The UK Employment Rights Bill: The government unveils a roadmap for implementation

Why should I read this?

The Employment Rights Bill (“Bill”) includes over 28 employment reforms and, cumulatively, the scale, breadth and complexity of the changes are of great significance for all employers.  As the Bill moves through the final stages of parliament towards Royal Assent (“RA”) (more on this below), the government has unveiled a roadmap detailing an anticipated timetable for implementing the Bill’s key measures.

Although the government has been clear to date that the Bill will be implemented in stages, the roadmap is the first time the government has provided more detailed timescales for commencement. The roadmap also sets out an anticipated timetable for any necessary consultations on the detail of the measures to come. 

Below, we summarise what employers need to know about the government’s roadmap, and the steps they should take to prepare.

What do I need to know?

In high-level summary, the government’s “initial view” of anticipated implementation dates are as follows (for further information on the changes below, see our tracker):

• Immediately on RA or soon after: Measures commencing on RA include the repeal of minimum service levels in a strike situation and, two months after RA, the repeal of some industrial action laws (including reducing advance notice of industrial action from 14 to 10 days and extending the expiry of the ballot mandate from six to 12 months). Although RA had been anticipated this summer, it is now much more likely that it will take place in the autumn (given that parliament is due to rise for the summer in late July and there are a number of final stages to complete before the Bill is ready for RA). The roadmap does not confirm any anticipated date for RA.
• April 2026: Doubling of the maximum protective award period in a collective consultation situation; day-one paternity and unpaid parental leave; whistleblowing protections; establishing the Fair Work Agency (“FWA”); SSP changes; simplifying the trade union (“TU”) recognition process making it easier for TU’s to apply for and gain collective bargaining rights; and electronic and workplace balloting.
• October 2026: Introduction of further restrictions on the so called practice of “fire and rehire”; third-party harassment protections; duty to take “all” reasonable steps to prevent sexual harassment; extending employment tribunal limits; some TU changes including a right of access to workplaces for organising and TU recruitment purposes, a duty to inform workers of their right to join a union and new rights for TU reps; extending protections against detriments for taking industrial action; powers to establish a Fair Pay Agreement in the adult social care sector; procurement two-tier code; and strengthening tipping laws.
• 2027: The government has deferred a number of changes to 2027 (with no detail of exact dates). In many cases, this reflects the need for detailed consultation, new guidance and updates to any applicable statutory Codes of Practice. Such measures include: day-one unfair dismissal rights (previously expected no sooner than autumn 2026), collective redundancy consultation threshold changes; flexible working; gender pay gap and menopause action plans; bereavement leave; new zero and “low” hours worker rights; rights for pregnant workers; powers to confirm steps that are “reasonable” to comply with the above duty to prevent sexual harassment; blacklisting; industrial relations framework; and the regulation of umbrella companies.

Alongside the above implementation timetable, the government will begin to consult on the detail of some policies as soon as summer/autumn 2025 including but not limited to day-one unfair dismissal rights; some trade union reforms; fire and rehire; and new zero hours and low hours worker rights. Consultations planned for late 2025 and early 2026 include further trade union measures; collective redundancy; flexible working; and tipping.

Separately, a Draft Equality (Race and Disability) Bill (“ERDB”) is expected soon following a recent consultation and call for evidence (read our briefings here and here). The roadmap does not provide any further detail on the ERDB’s timings, other than to confirm that the implementation of related measures in the Bill on the gender pay gap and outsourced workers (see our tracker for details) will be dependent on the ERDB’s broader timescales.

What should I do now?

Employers should prioritise preparations for those measures anticipated to take effect in 2025 and early 2026, including:

• Updating family leave polices to reflect the new day-one rights to paternity and unpaid parental leave;
• Budgeting for increased SSP costs from April 2026 and reviewing sickness absence policies and manager training on short-term sickness absence, levels of which may rise as a result of the SSP changes;
• Undertaking a pay audit of workforce pay practices (including national minimum wage, SSP and holiday pay) to identify and address any inadvertent issues in advance of the establishment of the FWA (although a transitional period is expected while powers transfer to the FWA);
• Reviewing collective redundancy consultation processes given the planned increase to the maximum protective award period;
• Assessing contingency planning for industrial action, including preparing for situations where it will be simpler and quicker for a union to commence industrial action; and
• Anticipating an increase in TU recognition requests and reviewing engagement strategy, including assessing existing employee relations and identifying and addressing engagement concerns.

For longer-term measures, it remains important for employers to risk assess their current practices and plan well in advance given the scale of change. Employers will be keen to see further details emerge as various consultations commence shortly and run over 2025-26, to support their preparations. Employers, workers, trade unions and other stakeholders will be able to engage with the consultations and provide their views.

To keep up-to-date with the latest developments, please see our tracker and look out for details of our Employment Rights Act 2025 Conference, planned for the autumn.