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What sexual harassment training do UK employers need under the "all reasonable steps" duty?

By Bodhih Training Solutions, Bengaluru · Updated

The short answer

Since 26 October 2024, employers in Great Britain have had a legal duty to take reasonable steps to prevent sexual harassment of their workers. From 30 October 2026 the Employment Rights Act 2025 raises that to all reasonable steps and makes employers liable for harassment by third parties such as customers and clients. No law names a course, but training, risk assessment and records are how you show the steps you took.

What changed, and when?

The duty sits in the Equality Act 2010, which covers England, Scotland and Wales. Northern Ireland has its own equality law.

DateChange
26 October 2024Worker Protection (Amendment of Equality Act 2010) Act 2023: a duty to take reasonable steps to prevent sexual harassment. A tribunal can increase compensation by up to 25% where it was breached.
30 October 2026Employment Rights Act 2025: the duty becomes all reasonable steps.
30 October 2026Employers become liable where a third party harasses a worker in the course of employment and the employer did not take all reasonable steps to prevent it. This covers every kind of harassment, not only sexual harassment.
LaterThe Act lets ministers make regulations saying what counts as reasonable steps. Law firms expect these after the October 2026 changes.

What should harassment training cover now?

"All reasonable steps" is a high bar. A policy and a yearly slide deck are unlikely to be enough on their own. Build the training from your own risk assessment.

  • Everyone: what sexual harassment is, with examples from your own workplace, and how to report it.
  • Managers: how to respond to a report, how to step in early, and what not to do.
  • Customer-facing teams: what to do when a customer, client, patient or contractor harasses them, and how the employer will back them.
  • People who investigate: fair process, records and confidentiality.
  • New starters: before or soon after they start, not at the next annual cycle.

How do you show the steps you took?

If a claim is brought, you will be asked what you did before the incident. Keep the evidence in one place.

  • Assign the training automatically when someone joins, is promoted or changes site.
  • Set a due date and a refresher interval, and let reminders and escalations run.
  • Keep completion certificates with the date, the course name and the version of the policy it covered.
  • Send managers and HR a weekly report of who is overdue.
  • Keep the risk assessment, the policy and the training record together, so you can show what you did and when.

Can a ready-made workshop meet the duty?

Not by itself. The duty is about your workplace and your risks. Bodhih's Respect at Work trainer toolkit ($29) is a general anti-harassment and bullying workshop with a facilitator guide, slides, case studies and role plays, which a trainer adapts. Check it against the Equality and Human Rights Commission's guidance, add your own policy, reporting routes and third-party risks, and record who completed it.

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Common questions

Questions people ask next

Is harassment training a legal requirement in the UK?

The law requires all reasonable steps to prevent sexual harassment; it does not name a course. Training is one of the steps regulators and tribunals expect to see.

How often should employees be trained?

The law sets no interval. Many employers train at induction and refresh every year, and again after a policy change or an incident.

Does the duty cover harassment by customers?

Yes. From 30 October 2026 an employer can be liable for harassment of a worker by a third party if it did not take all reasonable steps to prevent it.

What happens if an employer breaches the duty?

A tribunal that upholds a sexual harassment claim can increase compensation by up to 25%, and the Equality and Human Rights Commission can take enforcement action.

Can Bodhih LMS track this training?

Yes. Use groups by site or role, automations for due dates and refreshers, and scheduled reports of who is overdue.

Is this legal advice?

No. It summarises public sources as of the date shown. Confirm with an employment solicitor.