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Global Guide

Littler Global Guide – United Kingdom – Q3 2025

The Global Guide Quarterly is designed to provide high-level coverage of recent labour and employment law developments.

By Caroline Baker, Ben Smith, Natasha Somi, Ben Rouse and Dilshen Dahanayake

Potential Reform of Non-Compete Clauses

Proposed Bill or Initiative

Author: Natasha Somi, Associate

The UK Government has signalled a renewed focus on reforming non-compete clauses in employment contracts due to concerns about their impact on worker mobility and economic competition. On July 21, 2025, during public debates, it was confirmed that a consultation on potential reforms will be conducted “in due course.”

Details of the consultation have yet to be released, but its outcome could lead to changes in the regulation of non-compete clauses in the UK.


Government Announces Review of Parental Leave and Pay

Proposed Bill or Initiative

Author: Ben Rouse, Associate

In July 2025, the UK Government launched a review of all current and upcoming statutory parental leave and pay in Great Britain. The Government’s current stated objectives for the parental leave and pay system are to: (a) support the maternal health of women during pregnancy and post-partum; (b) support economic growth through labour market participation; (c) ensure adequate resources and leave for parents to facilitate the best start in life for babies and young children; and (d) support parents to make balanced childcare choices.

The request for information closed on August 25, 2025, however the review is expected to run for 18 months until the end of 2026. We therefore do not expect to know the details of any concrete changes until 2027.


Employment Rights Bill Moves Closer to Becoming Law; Implementation Timeline Published

Proposed Bill or Initiative

Author: Ben Smith, Senior Associate

The Employment Rights Bill, setting out significant changes to UK employment law, is expected to become law in November. The government’s roadmap to implementing the Bill, published in July, indicates that changes to the bill are expected to go into effect in stages in April 2026, October 2026, and 2027, with many of the more significant changes not expected until 2027, including the introduction of protection from unfair dismissal from the first day of employment and restrictions on the use of zero-hour contracts. Some changes to union laws will go into effect immediately once the Bill receives Royal Assent, or within two months thereafter.

The government is expected to consult on regulations and guidance that will add further detail to the Bill’s reforms over the next 12 to 18 months.


Non-financial Misconduct Rules Updated by the Financial Services Regulator

Proposed Bill or Initiative

Author: Caroline Baker, Partner

In the summer, one of the UK’s financial services regulators, the Financial Conduct Authority (FCA) consulted on its proposed changes to its handbook and guidance to help better address non-financial misconduct (NFM) in financial services, including the introduction of a new anti-harassment rule. The consultation is now closed, with final rules expected to be published later this year.

The new rules and guidance are expected to apply to financial services businesses other than banks beginning September 1, 2026. Financial services firms affected by the new NFM rules, will likely need to review contracts and policies and train staff on the final rules ahead of implementation. The rules will also impact employment investigations and decisions and therefore it will become even more important to think through all potential regulatory angles when making employment decisions that potentially touch on NFM.


Two Key Compliance Dates: New Corporate Offense of Failure to Prevent Fraud and New Restrictions on Non-Disclosure Agreements

Proposed Bill or Initiative

Author: Dilshen Dahanayake, Associate

On September 1, 2025, the new corporate criminal offense of “failure to prevent fraud” went into effect under the Economic Crime and Corporate Transparency Act 2023. The rules are complex in application, but there is a defence if the organisation can demonstrate it had reasonable fraud prevention procedures in place. Although largely a compliance matter, HR policies and procedures may be impacted. The government has published guidance to help organizations.

On October 1, 2025, Section 17 of the Victims and Prisoners Act 2024 went into effect. As a result, any provision in an agreement—such as non-disclosure clauses or agreements—that seeks to prevent a victim, or someone who reasonably believes they are a victim, from disclosing information about criminal conduct to certain persons, including law enforcement, lawyers, and certain family members, is void. Employers may wish to review their NDA drafting and practices. The government has also published non-statutory guidance.

Authors:

Caroline Baker

Partner

London

Ben Smith
Ben Smith

Senior Associate

London

Ben Rouse
Ben Rouse

Associate

London

Dilshen Dahanayake
Dilshen Dahanayake

Associate

London

Natasha Somi
Natasha Somi

Associate

London

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