Are Your Managers Ready? Stricter obligations to prevent sexual harassment from TODAY

From today, 30 October 2026, employers are now under a stricter legal obligation to take all reasonable steps to prevent sexual harassment in the workplace. This is a significant change that places greater emphasis on proactive prevention measures, rather than simply reacting to complaints once they arise.

Recent research suggests that many employers aren’t able to demonstrate they’ve put in place the required reasonable steps.

A recent survey of almost 1,000 HR and compliance professionals¹ found significant gaps in training, risk assessments and reporting arrangements that could leave organisations vulnerable to tribunal claims.

The biggest risk? Untrained managers

The research found that only 30% of organisations provide managers with dedicated training on handling sexual harassment issues, whilst 21% provide no specific manager training at all.

This presents a significant risk. Managers are often the first people employees speak to when something goes wrong. How that initial conversation is handled can have a significant impact on whether the employee feels supported, the quality of any investigation and, ultimately, an employer's ability to demonstrate it has taken appropriate steps to prevent and address harassment. A poorly handled disclosure may undermine trust, discourage reporting and increase legal exposure.

You should be considering whether your managers have received specific training on:

♦  Recognising sexual harassment.

♦  Responding appropriately to disclosures.

♦  Escalating concerns correctly.

♦  Supporting employees who raise complaints.

♦  Maintaining confidentiality and avoiding victimisation.

Providing general employee training alone may no longer be enough.

Risk assessments are being overlooked

The survey also found that 34% of respondents had never conducted a sexual harassment risk assessment, while a further 17% had not reviewed one for more than a year.

A risk assessment is increasingly viewed as one of the clearest ways of demonstrating compliance with the preventative duty. It provides evidence that you have considered where harassment could occur within your organisation and taken steps to minimise those risks. 

You should ensure that risk assessments are conducted regularly and updated whenever workplace circumstances change.

Policies alone are not enough

The findings suggest that many organisations are relying on policies without ensuring that employees fully understand them. Effective prevention requires more than simply publishing a policy on the company intranet.

Nearly half of respondents (47%) said their current sexual harassment training needs improvement, while 14% admitted they provide no training at all. 

Tribunals are likely to look beyond whether a policy exists and consider whether employers have taken practical steps to embed it within the workplace. Regular and meaningful training remains one of the most effective ways of demonstrating a commitment to prevention. 

Employees need to understand expected standards of behaviour, know how to report concerns and feel confident that complaints will be taken seriously.

What can you do?

With the October deadline approaching, you should consider whether you can demonstrate that you have:

 Carried out and documented a sexual harassment risk assessment.

 Reviewed and updated your sexual harassment policy.

 Delivered training to all employees.

 Provided dedicated training for managers.

 Established multiple reporting channels for employees.

 Regularly reviewed workplace risks and preventative measures.

  Maintained records of the steps taken to prevent harassment. 

The move to an "all reasonable steps" duty is intended to encourage employers to take a proactive approach. Organisations that review their arrangements now will be in a stronger position to demonstrate compliance should issues arise in the future.

How We Can Help

We are advising our clients to review their current arrangements and identify any gaps in their approach to preventing sexual harassment.

If you would like support complying with the new requirements, we offer a Sexual Harassment Pack, which includes:

 a template Sexual Harassment Risk Assessment document; 

 a Sexual Harassment Policy;

 an Employee Quiz to help demonstrate understanding of the policy; and 

 2 pre-recorded training webinars – one for employees and one for line managers. 

The package is available for £1,250 plus VAT.

These resources are designed to help employers take proactive steps towards compliance and demonstrate their commitment to preventing sexual harassment in the workplace*.

If you would like more information about our Sexual Harassment Pack or training webinars, or if you have any questions about your obligations, please get in touch with our Employment Team - employment@porterdodson.co.uk

¹All reasonable steps duty: One in five UK managers have no sexual harassment training, new data shows - VinciWorks

* Reliance on this training alone will not necessarily fulfil your obligations to take all reasonable steps; however, it is a good starting point.