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
The Employment Rights Bill was considered phase one of the Government’s Plan to Make Work Pay. The Employment Rights Bill received Royal Assent on 18 December 2025 to become the ERA 2025.
Apart from some early trade union measures which came or will come 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 and the Government published a roadmap to implementation back in July 2025, setting out the proposed phased implementation timings and a planned programme of consultations. The Government has indicated it intends to maintain its implementation timeline (save where it has stated publicly otherwise), although the consultation timeline seems to have been delayed.
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 roadmap, modified as developments come through 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, for example later in 2026/27.
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 roadmap, modified as developments come through (for example where commencement regulations have been published) 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.
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, 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 |
| April 2026 | – Collective redundancy protective award being doubled – ‘Day 1’ rights to paternity leave and unpaid parental leave – Whistleblowing protections – Fair Work Agency body established (although unclear if enforcement powers will come into force immediately) – Statutory Sick Pay – Trade union changes: simplifying trade union recognition process and electronic and workplace balloting – Gender pay gap and menopause action plans on a voluntary basis (mandatory from 2027) |
| October 2026 | – Fire and rehire/ fire and replace restrictions – Duty to prevent sexual harassment – increasing to “all reasonable steps” – Introducing employer liability for third party harassment – Employment tribunal time limits increasing from 3 to 6 months – Trade union changes, including: 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, extending protections against detriments for taking industrial action (note that the relevant provisions come into force on 18 February 2026 but require regulations setting out the “prescribed detriments”, which is anticipated later following consultation) and other public sector specific changes – Tightening tipping law – Procurement – two tier workforce code (public sector) |
| In 2027 | – Unfair dismissal changes – reduction in qualifying period and removal of compensation cap (assuming changes come into together, currently anticipated 1 January 2027) – Gender pay gap and menopause action plans (mandatory) – Enhanced dismissal protections for pregnant women and new mothers – 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: strengthened blacklisting rules and industrial relations framework – Regulation of umbrella companies – Collective redundancy – collective consultation threshold changes – Flexible working changes – Bereavement leave – Restrictions on zero hours contracts and applying the measures to agency workers |
| 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 or to children working on heritage railways under the ERA 2025 which is outside the scope of this hub.