The UK government is updating legislation aimed at preventing workplace sexual harassment. Starting in October 2026, employers must take ‘all reasonable steps’ to prevent sexual harassment of their employees while at work. Currently, employers are required to take ‘reasonable steps’, meaning they have made an active effort to prevent predatory behaviours. This duty applies not only to the behaviour of employees but also to harassment carried out by customers, clients, contractors and members of the public.
Why this matters.
Sexual harassment remains a real threat in workplaces across the UK. While previous legislation sought to address the issue, too many victims were left without the support and protection they deserved. Failing to take action can create the impression that:
• This kind of behaviour is tolerated or even encouraged.
• Employees who speak up will not be supported.
The result can be a toxic and potentially dangerous working environment that damages morale, wellbeing and productivity. Furthermore, employers who fail to adequately protect their people may face tribunal claims and increased compensation awards.
The changes
Previously, while employers were expected to follow the guidance set out by the Equality and Human Rights Commission (EHRC) under Worker Protection (Amendment of Equality Act 2010) Act 2023, they only needed to demonstrate that they had taken reasonable steps to prevent sexual harassment.
The key change is the addition of one word: all.
From October 2026, employers will be expected to show they have taken all reasonable steps to prevent sexual harassment in the workplace. This significantly raises the bar and places a greater emphasis on proactive prevention rather than reacting after an incident has occurred.
While the specific measures required will vary between organisations, employers must be prepared to demonstrate that they have done everything reasonably possible to identify risks, educate their workforce and take action to prevent harassment before it happens.
The reasonable steps an employer must take will depend on a range of factors, including:
Employer size and resources.
Larger organisations with greater resources may be expected to implement more comprehensive measures, such as structured classroom-based training programmes, refresher training and regular reviews of workplace culture and policies.
Sector.
Some industries and work environments carry a higher risk of sexual harassment than others. Hospitality, leisure and nightlife settings where alcohol is present, for example, may require additional safeguards and more robust preventative measures.
Third parties
If employees regularly interact with customers, contractors, suppliers, partners or members of the public, employers may need stronger protections due to the increased risk of third-party harassment.
Past failures and incidents
Previous complaints, investigations or identified weaknesses may create an expectation that employers take further action to address known risks. Failure to improve where shortcomings have already been identified may leave organisations vulnerable to challenge.
The steps outlined in the Equality and Human Rights Commission’s guidance represent best practice for preventing and responding to sexual harassment. In the event of a tribunal, evidence of how closely your organisation has followed this guidance may play an important role in determining whether you have met your obligations.
Don’t wait until a member of your team experiences harassment before taking action to prevent future incidents.
Training is no longer optional evidence
Demonstrating that you have taken all reasonable steps can be difficult without clear evidence. Policies alone are unlikely to be enough, although you need to have a Sexual Harassment Policy that sets out your organisation’s commitment to preventing sexual harassment, explains what behaviour is unacceptable, and provides a clear process for reporting and dealing with complaints. However, you must demonstrate action as well as words.
One of the strongest ways to demonstrate compliance is through documented training for both managers and employees. Training records, certificates, assessments and refresher programmes can provide tangible evidence that your organisation has taken proactive action to prevent harassment rather than simply responding when problems arise.
While the exact measures required will vary from business to business, sexual harassment training is increasingly regarded as a fundamental expectation for organisations of all sizes when evidencing that they have taken all reasonable steps to protect their people.
Our solutions
When faced with a sexual harassment complaint or tribunal claim, proving that you have taken all reasonable steps to prevent harassment can be challenging without clear evidence.
It becomes significantly easier if you have trained your managers to understand what constitutes sexual harassment, how to identify warning signs, how to intervene early, how to protect their people, how to respond appropriately to concerns and how to take action against perpetrators, with the intention of creating a safer and more supportive workplace for everyone.
By training your people, this will reduce your risk, both legally and financially and it will demonstrate your compliance and commitment to taking all reasonable steps in the event of an employment tribunal. Employees must also understand what sexual harassment is — and what it isn’t. Establishing boundaries, understanding when behaviour has crossed the line from workplace banter into unacceptable conduct, knowing how to challenge unwanted behaviour and feeling confident to speak up are all vital.
Employees should be encouraged not to tolerate sexual harassment, whether directed at themselves or others, and to report concerns so management can take appropriate action. Creating a culture where people feel safe raising concerns is just as important as having policies in place.
You need a management team that understands its responsibilities and a workplace culture where employees trust that concerns will be taken seriously and handled appropriately.
We recommend that to demonstrate you have taken all reasonable steps –
Tell them. Train them. Test them.
Training Sensei
Training Sensei provides affordable, effective courses that demonstrate employees have received compliance training.
Courses can be assigned to individuals and teams, while completion records provide valuable evidence that your organisation has taken proactive steps to train your people.
There are also specific Sexual Harrassment training courses for managers so they understand what to look for and their legal responsibilities in managing allegations of sexual harassment, along with a course aimed at educating employees. Both courses include a knowledge check, which documents that the learner has understood the training.
SEEDL
Businesses looking to embed learning into everyday workplace culture can benefit from SEEDL’s broader learning and development platform.
SEEDL provides high-quality CPD-accredited learning through both live events and on-demand resources. Employers can create structured learning pathways, monitor engagement and reinforce workplace expectations through continuous development rather than one-off training sessions.
Learning pathways can include:
• Sexual Harassment Prevention
• Inclusive Leadership
• Speaking Up
• Equality & Diversity
• Leadership and Management Development
Need support?
Unsure whether your organisation could demonstrate that it has taken all reasonable steps to prevent workplace sexual harassment?
Working with an experienced HR partner can help you navigate these changes with confidence. For businesses across Manchester and the North West, our HR consultants can provide tailored advice, review your existing approach, identify potential gaps and help prepare your organisation for regulatory changes.
Contact People Matters HR for a compliance review and discover how Training Sensei and SEEDL can help protect your people, strengthen your culture and support your legal obligations.