Employers are now able to complete and submit the Insolvency Service’s HR1 form entirely online through the existing government portal, as well as via a new dedicated HR1 link. We have compiled some reminders on when employers must complete an HR1 form and the consequences of failing to do so.
This update forms part of the Insolvency Service’s wider effort to modernise its processes and simplify how employers meet their statutory obligations in redundancy situations. The move to a digital service is also expected to ensure that employers are working with the most up-to-date version of the form and minimise opportunities for errors.
What is the HR1 form?
Employers must use the HR1 form to notify the Secretary of State, via the Insolvency Service, when it is proposing to make collective redundancies. Where an employer plans to dismiss as redundant between 20 and 99 employees at one establishment within a 90-day period, the Insolvency Service must receive the HR1 form at least 30 days before the first dismissal takes effect. Where 100 or more redundancies are proposed within the same period, the Insolvency Service must receive the HR1 form at least 45 days in advance. Failure to submit the HR1 form is a criminal offence, with the potential for an unlimited fine.
The purpose of the HR1 form is to ensure that employers inform the government in advance of large-scale redundancy proposals, which in turn enables relevant agencies to provide support to employees who lose their job.
Wide meaning of redundancy
It is important to remember that for the purposes of the obligation to consult collectively, and to notify the Secretary of State on an HR1 form, the term “redundancy” is wider than the definition used to determine eligibility for a statutory redundancy payment. It includes any dismissal for a reason or reasons not related to the individual concerned. This means it would cover a situation where an employer proposes to dismiss and re-engage employees on different terms and conditions (commonly known as “fire and rehire”).
Online only from 1 December 2025
From 1 December 2025, the Insolvency Service will no longer accept paper-based HR1 forms and applicants will be redirected to the digital version.
Employment Rights Bill changes to collective consultation thresholds
As HR1 forms move to a digital process, it is also worth keeping in mind the proposed changes to collective consultation thresholds in the Employment Rights Bill (the Bill). At present, the trigger for collective consultation is if the employer proposes to dismiss as redundant 20 or more employees at one establishment. The concept of “one establishment” was the subject of debate in several cases. Under the Bill, the trigger will become either:
- 20 or more employees at one establishment; or
- at least the “threshold number of employees”.
The government would have the power to make regulations specifying the threshold number, which might be a particular number or could be a particular percentage of employees, or it could be calculated in some other way. No matter the method of calculation, the provision will stipulate that the threshold number must not be lower than 20 employees. The government plans to introduce this change in 2027.
Increase in maximum protective award
In the meantime, the Bill proposes to increase the maximum protective award for failing to consult collectively over proposed redundancies from 90 days’ pay to 180 days’ pay. This change is likely to take effect in April 2026. Find out more about these changes in our blog post here and the timeline for implementation of the Bill here.
