From 30 October 2026, employers must take all reasonable steps to prevent sexual harassment at work. Not some steps. Not the obvious ones. All of them.
The Worker Protection (Amendment of Equality Act 2010) Act 2023 introduced a legal duty for employers to take proactive steps to prevent sexual harassment, which came into force in October 2024. The Employment Rights Act 2025 now raises that bar. One small word, “all”, makes a big difference to what is expected of you.
That means compliance is not just having a policy or saying training already exists. Employers need to show what they have done, how they have assessed risk, how people have been trained, and how prevention is reinforced in practice.
If challenged, the question will be simple: can you evidence that your organisation took prevention seriously before an issue arose?
What changes on 30 October 2026
Three things matter most for SME owners.
- The bar rises. ACAS guidance is clear that “all reasonable steps” means taking every step that is reasonable for your organisation, not just a selection. A tribunal will effectively ask: was there anything more you could reasonably have done?
- Third parties come into scope. You must also take all reasonable steps to prevent your employees being harassed by clients, customers, contractors and members of the public. If your people face the public, this is a real and present risk. Shared office space becomes a real risk!
- Evidence becomes everything. Good intentions do not count for much without a paper trail. Risk assessments, policy acknowledgements, training records and follow-up actions are what demonstrate prevention.
There is a financial edge too. Where a sexual harassment claim succeeds and the employer has not met the prevention duty, compensation can be increased by up to 25%.
Why a policy in a drawer will not cut it
Many SMEs have an anti-harassment policy. Fewer can show that anyone has read it, understood it, or knows what to do when something goes wrong.
We see the same gaps time and again:
- A policy written years ago that does not mention third-party harassment
- Training delivered once at induction and never refreshed
- Managers who would not recognise the warning signs, or would not know how to respond to a complaint
- One reporting route, usually straight to a line manager, which may be the very person involved
- No risk assessment, and no record of what has been done
Harassment is judged on its effect on the recipient, not the intention behind it. “It was only banter” is not a defence. That is exactly why your people need to understand where the line sits, and why your managers need the confidence to step in early.
Employers are making progress on policies, training and reporting. The next challenge is embedding prevention so it holds up under scrutiny.
Where training fits
Training is one of the clearest, most visible reasonable steps an employer can take. ACAS guidance points to mandatory sexual harassment training as part of what good prevention looks like.
But not all training carries equal weight. A generic video clicked through in ten minutes is hard to defend as “all reasonable steps”. Training that stands up to scrutiny is:
- Relevant to your workplace, your sector and the real risks your people face
- Role-specific, so managers learn how to spot, respond to and escalate concerns, not just what harassment is
- Refreshed regularly, not a one-off tick box at induction
- Recorded, with attendance, completion and certificates you can produce if asked
- Connected to your policy, your reporting routes and your risk assessment
Get those five right and training becomes part of your evidence, not just an item on the to-do list.
How HRCentral training helps you evidence prevention
Our Sexual Harassment Prevention training is built for SMEs that want to get this right, not just tick a box. It is practical, interactive and grounded in the reality of your workplace.
We deliver it in person at your premises or through our online learning platform, Improve LMS, so every employee can complete it, wherever and however they work.
Highlights include:
- What sexual harassment really looks like, including the less obvious forms that catch people out
- Why intention is not the test, and where “banter” crosses the line
- Harassment beyond the office, from work socials to WhatsApp groups and social media
- Third-party harassment and what it means for public-facing teams
- What “all reasonable steps” looks like in practice for your organisation
- Practical exercises that turn the learning into actions for your business
Every in-person session comes with workbooks and certificates. For clients using Breathe HR, we update your training matrix so your records are ready if you ever need them.
We also tailor content to your sector and your people. A hospitality team faces different risks to a construction site or an accountancy practice, and your training should reflect that.
Training is the start, not the finish
“All reasonable steps” goes beyond one course. Because we are an HR consultancy as well as a training provider, we can help you join up the whole picture:
- Risk assessments that identify where harassment could happen, including from third parties
- Policy reviews so your anti-harassment policy is current and covers third-party harassment
- Reporting routes that give people more than one way to raise a concern, including anonymously
- Manager coaching so your leaders handle complaints calmly, fairly and properly
- Engagement surveys through WeThrive to understand your culture and spot warning signs early
And because we charge by the hour, with no retainers, you only pay for the support you actually need.
Ready to evidence prevention?
The sooner your people are trained, the sooner you have the evidence to show for it.
Talk to us about Sexual Harassment Prevention training for your team. Email enquiries@hrcentral.co.uk or call 0118 324 2526, and we will build a plan that fits your business.
This article is HR best practice guidance, not legal advice. If you are facing a specific claim or legal question, speak to an employment solicitor. We work closely with a number of lawyers and are happy to make an introduction.
