2026 in Focus: What the ERB Roadmap Means for Employers
In July, the Government published its official Implementation Roadmap for the Employment Rights Bill, providing employers with the most detailed timeline yet for when the wide-ranging reforms are likely to take effect. For those of you already familiar with the broad proposals, this document is less about what is changing and more about when.
While the Bill itself was introduced with ambitious intentions, this latest update signals a more realistic, phased approach. Some headline changes like protections against zero-hours contracts and the long-anticipated ‘Day 1’ unfair dismissal right now appear unlikely to take effect until sometime in 2027, contrary to earlier expectations.
For Leaders, HR and People teams, this revised timeline brings greater clarity and time to prepare. If you’re reviewing policy documents, people strategies, or operational plans for next year, these now updated dates will be important for you to take note of.
Key Dates: What’s Happening and When?
The roadmap confirms that changes will roll out in stages between now and 2027, using common commencement dates: 6 April and 1 October each year.
Immediate (Following Royal Assent in 2025)
- Repeal of the Strikes (Minimum Service Levels) Act 2023
- Repeal of most of the Trade Union Act 2016
- New protections against dismissal for participating in industrial action
April 2026 – First wave of change
From 6 April 2026, the following measures are expected to come into force:
- Reform to Statutory Sick Pay - Removal of both the lower earnings limit and the three-day waiting period. This significantly broadens access.
- Doubling the protective award for collective redundancies
- ‘Day 1’ rights for:
- Paternity leave
- Unpaid parental leave
- New whistleblowing protections
- Simplified trade union recognition processes
- Introduction of electronic and workplace balloting
- Establishment of the new Fair Work Agency
This phase will require policy updates in relation to family leave, sickness absence, whistleblowing procedures, and trade union engagement. HR and payroll systems may also need configuration updates.
October 2026 – Expanded obligations
From 1 October 2026, a further set of changes are expected, including:
- New employer duties to take ‘all reasonable steps’ to prevent sexual harassment, including by third parties.
- Ban on fire and rehire practices
- Stricter employment tribunal limits and protections for those taking industrial action
- Launch of a Fair Pay Agreement Negotiating Body for adult social care
- Revised tipping legislation
- Expanded Trade Union rights
This wave introduces new risks for employers who haven’t recently reviewed their Dignity at Work or Respectful Workplace policies. Updates to handbooks will need to be made and manager training will be essential, especially in relation to harassment prevention, consultation protocols and contract variation processes.
2027 – Final phase
Though further detail is still expected following consultation, the Government has indicated that the final phase (throughout 2027) will include:
- Protections against zero‑hour contract abuse, extended to agency workers
- ‘Day 1’ right to protection from unfair dismissal
- New rights for pregnant workers
- Flexible working reform
- Gender pay gap and menopause action plans (voluntary from April 2026, likely firming up later)
- Bereavement leave
- Regulation of umbrella companies
- Collective redundancy consultation changes
These are more systemic changes that will require long-term planning, particularly for businesses relying on casual contracts or working across sectors with complex employment models.
Key Takeaways for Employers
- April and October 2026 are your anchor points. Planning updates should align with these dates as you prepare internal communications, training, policy reviews, contract updates and system changes.
- Consultations are still underway on several measures, but the roadmap gives enough certainty to begin risk assessments and scenario planning. Sector-specific guidance (e.g. from Acas) is expected in due course. These will be essential for operationalising the changes, especially for SMEs and non-unionised environments.
- While implementation is phased, the cumulative impact is significant. Early preparation will help ensure compliance and reduce disruption.
How Fresh Seed can support
Whether you need to review strategy, employment contracts, develop training for line managers, or assess policy gaps, we can help you prepare for what's ahead.
Get in touch here if you'd like to talk through a tailored roadmap for your business.