On 22 October 2026, the Government updated its anticipated implementation timeline for the Employment Rights Act 2025 (‘ERA 2025’), providing more detail on when the upcoming 2027 reforms are expected to take effect.
Key Dates
The revised key dates for 2027 are summarised below, however the majority of these remain subject to parliamentary processes and may, therefore, still be subject to further change.
| 1 January 2027 | – The qualifying period for ordinary unfair dismissal claims reduces from two years to six months and the compensatory award cap is removed (for dismissals where the effective date of termination falls on or after 1 January 2027) – New duty to inform workers of their right to join a trade union (previously anticipated on 30 October 2026) – Strengthened tipping laws |
| March 2027 | – Fire and rehire/replace protections (previously expected in January 2027 now postponed to March 2027) – Action plans on gender equality and supporting employees through the menopause (mandatory for public authorities in line with the pay gap reporting cycle for public authorities) |
| April 2027 | – Action plans on gender equality and supporting employees through the menopause (mandatory for private and voluntary sector employers in line with the pay gap reporting cycle for private and voluntary sector employers) – New organisation-wide threshold for collective redundancy obligations – New statutory entitlement to bereavement leave, including pregnancy loss – Extended trade union blacklisting provisions – banning blacklists drafted using AI and blacklisting by third parties |
| August 2027 | – Electronic balloting for statutory trade union recognition and derecognition ballots |
| September 2027 | – Regulations to restrict the use of non-disclosure agreements for allegations or disclosures of relevant harassment or discrimination |
| October 2027 | – Enhanced dismissal protections for pregnant women, new mothers and certain other types of family leave – Flexible working changes |
| December 2027 | – Regulation of umbrella companies |
| Timing to be confirmed | – Zero-hours contract reforms (previously expected sometime in 2027) |
Notably, the fire and rehire/replace restrictions, which were previously expected to take effect from 1 January 2027, have been pushed to March 2027. This delay may be linked to the Government’s recently launched consultation on a revised Code of Practice on dismissal and re-engagement, which runs until 17 December 2026. The revised Code of Practice is not expected to take effect until Summer 2027, seemingly after the anticipated implementation date for the substantive ERA 2025 fire and rehire reforms in March.
Another notable change is the lack of anticipated implementation date for the zero-hours contracts reforms. The Government’s updated timeline notes that timings for the introduction of the right to guaranteed hours, the right to reasonable notice and payment for shifts cancelled or changed at short notice will be updated following the consultation process.
In addition, the reforms in respect of public sector outsourcing had previously been expected in October 2026, however the updated implementation timetable no longer includes an anticipated date for this reform to take effect.
Recent Consultation Updates
The Government has also been busy this month publishing a number of new consultations and consultation responses. These include new consultations on employment status, the whistleblowing framework and a new Code of Practice on dismissal and re-engagement, alongside responses on the ERA 2025 reforms for enhanced dismissal protections for pregnant women and new mothers, and the proposed restrictions on contractual variations to expenses, benefits and shifts as part of the fire and rehire reforms.
Please visit our Reform Hub, which is regularly updated for the latest developments and look out for our further articles.
Don’t Forget: Changes Coming on 30 October 2026
Employers should also ensure they are prepared for the tranche of changes coming in on 30 October 2026. These include an enhanced duty on employers to take all reasonable steps to prevent sexual harassment, introduction of liability for third-party harassment, and new trade union rights, including significant new rights of access for trade unions. See our previous articles here, here and here for further information.
Please contact your usual Littler contact if you would like any support with preparing your business for the upcoming changes.
