From 1 October 2026, employers in Great Britain will be required to take all reasonable steps to prevent sexual harassment. This builds on the Worker Protection Act 2023, which introduced the current proactive duty on employers to take reasonable steps to prevent sexual harassment from October 2024.
This has been expanded by the Employment Rights Act to require all steps which are reasonable. The definition of reasonable has not changed, however. What was a reasonable step yesterday is still likely to be a reasonable step tomorrow. The difference is that employers will need to show they have taken all of the steps that were reasonable for their organisation, rather than only some of them.
There is no single checklist that will be right for every employer. What is reasonable for a law firm, a supermarket, a nightclub, a care provider, a factory, a charity or a fully remote business will not be identical. Size and budget can also be taken into account. A small firm is not expected to do as much as a large firm, but the decisions of what to do or not do should be recorded and justified.
The starting point should be a sexual harassment risk assessment. Employers need to understand where harassment could occur, who may be exposed, what situations increase the risk, and what controls are already in place. Once those risks are understood, the organisation can decide what further steps are reasonable.
The following examples below are not exhaustive. They show how “all reasonable steps” may look different in different working environments.
Listen again to our webinar on all reasonable steps to prevent sexual harassment.
Office staff
Reasonable steps may include:
- A clear sexual harassment policy
- Regular staff training
- Manager-specific training
- Guidance on workplace messaging platforms
- Clear reporting routes
- Bystander intervention training
- Reminders before office parties, conferences or away days
- Periodic staff surveys or culture checks
For office-based staff, the risks may include inappropriate comments, messages, workplace relationships, senior-junior dynamics, social events, business travel and online communication. A policy and annual training may be a starting point, but the employer should also consider whether managers know how to respond to concerns and whether employees trust the reporting routes.
Bystander intervention training can be particularly useful in office environments, where colleagues may witness inappropriate conduct in meetings, social settings or informal conversations. It helps staff understand when and how to intervene, report or support someone safely.
Home and hybrid workers
Reasonable steps may include:
- Training on digital harassment and online conduct
- Clear rules for Teams, Slack, email and private messaging
- Guidance on video calls and virtual meetings
- Regular manager check-ins
- Accessible reporting routes for remote staff
- Preservation of digital evidence
- Training managers to spot concerns remotely
Remote working does not remove the risk of sexual harassment. It changes where the risk appears. Harassment may happen through private messages, video meetings, social media, informal chat channels or late-night communications.
Employers should make clear that workplace standards apply in digital spaces. Remote staff should know how to report concerns, and managers should understand that warning signs may be less visible when people are not physically in the same workplace.
Staff who travel frequently for work
Reasonable steps may include:
- Travel-specific conduct guidance
- Pre-travel briefings
- Rules for client entertainment and alcohol
- Guidance on hotels, transport and late-night meetings
- Named escalation contacts
- Check-in arrangements for higher-risk travel
- Clear authority to leave unsafe situations
- Controls for third-party harassment by clients or suppliers
Business travel can create heightened risk because employees may be away from normal support structures, working late, attending events, staying in hotels or meeting third parties in less controlled settings.
Employers should include travel in the risk assessment. The aim is not to eliminate business travel, but to anticipate foreseeable risks and give staff clear support, expectations and escalation routes.
Work-related social events
Reasonable steps may include:
- Pre-event reminders about expected behaviour
- Clear alcohol management
- Manager briefing before the event
- Safe travel guidance
- Named reporting contact after the event
- Guidance on after-parties and informal continuation events
- Bystander intervention training
- Prompt follow-up if concerns are raised
Work-related social events are a common risk area. Even if an event takes place outside working hours or away from the office, it may still be connected to work.
Employers should not stop social events by default, but they should plan for foreseeable risks. Alcohol, senior-junior dynamics, travel, hotels and late-night settings can all increase exposure. Bystander intervention training can also help colleagues recognise when a situation is becoming uncomfortable and take safe, proportionate action.
Customer-facing staff
Reasonable steps may include:
- Policy wording covering third-party harassment
- Staff training on customer harassment
- Clear escalation scripts for managers
- Public notices setting expected behaviour
- Procedures for warning or banning customers
- Incident reporting forms
- Conflict-management training
- Supervision and rapid support routes
Customer-facing staff may face harassment from clients, customers, service users, patients, visitors or members of the public. From 1 October 2026, third-party harassment becomes an especially important compliance issue.
The employer should not treat this as unpredictable simply because the person behaving badly is outside the organisation. If customer contact is part of the job, the risk is foreseeable. Staff should know they will be supported if they report inappropriate conduct by a third party.
