October: employers start answering for how customers behave
From 30 October part of the Employment Rights Act 2025 takes effect: employers must take “all reasonable steps” against sexual harassment and become liable for harassment by third parties — customers, visitors, contractors. And from 1 October the tribunal time limit rises from three months to six.
October is the month the Employment Rights Act 2025 stops being a story about the future. Two dates to note: 1 October and 30 October 2026.
1 October: six months to bring a claim
The time limit for lodging an employment tribunal claim rises from three months to six. In Scotland, breach of contract claims follow on 9 November.
Three months was the deadline people missed most. Someone is dismissed, spends a month recovering, a month job-hunting, and by the time they look into their rights it is too late. Six months leaves room to try to settle first and litigate only if that fails.
One caveat: the clock runs from the event, not from the day you started thinking about it. And Acas early conciliation — free — still comes before a tribunal.
30 October: the customer is no longer someone else's problem
This is the change that matters for anyone whose work involves the public — cafés, shops, taxis, salons, care homes, sites, delivery.
Today an employer answers for what its own staff do. From 30 October it also answers for third parties — customers, visitors, contractors. If a regular has been pestering a waitress for months and the manager shrugs, that is now the employer's problem, and the employer can end up as respondent.
Alongside it comes an explicit duty to take all reasonable steps to prevent sexual harassment. Not advisable — required.
What counts as a reasonable step
There is no statutory list: what is reasonable depends on the business and what it can realistically do. A three-person café and a forty-site chain will be judged differently. Acas gives examples:
- risk assessment and an incident log — who, when, what happened;
- a written anti-harassment policy staff actually know about;
- training: how to de-escalate, what to do, who to tell;
- reviewing contracts with clients and suppliers;
- where risk is higher — cameras, panic alarms, never rostering someone alone.
One detail worth lifting from the Acas guidance: if you decide not to take a step, write down why. Declining to install cameras in a small shop is a position you can defend. No record at all is not.
Trade unions
From the same date employers must tell workers about their right to join a union, unions get wider rights of access to the workplace, and union representatives gain a right to facilities. Protection for workers taking industrial action is strengthened.
What comes next
On the government's published timeline, January 2027 brings the bigger items: the qualifying period for unfair dismissal drops to six months, the cap on compensatory awards is removed, and fire-and-rehire protections come in. Across 2027: guaranteed hours for zero-hours contracts, mandatory gender equality and menopause action plans for employers with 250+ staff, bereavement leave, and NDAs that conceal harassment made void.
Exact dates within 2027 have not been announced.
In short
If you are employed. Log incidents as they happen — date, time, what was said, who saw it. Report in writing, even a short message to your manager: after 30 October, an employer who does nothing after such a message owns the problem. And remember the new six-month window.
If you employ people. Three things before the end of October: a one-page policy, a conversation with the team that you record having had, and an incident log. That is not box-ticking — those three things are what "reasonable steps" looks like if it is ever disputed.
We do not give individual legal advice. For a specific situation, Acas advice is free, or speak to an employment solicitor.
