The Government has issued an updated implementation timetable for the Employment Rights Act 2025 as part of its ‘Plan to Make Work Pay.’ The timeline replaces the July 2025 roadmap and confirms a phased rollout of reforms across 2026 and 2027.
The substance of the reforms has not shifted. What has changed is the order in which obligations, costs and enforcement arrive. Some measures take effect earlier than expected, while others that significantly affect dismissal risk have been pushed back.
Understanding the sequence matters, because preparation looks very different depending on whether a change affects day-to-day payroll, workforce planning or how disputes are handled.
December 2025
A small number of measures took effect immediately on Royal Assent in December 2025. The most notable is the repeal of the Strikes (Minimum Service Levels) Act 2023.
Statutory minimum service level requirements therefore no longer apply.
February 2026
From 18 February 2026, the trade union framework changes. The great majority of the Trade Union Act 2016 is repealed, simplifying how industrial action and political funds are regulated.
Protections against dismissal for taking industrial action are strengthened, and the rules around notices and ballots are streamlined.
From this point, employees who qualify for Day 1 Paternity Leave and Unpaid Parental Leave are also able to give notice. This affects how leave requests are handled even before those rights become fully effective.
April 2026
Early April 2026 is one of the most significant stages in the revised timetable.
From 6 April 2026, Statutory Sick Pay becomes payable to a wider group of employees following the removal of the Lower Earnings Limit and the waiting period. At the same time, the maximum collective redundancy protective award doubles, increasing exposure where consultation obligations are not met.
Day 1 Paternity Leave and Unpaid Parental Leave take full effect. Whistleblowing protection is strengthened in relation to sexual harassment, and Bereaved Partners’ Paternity Leave is introduced, allowing up to 52 weeks’ leave where the mother or primary adopter dies within the first year.
Voluntary action plans on gender equality and menopause support are also introduced alongside menopause guidance. While optional at this stage, these measures indicate future expectations.
The updated timetable also confirms that the Fair Work Agency will be established on 7 April 2026.
This marks a change in how employment rights are enforced. Even before later reforms take effect, enforcement becomes more coordinated across different areas of employment law.
Late 2026
Electronic and workplace balloting for statutory trade union ballots will take effect no earlier than August 2026.
A wider set of changes is scheduled for October 2026. These include expanded trade union access rights, new protections for trade union representatives and a duty to inform workers of their right to join a trade union.
New sexual harassment obligations also sit in this phase. Employers will be expected to take all reasonable steps to prevent harassment, including 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, leaving room for further delay.
January 2027
From January 2027, the qualifying period for unfair dismissal reduces to six months and the compensatory award cap is removed.
The shorter qualifying period applies to dismissals from 1 January 2027 onwards, rather than to start dates. Fire and rehire protections, previously expected in late 2026, are also scheduled for 2027.
This phase represents a structural shift in how early employment exits are assessed.
Further reforms planned across 2027
The Government continues to work towards introducing additional measures during 2027. These include mandatory action plans on gender equality and menopause support, 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 review.
What the revised timeline means in practice
The updated Employment Rights Act timeline is set to reshape the risk profile.
2026 brings wider statutory coverage, higher baseline costs and a new enforcement body. The more visible dismissal reforms arrive later, but they land into a system that is already less forgiving.
The practical challenge is using the additional time wisely. Adjusting policies, payroll processes, record keeping and people management habits before the later reforms take effect is far easier than reacting once they are in force.
The revised roadmap gives clarity on timing. It does not reduce the need to prepare.
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 Limited - a Marketing & Content Agency for the Professional Services Sector.
