The Government is taking a phased approach to implementation of its Plan to Make Work Pay, which we explain in more detail below:
1. Employment Rights Bill
Described as phase one, the Employment Rights Bill was introduced on 10 October 2024 and is now making its way through Parliament with significant amendments being made along the way. Targeted consultations took place in October 2024 on some of the details of reforms in the Employment Rights Bill, and responses were published on 4 March 2025 (see here). Amendments have been made to the Employment Rights Bill to account for these consultation responses and additional reforms have also been introduced during its passage. Consequently, the Employment Rights Bill has now doubled in size since its first iteration.
The Employment Rights Bill has completed its stages in the House of Commons and has passed to the House of Lords. It will likely then be sent back and forth between the Houses as any disagreements on the final wording are resolved. This is known as ping-pong. Only once the Employment Rights Bill is agreed by both Houses, will it become law. It is anticipated that it will pass by Summer 2025.
The Employment Rights Bill, however, for many reforms 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 anticipated.
Overall, the Government anticipates that most reforms in the Employment Rights Bill will take effect no earlier than 2026, with reforms to unfair dismissal no sooner than Autumn 2026.
There will, however, be some reforms in the Employment Rights Bill that will come into force earlier than this, such as:
- the repeal of the Strikes (Minimum Service Levels) Act 2023, which is currently set to come into effect as soon as the Employment Rights Bill is passed; and
- the repeal and replacement of certain provisions of the Trade Union Act 2016, which are currently set to apply from two months after the Employment Rights Bill passes.
2. 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 the amendments to National Minimum Wage in April 2025. 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.
3. 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.
On 18 March 2025, the Government published a consultation on mandatory ethnicity and disability pay gap reporting open until 10 June 2025. In addition, a call for evidence was opened on 7 April and closes on 30 June 2025, seeking 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 are therefore still very uncertain, but one could anticipate that it would take a bit of time after the consultations to reconsider any bill drafting, before the Equality (Race and Disability) Bill is introduced in draft and before it makes its way through Parliament to become law. We anticipate, therefore, that these reforms will be more likely to be introduced later, for example into 2026/27.
4. Other longer term reforms
There will also be longer-term reforms (such as a review of worker status), 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.
We have created the below table, colour coded as to when headline employment policies, based on their priority in the reform agenda, are likely to be introduced.
We don’t have full implementation timelines yet but will keep this updated as this becomes clearer.
At a glance
- Red – High priority policy. Set out in the Employment Rights Bill, or a separate policy where early steps are already being taken, indicating it is high up the agenda. Those in the Employment Rights Bill are bold.
- Amber – Medium to high priority. Confirmed as either in the Equality (Race and Disability) Bill or via other means.
- Green – Lower priority. Subject to a longer-term review or consultation as per the Next Steps document.
