Since October 2024, employers have had a legal duty to take reasonable steps to prevent sexual harassment of their employees.
In short
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From 30 October 2026, employers must take all reasonable steps to prevent sexual harassment.
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The addition of the word "all" raises the bar for employers.
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Having a policy alone will not be enough.
What Changes?
From 30 October 2026, that duty becomes more demanding with the addition of one important word: all.
Employers will be required to take all reasonable steps to prevent sexual harassment. This raises expectations about the measures businesses should have in place and how effectively those measures operate in practice.
The key question: What more could you reasonably have done to prevent sexual harassment in your workplace?
Why It Matters
If a sexual harassment claim succeeds and the employer has breached its preventative duty, an employment tribunal can increase compensation by up to 25%.
The Equality and Human Rights Commission (EHRC) can also take enforcement action in relation to breaches of the duty.
The phrase "all reasonable steps" is already familiar in employment law. It is used in the statutory defence available to employers facing certain harassment claims.
Employers can find that defence difficult to establish. Tribunals look beyond written policies to examine whether preventative measures were genuine, appropriate and effective.
A policy that nobody reads, or training that has not been refreshed for years, is unlikely to provide convincing evidence that an employer has done everything reasonably expected of it.
The practical point: Prevention must be more than a document or a one-off training session. Employers need to show that their approach is active, relevant and regularly reviewed.
What Good Looks Like
Effective sexual harassment prevention requires a practical approach that reflects the risks, people and working environment of each organisation.
Employers should consider the following measures:
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A dynamic risk assessment. Identify potential harassment risks, involve people with different perspectives, assign responsibility and review the assessment regularly.
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Clear, accessible policies. Make sure employees understand the organisation's expectations and know where to find the relevant guidance.
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Relevant and refreshed training. Provide training that reflects employees' roles, responsibilities and working environments, and keep it up to date.
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Trusted reporting routes. Give people clear, accessible ways to raise concerns and confidence that they will be taken seriously.
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Prompt, fair and impartial action. Respond appropriately when concerns are raised, investigate thoroughly and take proportionate action where necessary.
These measures should not exist in isolation. They need to form part of a consistent approach to workplace behaviour, management and culture.
The Human Side
There is a simple question every employer should ask:
Do people feel safe speaking up here?
If the honest answer is no, that is where to start.
Employees need to know that concerns will be heard, handled sensitively and addressed fairly. Managers need the confidence and capability to respond appropriately.
A workplace where people feel safe, respected and able to speak openly is an important foundation for effective harassment prevention.
What to Do Now
Employers should use the time before 30 October 2026 to review their existing arrangements and identify where improvements are needed.
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Refresh your risk assessment. Review the risks of sexual harassment in your organisation and ensure that appropriate preventative measures are in place.
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Listen to your people. Ask employees what would help them feel safer and more confident. Seek different perspectives across the organisation.
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Review your complaint and investigation processes. Make sure concerns can be raised safely and that investigations are fair, thorough, impartial and effective.
The objective is not simply to demonstrate that procedures exist. It is to ensure that they work in practice and that people have confidence in them.
Let's Talk
At Impact Lawyers, we help businesses build sexual harassment prevention measures that work in real life, not just on paper.
Whether you need a harassment risk review, support with policies and reporting procedures, or practical manager training, we can help you prepare for the strengthened duty.
Talk to Victoria about how we can support your business.
Email: victoria.hall@impactlawyers.co.uk
By Victoria Hall, Co-Founder Employment Law
Victoria is an experienced employment lawyer, a Level 7 CIPD-qualified HR professional, accredited external workplace investigator, practising coach and a non-executive director.
This article is for informational purposes only and does not constitute legal advice. For specific legal advice tailored to your business, please contact the Impact Lawyers team at contact@impactlawyers.co.uk .