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Employment Rights Bill: next steps for implementation

By Verity Buckingham and Sarah Beeby
July 14, 2025
  • Legislative changes
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The Employment Rights Bill (ERB) is set to bring in the most significant reforms to UK employment law for more than 20 years. The government will implement the changes in phases. The Department for Business and Trade has published a policy paper, “Implementing the Employment Rights Bill: our roadmap for delivering change”, which outlines the planned timetable for consultations and implementation of the key measures in the ERB.

Our at-a-glance tables set out the key expected milestones, starting from consultations through to measures coming into force over the next two years.

Timetable for expected consultations

DateKey consultations
Summer – Autumn 2025Day-one unfair dismissal rightsStatutory probationary period dismissal processes
Autumn 2025Trade union reforms: electronic/workplace balloting, simplified recognition, duty to inform of the right to join, access rightsNew Acas Code of Practice for trade union representativesDismissal and re-engagement (“fire and rehire”) practicesUmbrella company regulationBereavement leave Increased rights for pregnant workers Crackdown on exploitative zero hours contracts
Winter 2025 – early 2026Further trade union protections (e.g. detriment for taking industrial action, blacklisting)Tipping law reformsCollective redundanciesFlexible working

Timetable for the implementation of key measures

DateExpected measures to come into force
Autumn 2025The following measures will come into force on, or soon after, Royal Assent: Repeal of parts of the Trade Union Act 2016 (reducing ballot and notice requirements, and other procedural barriers)Repeal of the Strikes (Minimum Service Levels) Act 2023 (removing requirement that a minimum level of service be provided during a strike in six specific sectors)Protection from dismissal for taking industrial actionSimpler industrial action ballot notices
April 2026Collective redundancy protective award period to increase (from maximum of 90 days’ pay to 180 days’ pay)Day-one rights to paternity and unpaid parental leaveWhistleblowing protections (detail to be confirmed, but we expect this to be the point at which sexual harassment reports will become protected disclosures)Fair Work Agency establishedRemoval of lower earnings limit and waiting period for Statutory Sick PaySimplified trade union recognition processElectronic/workplace ballotingVoluntary disclosure of equality action plans (setting out steps employers are taking to address gender pay and menopause support)
October 2026Restriction of dismissal and re-engagement (“fire and rehire”)New duty for employers to take all reasonable steps to prevent sexual harassmentRequirement for employers to prevent third-party harassment of employees Tribunal time limit extended to six monthsTrade unions – rights and protections for representatives; duty to inform of right to join; improved rights of access to workplaces Tightened tipping laws
2027Day-one unfair dismissal protectionNew rights for zero hours and low-hours/agency workers (e.g. guaranteed hours contracts, shift notice and compensation for cancelled shifts)Compulsory disclosure of equality action plans, covering steps employers are taking to address gender pay gap and provide menopause supportEnhanced rights for pregnant workersNew collective redundancy consultation threshold (to be defined in upcoming regulations)Reasonableness test for flexible working refusalsDay-one right to bereavement leave

Key aspects of the ERB will require secondary legislation and regulations, supported by existing (but amended) and new Codes of Practice, as well as official guidance.

The government will bring most changes into force with a common commencement date of 6 April or 1 October. The government has confirmed it will release further details on specific policies and implementation timelines following the outcome of related consultations.

While the roadmap outlines the government’s initial timeline for key reforms, it emphasises that this is subject to change. It plans a wide-ranging consultation process and the feedback it receives may influence both the content and timing of secondary legislation. Notably, we expect the consultation on the proposed day-one right to protection from unfair dismissal to launch shortly.

To support employers, workers and trade unions, the government will issue practical guidance and ensure there is adequate time to review and prepare before new measures take effect. Further adjustments to the ERB’s planned reforms are likely as consultations progress.

We will keep you informed of ERB developments via our blog.

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Verity Buckingham

About Verity Buckingham

Verity is experienced in all aspects of employment law and corporate immigration matters. She deals mostly with corporate clients advising on contentious and non-contentious employment matters. Verity's contentious practice includes defending claims in the Employment Tribunal and experience of Employment Appeal Tribunal litigation in relation to claims of unfair dismissal, discrimination, equal pay and whistleblowing.

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Sarah Beeby

About Sarah Beeby

Sarah is a partner and head of the Firm's tier one ranked People, Reward and Mobility practice in Milton Keynes. A very experienced employment lawyer, she undertakes a full range of employment work for a wide variety of clients in the private and public sectors, including many leading companies and household names. Sarah's work includes advising on large-scale redundancy and restructuring exercises, TUPE transfers and complex outsourcing arrangements, as well as advising on the employment aspects of large corporate transactions, having worked on numerous multi-million pound transactions for an impressive portfolio of clients.

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