting legal changes that took effect on 18 February 2026 under the Employment Rights Act 2025.

Key changes include:

• Simpler ballot notices – unions will have to provide less detailed information when notifying employers of a ballot.
• Shorter notice for industrial action – reduced from 14 days to 10 days (Northern Ireland remains at 7 days).
• Longer ballot validity – ballots opened on or after 18 February 2026 will be valid for 12 months, with no option to extend.
• Removal of the 40% support threshold for “important public services” – industrial action no longer needs this higher level of support (this threshold never applied in NI).
• No legal requirement to supervise picketing – unions will no longer be required to appoint a picket supervisor.
• Stronger protection from dismissal – employees taking part in lawful, official industrial action will be protected for the full duration of the action, not just for 12 weeks.

Consultation published on detriment for taking lawful industrial action

Following the Supreme Court’s decision in Secretary of State for Business and Trade v Mercer (2024), the GB Government has launched a consultation on protecting workers from detriment short of dismissal for taking part in lawful industrial action. The Court found that current law does not protect workers from sanctions such as warnings, disciplinary action or other penalties, and that this breaches Article 11 ECHR.

The Consultation proposes:

• Prohibiting all forms of detriment for taking part in lawful industrial action (the Government’s preferred option).
• Confirming that proportionate pay deductions during strikes will still be allowed.
• Considering whether to create a list of prohibited detriments, though little detail is provided.
• Allowing tribunals to apply ACAS Code uplifts to compensation in these cases.

Consultation closes on 23 April 2026, with regulations expected to take effect in October 2026.

The position in Northern Ireland

Industrial action laws in Northern Ireland will also be updated in several areas, but the approach remains more cautious than in Great Britain. The Department plans to keep the 7‑day notice period for industrial action, and will also look at ways to simplify the balloting process for unions and employers. It also intends to allow e‑balloting as an alternative to postal ballots.

The NI Code of Practice on Picketing states where picketing that is officially organised by a trade union should always have someone in charge ideally a union official. At present there is no proposal to change this requirement.

For employees taking part in industrial action, similar to GB the Department proposes to remove the current 12‑week limit on protection from dismissal for those involved in official industrial action. This means protection would last for the full duration of lawful action. The position on unofficial industrial action will remain unchanged—employees dismissed while taking part in unofficial action will normally not be able to claim unfair dismissal. There are no current proposals to amend the law to remove the lacuna identified by Mercer.

The 40% support threshold for “important public services” was never in place in Northern Ireland.

On 4 March 2026, in Great Britain, Government launched landmark gender pay gap and menopause action plans and published Creating an action plan: guidance for employers

Action Plans setting out new requirements for employers in England, Scotland and Wales to publish Gender Pay Gap and Menopause Action Plans.

These changes form part of the Employment Rights Act 2025 and will begin on a voluntary basis in April 2026, becoming mandatory in Spring 2027.

Although these requirements do not apply in Northern Ireland, they signal the direction of travel for workplace equality legislation and could influence future NI policy.

What is Changing in GB?

From April 2026, large employers (those with 250+ employees) in England, Scotland and Wales will be encouraged to publish an Action Plan alongside their Gender Pay Gap data. These plans must set out:

• How the organisation is reducing its gender pay gap
• How it is supporting employees experiencing menopause

The Government has published guidance and a list of recommended, evidence-informed actions employers can choose from. These include steps relating to recruitment, promotion, workplace culture, transparency and health‑related support.

Mandatory reporting is expected from Spring 2027, with plans published on the Government’s gender pay gap reporting platform. Employers who do not submit a plan may be publicly listed.

What will Action Plans look like?

Action plans will need to be practical and measurable. Employers must select at least two actions from a Government‑approved list, covering areas such as:

• Improving recruitment and promotion practices
• Increasing diversity in senior roles
• Supporting women with health conditions, including menopause
• Improving transparency around pay and progression

The menopause section includes actions such as manager training, workplace adjustments, access to occupational health and reviewing policies to ensure they reflect menopause‑related needs.

Further guidance will be issued in April 2026 on how to analyse data, choose actions, publish plans and monitor progress.

The position in Northern Ireland

Northern Ireland is not included in these new GB requirements. There is currently:

• No Gender Pay Gap Reporting duty in NI
• No requirement to publish Menopause Action Plans

However, Gender Pay Gap Reporting is expected to form part of the Good Jobs / Employment Rights Bill, likely no earlier than April 2027.

Although most of the GB Employment Rights Act 2025 will not apply in Northern Ireland, SSP is a devolved matter, and the Department for Communities has confirmed that Northern Ireland will follow the same SSP reforms as Great Britain.

In light of this the SSP changes coming into effect on 6 April 2026 will apply to Northern Ireland.

How do the SSP rules currently operate in Northern Ireland?

SSP is currently paid from the 4th day of sickness absence at a flat weekly rate (£118.75 per week from 6 April 2025, reviewed annually).

To qualify, employees need to be earning more than the Lower Earnings Limit, which is currently £125 a week (reviewed annually).

What is changing from 6 April 2026?

The key changes are:

1. SSP will be paid from the first full day of sickness, instead of from day 4. The current 3‑day waiting period will be removed;
2. The Lower Earnings Limit will be abolished, meaning employees will qualify for SSP regardless of how much they earn;
3. The SSP weekly rate will increase as part of the annual uprating cycle, rising from £118.75 to £123.25 per week from 6 April 2026.

These changes apply in Northern Ireland on the same timeline as Great Britain and represent the most significant reform to SSP in years.

