The Government is taking a phased approach to implementation of its Plan to Make Work Pay, which we explain in more detail below.
ERA 2025
Described as phase one of the Plan to Make Work Pay, the ERA 2025 completed its final stages in Parliament on 16 December 2025 and received Royal Assent on 18 December 2025.
Apart from some early trade union measures which came into effect automatically under the ERA 2025, the majority of measures will need to be brought into force by commencement regulations. Also, for many reforms, the ERA 2025, simply provides the framework. Much of the detail is still to be fleshed out by secondary legislation, codes of practice and guidance. Consultations to inform this detail are also underway with more anticipated soon.
Changes under the ERA 2025 are set to take effect in phases. The Government published previously a roadmap to implementation back in July 2025 (including a planned programme of consultations). This has now been superseded by an updated timeline setting out when measures will take effect. The timeline states that it focuses on the changes being introduced in 2026 and that the Government will continue to work towards the timetable set out in the roadmap for measures being introduced throughout 2027. It also notes that the timings will continue to be kept under review as the Government consultants and develops the details of policies.
Therefore, details of reforms and their implementation timings will become clearer (and more certain) as regulations and further guidance are published. Timings below and in this hub are based on the new timeline, and we will continue to monitor developments and update the hub for changes.
Reforms using existing powers or other means
Some reforms are to be delivered outside of the ERA 2025 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, rumours are that this may have been 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 given that there is still no timing set for introduction of the bill.
Other longer-term reforms
There will also be longer-term reforms (such as a review of worker status and the 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 was anticipated by the end of 2025 (but this is still awaited).
At a glance
We set out below a high-level overview of anticipated timings for implementation of the key reforms in the ERA 2025*. Timings are based on the Government’s updated published timeline (published on 3 February 2026), and we will continue to monitor developments and update the hub for changes.
The Government has said that for most reforms it intends to use common commencement dates of 6 April and 1 October, which is largely reflected in the updated timeline.
The timeline below also includes the longer-term reforms anticipated via the draft Equality (Race and Disability) Bill and by other means.
Please refer to the specific reform in the Reform Hub for more detail on timings for each key reform. Note also that there are some transitional provisions or complexities in certain areas as to how and when the reforms will operate which is not reflected in the below summary.
| Implementation Timing | Reforms |
| 18 December 2025 | Repeal of Strikes (Minimum Service Levels) Act 2023 |
| 6 January 2026 | Repeal of the Workers (Predictable Terms and Conditions) Act 2023 (never been brought into force) |
| 18 February 2026 | Trade union changes, including: – Repeal of the great majority of the Trade Union Act 2016 and including but not limited to removal of the support thresholds for industrial action ballots in important public services and simplifying industrial action notices and industrial action ballot notices – Strengthened protections against dismissal for taking industrial action – Employees that are newly eligible for ‘Day 1’ Paternity Leave and Unpaid Parental Leave can give notice (see 6 April 2026 below) |
| 6 April 2026 | – Collective redundancy protective award being doubled – ‘Day 1’ rights to paternity leave and unpaid parental leave – Whistleblowing protections (sexual harassment) – Bereaved Partner’s Paternity Leave (this is a non ‘Plan to Make Work Pay’ measure but has been added) – Statutory Sick Pay – removing the Lower Earning Limit and waiting period – Action plans on gender equality and supporting employees through the menopause on a voluntary basis (mandatory from 2027) – Menopause guidance – Simplifying trade union recognition process |
| 7 April 2026 | – Fair Work Agency body established (phased implementation likely, with details to be published in due course) |
| August 2026 | – Electronic and workplace balloting for Statutory Trade Union Ballots |
| October 2026 | – Employer duty to prevent sexual harassment – increasing to “all reasonable steps” – 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 (but note 2027 below) – Introducing an obligation on employers not to permit harassment by third parties – Employment tribunal time limits increasing from 3 to 6 months (note the Government’s published timeline currently indicates this will be “no earlier than October 2026“) – Trade union changes, including: duty to inform workers of their right to join a trade union, strengthening trade unions’ right of access, unfair practices in the trade union recognition process, new rights and protections for trade union representatives, extending protections against detriments for taking industrial action (note that the relevant provisions came into force on 18 February 2026 but require regulations setting out the “prescribed detriments”, which is anticipated later following a consultation which opened in February 2026) and bringing forward regulations to establish the Fair Pay Agreement Adult Social Care Negotiating Body in England – Tightening tipping law – Procurement – two tier workforce code (public sector) |
| January 2027 | – Reduction of unfair dismissal qualifying period to 6 months, for dismissals from 1 January 2027, and uncapping compensatory awards – Fire and rehire protections |
| In 2027 | – Action plans on gender equality and supporting employees through the menopause (mandatory) – Enhanced dismissal protections for pregnant women and new mothers – Specifying 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: extending blacklisting protections and industrial relations framework – Regulation of umbrella companies – Collective redundancy – collective consultation threshold changes – Flexible working changes – Bereavement leave (including pregnancy loss) – Restrictions on the use of zero hours contracts – Electronic and workplace balloting for recognition and derecognition ballots |
| Other reforms in ERA 2025 but timings unknown | – Requirement to keep adequate annual leave records – Restrictions on NDAs for allegations or disclosures of relevant harassment or discrimination – Potential changes to time off for public duties (subject to a review under the ERA 2025) |
| 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 was anticipated by the end of 2025 but is awaited) – Right to switch off? |
*Note: this hub does not include the changes in respect of seafarers, ships’ crews, health and safety, Certification Officer levies or to children working on heritage railways under the ERA 2025 which is outside the scope of this hub. There are also other pay and tax related changes which are excluded from this timeline.