Yesterday the Government published its Employment Rights Bill Implementation Roadmap. The Roadmap provides the first clear indication of the Government’s anticipated commencement dates for the various employment related reforms in the Bill. Previously, there was uncertainty about when the changes would take effect; while the Government had committed not to introduce the day 1 right to unfair dismissal until Autumn 2026 at the earliest, most other changes lacked specific timeframes.
The Roadmap outlines a phased approach to implementing the changes over the next two years, starting this summer and using the familiar employment law implementation dates of April and October. It aims to balance giving businesses time to prepare with delivering reform at pace. Some changes relating to industrial action will take effect as soon as the Bill receives Royal Assent, while two headline changes—on zero hours contracts and the removal of the two-year qualifying period for unfair dismissal—will not occur until 2027, reflecting their complexity and impact. Employers will welcome this clarity and the longer lead-in time.
There is still uncertainty about when the Bill will receive Royal Assent. The Bill is moving to the Report Stage in the House of Lords, having passed the Committee Stage in late June. Initially expected to be finalised by the end of this parliamentary term, slow progress and extensive debate have led to speculation (so far unconfirmed) that Royal Assent may not occur until Parliament resumes in the Autumn.
The Roadmap also outlined when various consultations—which will inform the secondary legislation containing the detail of the Bill, such as the second threshold trigger for collective consultation—will be launched. The Government has also committed to developing guidance and Statutory Codes of Practice to support compliance.
The implementation dates for the legislation and timings of the various consultations are outlined below. For more information on the Bill, see our Employment Rights Bill tracker.
| Timings | Legislation/ Consultation | Details |
Royal Assent or soon afterwards | Legislation | - Repeal of the Strikes (Minimum Service Levels) Act 2023
- Repeal of most of the Trade Union Act 2016 (some provisions will be repealed via commencement order at a later date)
- Removing the 10 year ballot requirement for trade union political funds
- Simplifying industrial action notices and industrial action ballot notices
- Protections against dismissal for taking industrial action
|
| Summer / Autumn 2025 | Consultation | - Giving employees protection from unfair dismissal from day 1 including proposals on the dismissal process in the statutory probationary period
|
| Autumn 2025 | Consultation | - A package of trade union measures including electronic balloting and workplace balloting; simplifying trade union recognition processes; duty to inform workers of their right to join a trade union; and, right of access. New rights and protections for trade union representatives will be covered by an Acas Code of Practice consultation.
- Fire and rehire
- Regulation of umbrella companies
- Bereavement leave
- Rights for pregnant workers
- Zero hours contracts changes
|
April 2026 | Legislation | - Collective redundancy protective award – doubling the maximum period of the protective award from 90 days to 180 days
- Day 1 rights to paternity leave and unpaid parental leave
- Whistleblowing protections
- Fair Work Agency body established
- Statutory Sick Pay – removal of the Lower Earnings Limit and waiting period
- Simplifying the trade union recognition process
- Electronic and workplace balloting
|
| October 2026 | Legislation | - Fire and rehire
- Procurement changes and the two-tier code
- Tightening tipping law
- Duty to inform workers of their right to join a trade union
- Strengthen trade unions' right of access
- Requiring employers to take “all reasonable steps” to prevent sexual harassment of their employees
- Introducing an obligation on employers not to permit the harassment of their employees by third parties
- New rights and protections for trade union representatives
- Extending employment tribunal time limits
- Extending protections against detriments for taking industrial action
|
| Winter/ early 2026 | Consultation | - Trade union measures including protection against detriments for taking industrial action and blacklisting.
- Tightening tipping law
- Collective redundancy
- Flexible working
|
| 2027 | Legislation | - Introducing gender pay gap and menopause action plans (to be introduced on a voluntary basis in April 2026)
- Strengthening protections for pregnant workers
- Introducing a power to enable regulations to specify steps that are to be regarded as “reasonable”, to determine whether an employer has taken all reasonable steps to prevent sexual harassment
- Blacklisting
- Industrial relations framework
- Regulation of umbrella companies
- Collective redundancy threshold – introducing a second collective consultation threshold trigger
- Changes to flexible working
- Bereavement leave
- Zero hours contract measures and application to agency workers
- Day 1 right to protection from unfair dismissal
|
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