The changes are explained in more detail in the Government Factsheet: Statutory Sick Pay (SSP)

What your Organisation needs to do

Removing the waiting days and the earnings threshold will mean more employees will qualify for SSP. It may also increase your levels of short‑term absence and the associated costs for your Organisation.

You should take steps now to prepare for the changes coming in April 2026 as follows:

1. Update your payroll systems so SSP is paid from day 1 and at the new SSP rate;
2. Review sickness absence policies to ensure they reflect day a SSP entitlement;
3. Check attendance management procedures so managers follow them consistently, particularly for repeated short‑term absences;
4. Brief and train managers on the new rules and re-inforce the importance of return‑to‑work interviews and of pro-active and consistent absence management;
5. Assess the impact on part‑time and lower‑earning staff, who may now qualify for SSP for the first time;
6. Audit the potential financial impact of the changes on your Organisation, including any knock‑on effects for enhanced sick pay schemes.

These SSP reforms sit alongside wider employment law changes expected under the forthcoming Good Jobs / Employment Rights Bill in Northern Ireland. However, SSP is one of the few measures being implemented ahead of the wider Bill.

Commentary

If your Organisation already provides contractual sick pay from day 1, the impact of these changes may be limited. However, if you currently pay SSP only, you will need to consider how these changes affect your policies, processes and day‑to‑day management of sickness absence. In particular, clear procedures and effective and consistent management of short term absence will be increasingly important.

In Great Britain, on 26 February 2026 the Government opened a further

Consultation on the threshold for triggering collective redundancy obligations.

This considers setting a new organisation‑wide threshold for triggering collective redundancy obligations should be set. The consultation runs from 26 February 2026 to 21 May 2026 and applies only to England, Scotland and Wales.

Employment law is devolved and Northern Ireland is not included in these proposals. However, the consultation does consider if the rules could apply to Northern Ireland where the same employer operates across both jurisdictions. This makes the proposals relevant for NI employers with GB operations or shared workforce structures.

Importantly “organisation‑wide” refers only to employees employed by the same legal entity, not everyone employed across a wider corporate group. This means the threshold is triggered per company, not per group. So, if Group Limited owns several separate companies, the numbers are not added together. For example, if Group A Ltd proposes 19 redundancies and Group B Ltd proposes 10, these figures would not be combined because the employees work for different legal entities. Only redundancies within the same employing company count toward the organisation‑wide threshold.

Proposals

Collective redundancy rules in Great Britain currently require employers to start consultation when they plan to make 20 or more redundancies at a single establishment within 90 days. The meaning of “establishment” has been shaped by case law, including the Woolworths decision, where many employees did not fall into collective consultation because their redundancies were spread across smaller sites, each below the 20‑employee threshold. This has been heavily criticised by some.

The GB Employment Rights Act 2025 will change this by introducing a new requirement to consult when redundancies reach a threshold across the whole organisation, not just at a single site. The consultation now seeks views on how that organisation‑wide threshold should be set.

The Consultation sets out four possible methods for setting the new threshold:

1. Method 1: Single Fixed Number (Government’s Preferred Option)

A fixed threshold somewhere between 250 and 1,000 proposed redundancies across the organisation. This is the simplest and most predictable approach.

2. Method 2: Percentage‑Based Threshold

Collective consultation would be triggered when an employer proposes to make a certain percentage of its total workforce redundant.

3. Method 3: Fixed Threshold Based on Employer Size

A sliding scale depending on total headcount, for example:

• 50 redundancies for employers with 0–2,499 employees
• 500 redundancies for employers with 2,500–9,999 employees
• 750 redundancies for employers with 10,000+ employees

4. Method 4: Combined Percentage and Fixed Threshold

A mixed model where smaller employers use a percentage trigger and larger employers use a fixed number.

The Government is leaning towards Method 1 but is seeking views on all options.

The consultation also includes an Analytical Annex, which estimates that up to 39,000 employers and 18.2 million employees could fall within scope depending on where the threshold is set.

Position in Northern Ireland

Northern Ireland is not included in these proposals, and the current Northern Ireland Good Jobs Bill does not contain similar plans. NI already differs from GB in some areas of redundancy law. For example, NI retained the 90‑day consultation period for 100+ redundancies, whereas GB reduced it to 45 days.

However, the GB consultation raises two important questions (see full details below) for NI employers:

• Could the new GB rules apply to NI employees if their employment has a “sufficiently strong connection” with Great Britain?
• Should employees outside England, Scotland and Wales be excluded when calculating total employee numbers for the new threshold?

This matters for employers who operate across both jurisdictions, have NI employees working remotely for GB operations, or have NI employees who regularly travel to GB for work. Determining whether an employee has a “strong connection” is fact‑specific and may be difficult in practice. This creates practical challenges for organisations that operate across both jurisdictions, particularly when monitoring headcount and assessing whether the new GB thresholds are triggered.

Question 15 seeks views:

The changes to the Collective Redundancy consultation threshold will generally apply only to employees who are working in Great Britain and not to those working

in Northern Ireland (unless their employment has a sufficiently strong connection with Great Britain).

Do you foresee any potential challenges for a business operating across both Great Britain and Northern Ireland when monitoring headcount and redundancies? Please explain your

answer.

[ ] Yes

[ ] No

[ ] Don’t know

[ ] Other

[FREE TEXT BOX] Please explain your answer below.

Question 21 seeks views:

Should employees outside of England, Scotland and Wales (where these regulations would apply) be excluded when working out the total employee numbers an employer has?

[ ] Yes

[ ] No

[ ] Don’t know

[ ] Other

We encourage any employer to provide us information, and we will feed those views into the Consultation response.