employment-law
Preventing workplace sexual harassment: employer checklist for October 2026
A practical employer checklist for the strengthened sexual-harassment prevention duty and third-party harassment rules effective from 30 October 2026.
From 30 October 2026, UK employers must take all reasonable steps to prevent sexual harassment of employees. Employers must also take all reasonable steps to prevent harassment by third parties such as customers, clients, contractors, patients, residents and visitors. This is more than a policy-writing exercise: the organisation should be able to demonstrate that it identified its particular risks, introduced proportionate controls, trained people and checked whether those controls worked.
Start with a workplace-specific risk assessment
A generic statement that harassment is prohibited will rarely describe the risks in every workplace. Consider where, when and how people interact. Relevant factors can include lone work, alcohol, social events, night shifts, customer-facing duties, travel, messaging platforms, seniority imbalances and work on client premises.
Speak to employees without requiring them to disclose personal experiences publicly. Review previous complaints, exit feedback, absence patterns and recurring concerns. Consider whether temporary workers, apprentices, younger workers or people whose first language is not English may face additional barriers to reporting. Record the hazards, existing controls, further action, owner and review date.
Update policies and reporting routes
The anti-harassment policy should define sexual harassment in accessible language and give realistic examples. It should cover conduct in person, online, at social events, during travel and through work-related messaging. Explain that conduct can be unwanted even if the person responsible describes it as a joke or did not intend harm.
Provide more than one reporting route. An employee may not feel able to complain to a line manager who is involved, close to the alleged harasser or connected to a valuable client. Name an alternative manager, HR contact or independent channel. Explain confidentiality honestly: information should be limited to those who need it, but complete secrecy cannot always be promised if the employer must investigate or protect others.
Set expectations for customers and other third parties too. Depending on the workplace, reasonable controls might include customer conduct notices, contract terms, incident escalation, removing a worker from immediate risk, refusing service or raising misconduct with a client-site manager. Employees should never be told that harassment is simply part of a public-facing role.
Train managers and employees
Training should be relevant, understandable and repeated. Cover recognising harassment, safe intervention, reporting, retaliation, confidentiality and manager responsibilities. Use scenarios that resemble the real workplace rather than abstract legal definitions. Record attendance and arrange catch-up training for starters and absentees.
Managers need additional instruction. They should know how to receive a concern without dismissing it, promising an outcome or beginning an improvised investigation. They must preserve evidence, consider immediate protection, escalate promptly and avoid penalising the person who reported the issue.
Respond properly when concerns arise
Take every report seriously, including informal remarks and concerns raised by witnesses. Ask what immediate support or safety measures are needed. Temporary changes should avoid placing the reporting employee at a disadvantage wherever possible.
Choose an impartial investigator, define the allegations and collect relevant evidence. Give the person complained about a fair opportunity to respond. Keep clear notes and reach findings on the available evidence. If disciplinary action may follow, use a fair procedure and allow an appeal. Our disciplinary and grievance guide explains the broader process.
Do not wait for a formal grievance where the employer already knows about serious conduct. Equally, avoid treating every allegation as proven before investigation. The prevention duty and procedural fairness must operate together.
Monitor whether prevention measures work
Review the risk assessment after incidents, organisational change, new premises, new client contracts or evidence that reporting routes are not trusted. Look for patterns rather than relying only on formal complaint numbers. Very low reporting can mean a healthy culture, but it can also indicate that employees expect nothing to happen.
Useful monitoring evidence includes training completion, manager briefings, anonymous survey results, incident response times, recurring locations or shifts, actions taken with third parties and policy review records. Senior leaders should receive enough information to challenge gaps without circulating unnecessary personal details.
Employer checklist
- complete and record a workplace-specific harassment risk assessment;
- update the anti-harassment policy and examples;
- provide at least one alternative reporting route;
- identify risks from customers, clients, contractors and visitors;
- train employees and give managers additional response training;
- document attendance, incidents, investigations and corrective action;
- prohibit retaliation and monitor the treatment of everyone involved;
- review controls after incidents and at planned intervals.
The employee handbook should make the standards and reporting routes easy to find. Create an industry-aware employee handbook and review the final wording against the organisation's actual risk assessment, reporting structure and third-party arrangements.
This guide provides general information, not legal advice. What counts as all reasonable steps depends on the organisation and circumstances. Obtain specialist advice about serious allegations, dismissal, regulatory duties or threatened claims.
