Government publishes timeline for employment law reform

As the Employment Rights Bill (ERB) nears the end of its passage through Parliament, the government has published “Implementing the Employment Rights Bill: Our roadmap for delivering change” (the Roadmap) setting out its planned schedule for employment law reform.

In the Roadmap, the government sets out what it refers to as a ‘phased approach’ towards implementing the reforms set out in the ERB. It recognises the importance of consultation with stakeholders on the likely impact of the reforms, that further guidance will be needed, and that everyone will need time to familiarise themselves with the changes before they take effect (particularly smaller businesses).

The government also commits to providing additional support to organisations such as Acas, the employment tribunal and the new Fair Work Agency to ensure that they have enough capacity to enforce the reforms (although it is not yet clear how such support will be implemented).

Key points to note

A full list of the government’s anticipated schedule of consultation and implementation dates are set out in the tables below. Key points to note are as follows:

Reforms to statutory sick pay are scheduled to take effect in April 2026, with paternity leave and unpaid parental leave also scheduled to become ‘day one’ rights from then onwards. Employers will therefore need to start reviewing their payroll processes and HR systems as a priority.
The government does not intend to implement the unfair dismissal reforms in the ERB until 2027. Presumably this is so that details of the new statutory probationary period and ‘lighter touch’ dismissal process can be ironed out, and employers will have time to familiarise themselves with the new rules and prepare accordingly.
The increase to the protective award for failure to collectively consult is scheduled to take effect in April 2026. However, associated reforms including changes to the law on ‘fire and rehire’ and the threshold for collective consultation are being delayed until 2026 and 2027 respectively.
The extension to time limits for tribunal claims is not scheduled until October 2026. As this reform is likely to result in an increased number of claims (in an already stretched tribunal system), the later implementation date may be to allow for additional support to be set up for tribunals in advance.
The government is not proposing to introduce the changes to arrangements for zero and low hours workers until 2027, with consultation on those proposals taking place this year. This is perhaps unsurprising given the complexity of the reforms, the level of detail still to be finalised, and the impact they are likely to have on existing employer processes and systems.

Planned consultations

In the Roadmap, the government confirms its intention to use consultations to inform future regulations, guidance notes and/or codes of practice. The consultations are all due to start this year, as follows:

Summer/Autumn 2025	Reinstating the School Support Staff Negotiating Body Fair Pay Agreement for Adult Social Care sector ‘Day one’ unfair dismissal protection (including the dismissal process in the statutory probation period)
Autumn 2025	Trade union measures, including electronic and workplace balloting, simplifying trade union recognition processes, duty to inform workers of their right to join a 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 Ending the ‘exploitative use’ of zero hours contracts
Winter 2025	Trade union measures, including protection against detriments for taking industrial action and blacklisting Tipping law Collective redundancy Flexible working

Anticipated implementation dates

The Roadmap confirms that the government intends to use information gathered during the consultation process to assess implementation dates. The following is therefore the government’s initial view on a likely schedule and may be subject to change:

As soon as Employment Rights Bill receives Royal Assent (anticipated to be Autumn 2025) or shortly afterwards	Repeal of the Strikes (Minimum Service Levels) Act 2023 Repeal of the majority of the Trade Union Act 2016 Removal of 10-year ballot requirement for trade union political funds Simplifying industrial action notices and industrial action ballot notices Protection against dismissal for taking industrial action
April 2026	Increase to collective redundancy protective award ‘Day one’ right to paternity leave and unpaid parental leave Whistleblowing protections Reform to statutory sick pay Simplifying the trade union recognition process Electronic and workplace balloting
October 2026	Fire and re-hire Regulations to establish the Fair Pay Agreement Adult Social Care Negotiating Body Procurement – 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 Introduction of obligation on employers not to permit the harassment of their employees by third parties New rights and protections for trade union representatives Employment tribunal time limits Extending protections against detriments for taking industrial action
2027	Gender pay gap and menopause action plans (these will be introduced on a voluntary basis in April 2026) Rights for pregnant workers Introducing a power to enable regulations to specify steps that are regarded to be ‘reasonable’ to determine whether an employer has taken all reasonable steps to prevent sexual harassment Blacklisting Industrials relations framework Regulation of umbrella companies Collective redundancy consultation threshold Flexible working Bereavement leave Ending the ‘exploitative use’ of zero hours contracts and applying the new measures to agency workers ‘Day one’ unfair dismissal right

TLT thoughts

As anticipated, aside from the trade union changes that take place shortly after the ERB becomes law, the government’s reforms are largely timetabled for 2026 and beyond.

Although the detail of many of the reforms is still to be established, the Roadmap will be welcome news for many employers, reducing some level of uncertainty and giving them more scope to outline plans for any changes to the workforce and HR systems / processes over the next couple of years. It will also be reassuring for employers (particularly those operating smaller businesses) that the government is planning to provide guidance and allow time for the new rules to be digested and understood before they are implemented.

As this year progresses, we should also start to see glimpses of the proposed detail for some of the key reforms (such as those relating to unfair dismissal) as consultation documents are published. We will keep you updated, and please do reach out to your TLT contact if you have any questions at this stage or if you want to discuss the potential impact of the above schedule on your workforce planning.

Further resources on upcoming employment law reform, including the Employment Rights Bill, can be found on our Employment Law Reform – In Focus page.

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at 3 July 2025. Specific advice should be sought for specific cases. For more information see our terms & conditions.

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