Timings

The Government is taking a phased approach to implementation of its Plan to Make Work Pay, which we explain in more detail below.

Employment Rights Bill

Described as phase one, the Employment Rights Bill was introduced on 10 October 2024 and has been making its way through Parliament, with significant amendments being made along the way. Consequently, the Employment Rights Bill has now doubled in size since its first iteration.

The Employment Rights Bill is now in its final stages and is expected to pass very soon and go on to receive Royal Assent to become law – we are anticipating that this could be sometime towards the end of December 2025 – but we await developments.

For many reforms, however, the Employment Rights Bill, simply provides the framework. Much of the detail is still to be fleshed out by secondary legislation, codes of practice and guidance. Further consultations on this detail are also underway with more anticipated soon (the Government recently suggested 26 more consultations are anticipated after the Employment Rights Bill becomes law). The Government has published a roadmap to implementation, which sets out the proposed initial timings for the policy measures in the Employment Rights Bill and has indicated it wishes to keep to this delivery timeline.

Reforms using existing powers or other means

Some reforms can be delivered outside of the Employment Rights Bill using existing powers or other means such as amendments to National Minimum Wages. The right to switch off was also promised to be introduced via a Code of Practice. Although not formally confirmed by the Government, current rumours are that this may be being dropped or pushed significantly down the Government’s agenda.

Equality (Race and Disability) Bill

Other reforms will be contained in the Equality (Race and Disability) Bill, such as extending pay gap reporting and equal pay to ethnicity and disability. The Government previously promised in its Next Steps document that this would be published in draft during the 2024/25 Parliamentary Session but this is still awaited.

On 18 March 2025, the Government published a consultation on mandatory ethnicity and disability pay gap reporting, which closed on 10 June 2025. In addition, a call for evidence, which closed on 30 June 2025, sought views on making the right to equal pay effective for ethnic minority and disabled people and other areas of equality law. Responses to this will help shape this bill.

Timings for implementation for these reforms are therefore still uncertain, but we anticipate that these reforms will be more likely to be introduced later, for example into 2026/27.

Other longer-term reforms

There will also be longer-term reforms (such as a review of worker status and parental leave system), which the Government recognises will take longer to undertake and implement and will require a further review or call to evidence, with any changes to the law to follow. The first of these has commenced with a review of parental leave and pay and accompanying call for evidence launched on 1 July 2025. The review is set to run for 18 months after which a roadmap for implementation is promised. The review of worker and employment status is anticipated by the end of 2025.

Timing	Reforms
When the Employment Rights Bill passes (Royal Assent) or soon afterwards	Union changes: – Repeal of Strikes (Minimum Service Levels) Act 2023 – Repeal of the great majority of the Trade Union Act 2016 (some provisions will be repealed via commencement order at a later date) – Other trade union changes including, removing the 10 year ballot requirement for trade union political funds, simplifying industrial action notices and industrial action ballot notices and protections against dismissal for taking industrial action
April 2026	– Collective redundancy protective award being doubled – ‘Day 1’ paternity leave and unpaid parental leave – Whistleblowing protections – Fair Work Agency body established – Statutory Sick Pay – Trade union changes: simplifying trade union recognition process and electronic and workplace balloting
October 2026	– Fire and rehire – Duty to prevent sexual harassment – increasing to “all reasonable steps” – Introducing third party harassment – Increasing employment tribunal time limits – Trade union changes: duty to inform workers of their right to join a trade union; strengthening trade unions’ right of access; new rights and protections for trade union reps, and extending protections against detriments for taking industrial action (among other public sector specific changes) – Tightening tipping law – Procurement – two tier code (public sector)
December 2026	Commencement of the Mandatory Seafarer’s Charter*
In 2027	– Gender pay gap and menopause action plans – Rights for pregnant workers – Introducing a power to enable regulations to specify steps that are to be regarded as “reasonable”, to determine whether an employer has taken all reasonable steps to prevent sexual harassment – Trade union changes: blacklisting; industrial relations framework – Regulation of umbrella companies – Collective redundancy – collective consultation threshold changes – Flexible working – Bereavement leave – Restrictions on zero hours contracts and applying the measures to agency workers – Unfair dismissal changes
Other reforms in the Plan to Make Work Pay – timing of which is unknown but given the early stages of policy development this is likely later, so 2027 and beyond	– Gender pay gaps – outsourcing measures – Wider equality law changes to be included in the draft Equality (Race & Disability) Bill, including extending pay gap reporting to ethnicity and disability, extending equal pay claims to race and disability and outsourcing of services, implementing a Regulatory Enforcement Unit for equal pay, dual discrimination and potentially pay transparency measures – Parental leave system review to complete by January 2027 with roadmap after to follow – Reviews of carer’s leave system, TUPE, worker and employment status and self-employment protections (a consultation for which is anticipated by the end of 2025) – Right to switch off – Health and safety (which is not covered in this Hub)

*Not covered in this hub