Hospitality staff
Reasonable steps may include:
- Clear customer behaviour standards
- Signage stating harassment of staff will not be tolerated
- Training on alcohol-related risk
- Manager escalation procedures
- Security arrangements where appropriate
- Buddy systems for closing shifts
- Procedures for removing customers
- Bystander intervention training for staff and supervisors
Hospitality environments can carry particular risks because of alcohol, late hours, customer interaction, physical proximity and pressure to maintain customer service standards.
Reasonable steps should be practical and operational. Staff should not be left to manage inappropriate customer behaviour alone. Managers should know when to intervene, when to remove a customer, and how to support staff after an incident.
Lone workers
Reasonable steps may include:
- Lone-working risk assessments
- Check-in and check-out procedures
- Panic alarms or safety apps where appropriate
- Buddy systems for higher-risk tasks
- Clear rules for home visits or off-site meetings
- Escalation contacts
- Training on boundaries and reporting
- Controls for third-party contact
Lone workers may be more vulnerable because there are no immediate colleagues nearby to witness or intervene. This can apply to delivery drivers, home visitors, maintenance staff, carers, consultants, security staff or employees visiting customer sites.
The employer should consider both prevention and rapid support. If an employee is working alone with a client, customer, service user or member of the public, the risk assessment should identify how they can get help quickly and how concerns will be reported afterwards.
Night shift workers
Reasonable steps may include:
- Night-shift-specific risk assessments
- Adequate supervision
- Safe staffing levels
- Lighting and access controls
- Transport or parking considerations
- Clear escalation routes when HR is not on site
- Training for night supervisors
- Procedures for visitors, contractors or customers at night
Night work can increase risk because fewer people may be present, supervision may be reduced, and staff may be working in isolated areas or during periods when support functions are unavailable.
Reasonable steps should reflect that reality. Employees should know who to contact, how quickly support can be obtained, and what managers or supervisors are expected to do if a concern arises outside normal office hours.
Retail workers
Reasonable steps may include:
- Training on customer harassment
- Clear rules for customer behaviour
- Public notices in stores
- Manager escalation scripts
- Procedures for banning or warning customers
- Incident logs
- Controls for changing rooms, stockrooms and isolated areas
- Support for young workers, apprentices or new starters
Retail environments can involve frequent public contact, pressure to tolerate difficult customers, isolated store areas and younger or less experienced staff.
Employers should make clear that “the customer is always right” does not extend to harassment. Store managers should be trained to respond quickly and consistently, and staff should know they will not be penalised for escalating concerns.
Workers with vulnerable adults
Reasonable steps may include:
- Careful role-specific risk assessment
- Safeguarding procedures
- Behavioural boundary training
- Lone-working controls
- Clear escalation routes
- Support from managers or clinical/safeguarding leads
- Guidance on capacity, communication and de-escalation
- Recording and review of incidents
Where staff work with vulnerable adults, employers need to approach the issue carefully. The risk assessment should not assume that disability, illness or vulnerability automatically creates a harassment risk. It should focus on the actual work, environment, behaviours, communication needs and safeguarding context.
A disability or mental health issue does not mean staff must tolerate harassment. However, the response may need to be sensitive, proportionate and informed by safeguarding, equality and health and safety considerations.
Staff in single-sex environments
Reasonable steps may include:
- Training that includes same-sex harassment examples
- Clear rules on banter, initiation and humiliating conduct
- Supervisor briefings
- Reporting routes outside the immediate team
- Checks on changing areas, welfare facilities and isolated locations
- Culture reviews where poor behaviour is normalised
- Bystander intervention training
Employers should not treat single-sex environments as low risk. Sexual harassment can happen between men, between women, or between people of either sex. In some single-sex workplaces, inappropriate conduct may be more easily dismissed as joking, banter, horseplay or part of the culture.
That is a risk in itself. Training and communications should make clear that sexualised, humiliating, intimidating or degrading conduct is unacceptable regardless of who is involved. Managers and supervisors should be equipped to challenge behaviour early, rather than allowing it to become normalised.
Defensible actions to take now
Across all working environments, the core compliance question is the same: did the employer identify the foreseeable risks and take every reasonable step to address them?
That does not mean every employer must take every possible step. A small office will not need the same controls as a national retailer, a hospitality venue or a care provider. But every employer should be able to explain its reasoning.
A defensible approach should include:
- A documented sexual harassment risk assessment
- Clear policies and standards
- Training that reflects the actual working environment
- Manager-specific guidance
- Trusted reporting routes
- Controls for third-party harassment
- Evidence of communication and completion
- Regular review after incidents or business changes
The move to “all reasonable steps” requires employers to connect their risks, controls, training, reporting routes and evidence into one coherent prevention programme.
