Third-Party Harassment: What Employers Need to Know Before October 2026
From 30 October 2026, employers in Great Britain will have additional legal obligations to protect staff from harassment at work, including harassment by customers, clients, contractors and members of the public.
What is changing?
Under the new legislation, employers in Great Britain could be held liable if an employee is harassed by a third party in the course of their employment and the employer cannot demonstrate that it took all reasonable steps to prevent it.
The protection applies to harassment related to age, disability, gender reassignment, race, religion or belief, sex and sexual orientation, as well as sexual harassment.
Who is considered a third party?
A third party is anyone an employee comes into contact with through their work who is not employed by the organisation.
This may include:
• Customers and clients
• Contractors and consultants
• Patients, students or service users
• Attendees at conferences, events or meetings
• Members of the public
What are "all reasonable steps"?
What amounts to “all reasonable steps” will depend on the size and nature of the business and employees’ level of contact with third parties. Employers should assess their workplace risks and ensure that policies, training and reporting procedures address them.
What should employers do now?
Employers in Great Britain should review their policies, risk assessments, training and reporting procedures now to identify gaps and prepare for the new provisions. Some examples of steps might include:-
• Update anti-harassment policies to include reference to third-party harassment.
• Assess workplace risks where employees regularly interact with customers, clients, contractors, or the public.
• Provide training on recognising, reporting, and responding to harassment.
• Ensure employees know how to report incidents and that complaints are investigated promptly.
• Regularly review policies, training, and risk assessments to ensure they remain effective and aligned with legal requirements.
Other employment law changes from October 2026
Alongside the introduction of employer liability for third-party harassment, employers in Great Britain should also be aware of other key changes taking effect from October 2026:
• Extended Employment Tribunal time limits – employees will have six months, rather than three, to bring most claims.
• Enhanced trade union access rights – recognised trade unions will have greater rights to access workplaces and communicate with workers, making it easier for unions to recruit, organise and support employees.
If you would like further information about this topic or need advice on an employment law or HR issue, please contact us.
