The Government has confirmed a revised implementation timetable for the Employment Rights Act 2025 under its ‘Plan to Make Work Pay’. The update replaces the previous July 2025 roadmap and resets several dates that HR teams may already have built into policy reviews, training programmes and workforce planning.
What has changed is the order in which pressure hits. Enforcement capability, statutory cost exposure and trade union leverage all arrive first, with the most litigation-sensitive dismissal reforms following later.
For HR, this presents a sequencing issue that affects when policies need to be rewritten, when managers need retraining and when systems need stress-testing.
What has already changed
Some measures under the Employment Rights Act 2025 took effect immediately on Royal Assent in December 2025. Most notably, the Strikes (Minimum Service Levels) Act 2023 has been repealed.
HR teams in unionised or strike-exposed environments should already be operating on the basis that statutory minimum service level obligations no longer apply.
February 2026: trade union framework resets
From 18 February 2026, a wide package of trade union law reforms comes into force. The great majority of the Trade Union Act 2016 is repealed, simplifying rules around industrial action, ballots and political funds.
The same date brings stronger protections against dismissal for taking industrial action and procedural changes to notices and ballots. Employees newly eligible for Day 1 Paternity Leave and Unpaid Parental Leave are also able to give notice from this point.
For HR, this is an early trigger point for policy updates, manager briefings and industrial relations playbooks.
April 2026: multiple key changes
Early April 2026 is one of the most significant phases in the revised timetable.
From 6 April 2026, Statutory Sick Pay expands through the removal of the Lower Earnings Limit and waiting period, pulling a much wider group of employees into scope. On the same date, the maximum collective redundancy protective award doubles, increasing financial exposure where consultation fails.
Day 1 Paternity Leave and Unpaid Parental Leave become fully effective. Whistleblowing protection is strengthened in relation to sexual harassment, and Bereaved Partners’ Paternity Leave is introduced, allowing up to 52 weeks’ leave where a mother or primary adopter dies within the first year.
Voluntary action plans on gender equality and menopause support also appear at this stage, alongside new menopause guidance. While not mandatory yet, these measures signal future expectations for HR governance.
The revised timetable also confirms that the Fair Work Agency will be formally established on 7 April 2026.
For HR teams, this marks a shift in the enforcement backdrop. Even before later reforms take effect, April 2026 is the point at which employers should expect a more coordinated approach to enforcement across multiple employment rights.
Late 2026: access rights, harassment duties and tribunal timing
Electronic and workplace balloting for statutory trade union ballots will take effect no earlier than August 2026. This reform has been separated out from the October tranche in the updated timetable.
October 2026 remains a focal point for workplace protections. These include expanded trade union access rights, new rights for representatives, duties to inform workers of their right to join a trade union and extended protection against detriment for industrial action.
New sexual harassment duties also sit here, including obligations to take all reasonable steps to prevent harassment and not to permit harassment by third parties, supported by regulation-making powers on what counts as reasonable.
Employment tribunal time limit changes are described as taking effect no earlier than October 2026, expressly allowing for further slippage.
January 2027: dismissal risk shifts materially
The reduction of the unfair dismissal qualifying period to six months and the removal of the compensatory award cap will take effect from January 2027.
The reduced qualifying period applies to dismissals from 1 January 2027 onwards, not to employment start dates. Fire and rehire protections, previously expected in October 2026, are now also scheduled for 2027.
For HR, this represents a structural change to exit risk, particularly around probation management, documentation standards and early performance processes.
Further reforms across 2027
The Government continues to work towards delivering a further set of reforms during 2027. These include mandatory gender equality and menopause action plans, enhanced dismissal protections for pregnant women and new mothers, regulation of umbrella companies, changes to collective consultation thresholds, flexible working reforms, expanded bereavement leave including pregnancy loss, restrictions on zero-hours contracts and further extensions of electronic and workplace balloting.
All of these timings remain subject to consultation and ongoing review.
HR takeaway
The revised Employment Rights Act timeline does not reduce HR exposure. It redistributes it.
2026 is about cost, enforcement and leverage. 2027 is about claims volume and compensation risk. HR teams that wait for the dismissal reforms to land before acting will be working in a much tighter environment, with stronger unions, broader statutory coverage and a new enforcement body already in place.
The practical task now is sequencing internal change properly, not waiting for the final whistle.
Author
Gill Laing is a qualified Legal Researcher & Analyst with niche specialisms in Law, Tax, Human Resources, Immigration & Employment Law.
Gill is a Multiple Business Owner and the Managing Director of Prof Services - a Marketing & Content Agency for the Professional Services Sector.
