From October 30, companies in the UK will need to take all reasonable steps to reduce the risk of staff suffering from instances of sexual harassment. They’ll become legally responsible when external stakeholders, including customers and clients, harass employees and could be and will be held liable if they fail to take suitable steps to prevent this. These rulings apply to people working in bars, hospitals, shops, and call centres, representing one of the biggest changes in sexual harassment law in UK legal history.
The rule changes follow on the back of the 2019 ILO Violence and Harassment Convention, which recognises that everybody has the right to work in a workplace free from harassment and violence. Previously, the law focused on colleagues and managers, but now it extends to patients, clients, and customers, who can also be perpetrators of sexual harassment-related crimes.
The convention was adopted in 2019. It was ratified by the UK in 2022, and 56 countries had done the same by the end of April 2026.
Grapple Law says that employers need to be aware of these changes.
“Many companies still aren’t aware that the rules around sexual harassment are changing. Companies need to do more than simply have internal policies that protect staff. Now they need to make sure they take all reasonable steps to protect workers from customers and clients as well, which was a gap in the previous legislation.”
How the new regulations operate
The new regulations fundamentally change how employment law operates in Britain. The Employment Rights Act of 2025 became law in December last year and comes with a set of phased provisions. Some measures came into force on October 1, 2026, while three harassment measures come into force on October 30.
There are also slight changes to the wording of the law. Previously, the rules stated that employers had a duty to take “reasonable steps” to reduce the risk of sexual harassment. From October 30, the law will state “all reasonable steps.” This means that doing a few things, like writing a policy to protect staff, won’t be enough. Employers will need to take more comprehensive action, which is why many are now taking advice from legal firms who deal in this area.
An additional measure in the new rules makes employers liable for harassment by third parties. Steps employers can take include:
- Publishing policies
- Handling reports and complaints about sexual harassment from customers or clients
- Carrying out risk assessments
Customers, clients, and patients are now included
Previously, employers were generally safe if customers, clients, or patients harassed their staff. Now, though, the regulatory situation has changed, and employees have recourse. Previously, the UK had a narrow rule on third-party harassment, but it was repealed in 2013.
New rules are simpler: employers cannot permit third parties to harass their employees. For example, workplaces can’t permit harassment if it happens during the course of a job, and they must take all reasonable steps to prevent it.
The term “third party” in the new law simply refers to anybody who is not the employer itself or a member of the staff team. Harassment under the Equality Act can take various forms, not just sexual harassment, but also harassment related to disability, race, or religion.
What this means in practice is that an employer’s responsibility doesn’t stop at the staff room door. Instead, it extends into the workplace and any situation in which an employee interacts with a client. For example, delivery drivers providing deliveries to households throughout the country are protected under the law. So too are care workers employed by care companies.
How common is the problem?
The law comes on the back of new research suggesting that harassment issues are significant. According to the Government Equalities Office’s 2020 Sexual Harassment Survey of more than 12,000 people, 29% of employees said they had experienced some sort of sexual harassment in a work-related setting in the previous 12 months. Women and men were affected at similar rates: 30% and 27%, respectively.
Interestingly, around 14% of people who said they’d been harassed at work said the person harassing them wasn’t an employee. In many cases, it was customers, clients, or patients. 9% said they had been harassed when visiting customers or clients.
According to the survey, the majority of harassment goes unreported. Only around 15% of people who had experienced harassment said that they made an official report. The vast majority said that the harassment itself didn’t seem serious enough for them, or they were worried that reporting it might damage their career.
How this fits in with ESG policies
Harassment has been a significant issue in conversations about how people are treated at work ever since the #MeToo movement went viral in 2017. It’s also in companies’ interests to make sure they deal with harassment issues at source. Workplaces where staff are frequently subjected to unpleasant behaviour by patients, customers, and clients often have higher turnover and bigger recruiting costs.
The new law aims to change the situation in the workplace. Employers now have to take all reasonable steps to protect their people and prevent sexual harassment from becoming a reason for them to be driven out of the firm.
“One of the biggest problems that many workers face is knowing whether what happened to them counts under the law. Sometimes it’s not clear what constitutes harassment, what doesn’t, and when employers are responsible for preventing it. That’s why it’s critical for everybody to get as much legal advice as they can,” says Grapple Law.
Law firms across the UK are giving people advice about how to deal with harassment and discrimination in the workplace. Many online tools can help people understand their position early on, even if they cannot directly judge whether someone broke the law.
The government is still to release the list of steps that it sees as reasonable, so employers are being encouraged to take action early to put systems in place, depending on what ministers decide. For public-facing businesses like bars and restaurants, the changes will be the most significant. These companies will need to think carefully about how they deal with harassment in the workplace and the policies they put in place from October 30.
Editor’s Note: The opinions expressed here by the authors are their own, not those of impakter.com
