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 received Royal Assent on 18 December 2025. It sets the legal framework for reforms, but much of the practical detail – including how and when the changes will apply – is continuing to be developed through secondary legislation, codes of practice and guidance. Some of that detail has now been confirmed, but further regulations and guidance are still awaited in a number of areas.
The Government is bringing measures into force in phases and has published an implementation timeline for when key reforms are expected to take effect. The timeline focuses mainly on the changes expected in 2026, while explaining that the Government will continue to work towards the roadmap for measures expected in 2027. Timings will be kept subject to review as the Government consultation and policy development continues.
The position will therefore continue to evolve as further regulations, consultation responses and guidance are published.
Timings below and in this hub are based on the current Government timeline and commencement regulations available to date. We will continue to monitor developments and update the hub as the position becomes clearer.
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 Wage. 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 have been promised via a Equality (Race and Disability) Bill. See the Pay Gap Reporting and Equal Pay sections for further information.
Timings for implementation for these reforms are 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 (such as a review of parental leave and pay and accompanying call for evidence and a consultation on carer’s leave and support for parents of seriously ill children). The review of worker and employment status was anticipated by the end of 2025 (but this is still awaited).
At a glance
Below is a high-level overview of implementation timings for the key reforms in the ERA 2025* based on the Government’s updated timeline and commencement regulations (where available). The Government recently updated its timeline on 16 July 2026 to capture measures that will take effect from 6 April 2026 onwards. The below timeline has been updated to reflect this. We will also continue to monitor developments and update the hub for changes.
The timeline below also includes the longer-term reforms anticipated outside of the ERA 2025 (e.g. potentially via a proposed Equality (Race and Disability) Bill).
Please refer to the relevant sections in the Reform Hub for more detail on timings. 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 – Requirement to keep adequate records to demonstrate compliance with annual leave and pay requirements |
| 7 April 2026 | – Fair Work Agency body established (some powers due to take effect immediately and others expected in phases) |
| By 31 August 2026 | – Electronic and workplace balloting for Statutory Trade Union Ballots |
| 1 October 2026 | – Employment tribunal time limits increasing from 3 to 6 months – for breach of employment contract claims in Scotland this change will take place on 9 November 2026 |
| 30 October 2026 | – Trade union measures, 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 and “all remaining trade union recognition measures” new rights and protections for trade union representatives and extending protections against detriments for taking industrial action – Employer duty to prevent sexual harassment – increasing to “all reasonable steps” – Introducing an obligation on employers not to permit harassment by third parties – Introducing a power that will enable the minister to make regulations at a later date specifying employer steps to prevent sexual harassment |
| October 2026 (Unspecified) | – Bringing forward regulations to establish the Fair Pay Agreement Adult Social Care Negotiating Body in England – Procurement – two tier workforce code (public sector) |
| By the End of 2026 | – Strengthening tipping law (this was previously anticipated in October 2026) |
| January 2027 | – Reduction of unfair dismissal qualifying period to 6 months, for dismissals where the effective date of termination falls on or after 1 January 2027 and uncapping comepnsatory 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 – 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 (the timeline notes that timings will be updated after consultation) – Electronic and workplace balloting for recognition and derecognition ballots – Restrictions on NDAs for allegations or disclosures of relevant harassment or discrimination |
| Other reforms in ERA 2025 but timings unknown | – 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 anticipated in a draft Equality (Race & Disability) Bill, including extending pay gap reporting to ethnicity and disability, making the right to equal pay effective for race and disability and promoting pay equality in contractual arrangements (e.g. to outsourcing arrangements), establishing an Equal Pay Regulatory and Enforcement Unit, pay transparency measures and more – 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? – Potential intervention in respect of workplace monitoring technologies (which may include a new legislative requirement for employers to consult and negotiate with unions or elected representatives before introducing workplace monitoring technologies) |
*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.