Changes to the Harassment Bill 2025 - What Schools & Trusts Should Know

As employment law continues to evolve, employers in the education sector need to stay updated on legislative changes to ensure compliance and maintain a safe working environment.

A key area undergoing significant reform is harassment legislation, which introduces new preventative responsibilities for employers.

The Employment Rights Bill was introduced to Parliament on 10 October 2024, representing the first step in delivering the 'Plan to Make Work Pay'. Further changes to the Employment Rights Bill (Harassment) are scheduled for 2025.

The Bill is expected to receive Royal Assent in 2025, with most reforms likely to take effect in 2026 following consultation. This article explores one of the changes involved in the Employment Rights Bill 2025, the new harassment legislation. 

Further Changes to the Employment Rights Bill (Harassment) 2025

1. Heightened Duty to Prevent Sexual Harassment

Further changes to the Employment Rights Bill 2025 strengthen employers' obligations, requiring them to take "all reasonable steps" (instead of the previous "reasonable steps") to prevent sexual harassment. Regulations may specify what these steps should entail, creating a more prescriptive framework for compliance.

Education leaders must assess and enhance the existing anti-harassment measures, ensuring all workers feel protected and supported. 

2. Expanded Liability for Third-Party Harassment 

According to the Employment Rights Bill amendments, once the relevant clause of the Bill takes effect, employers need to take all reasonable steps to prevent third-party harassment to avoid liability.

Unlike the previous "three strikes" rule under the Equality Act 2010, employers can now be held accountable for third-party harassment from the first incident under the new harassment law. An employer will be deemed to have allowed third-party harassment of an employee if both of the following conditions are met:

  • The third-party harasses the employee in the course of their employment.
  • The employer did not take all reasonable steps to prevent the harassment.

In education, where external interactions (e.g., with parents, contractors, or community members) are common, this change heightens the need for robust policies and proactive measures.

3. Whistleblowing Protections for Sexual Harassment Complaints

Currently, the Equality Act 2010 provides protection against victimisation at work for individuals who raise a complaint of sexual harassment.

The Employment Rights Bill 2025 extends the list of disclosures eligible for protection under whistleblowing laws to include sexual harassment. Workers who disclose information about sexual harassment that has occurred, is occurring, or is likely to occur will now be explicitly covered by whistleblowing protections (such as protection from detriment or dismissal), provided they reasonably believe that their disclosure is in the public interest.

This change in the new harassment legislation also means that non-disclosure agreements (NDAs) will no longer be able to prevent such protected disclosures from being made.

Trust leaders and HR teams must establish clear whistleblowing procedures in alignment with this update.

4. Guidance from Ministers

The Employment Rights Bill 2025 empowers ministers to define what constitutes "reasonable steps" and to mandate that employers consider specific factors when implementing preventative measures.

Schools may need to adapt quickly to guidance or regulations that outline expected practices, including training, reporting mechanisms, and workplace culture initiatives. 

Practical Steps for Schools and MATs

Pippa Lloyd, Head of HR at Keystone Knowledge, shares insights on how educational institutions can prepare themselves in accordance with the Employment Rights Bill amendments:

She says that schools and trusts need to be proactive in identifying where harassment risks may occur, from interactions with third parties to staff relations. Updating policies, providing regular training, and encouraging a culture of openness are vital steps to ensure compliance and protect staff wellbeing.

To address these new harassment legislation changes effectively, schools and trusts should:

  • Review policies and procedures

Update harassment and whistleblowing policies to reflect the new legal requirements

  • Enhance training

Provide comprehensive training on preventing harassment for all staff, including practical guidance on identifying and responding to issues

  • Risk assessments

Conduct risk assessments to identify potential third-party harassment scenarios and develop mitigation strategies

  • Strengthen reporting mechanisms

Ensure staff have access to clear, confidential, and effective reporting channels

  • Encourage a supportive culture

Create an inclusive and respectful work environment that prioritises employee wellbeing and deters harassment

Do you need support with policy review, training, or risk assessments? Keystone Knowledge is here to help you navigate the changes smoothly and prepare in advance – contact us today. 

Why the Employment Rights Bill Amendments Matter

The education sector has unique challenges, with staff often interacting with diverse stakeholders. These changes emphasise the need for schools and trusts to adopt a proactive, zero-tolerance approach to harassment. Failure to comply could result in reputational damage, legal consequences, and a negative impact on staff morale and student outcomes.

By taking swift and comprehensive action, education leaders can ensure they not only meet their legal obligations but also build a safer and more supportive workplace for all.

Connect with Keystone Knowledge to Access Unrivalled Support from HR Experts

Need support with navigating the changes to the Employment Rights Bill 2025? We can provide:

  • Professional advice and support to review and refine your existing HR policies
  • Creation of customised, tailored policies designed to meet the specific needs of your school or trust, ensuring alignment with best practices and upcoming legal changes
  • Thorough case work and project assistance to tackle unique challenges effectively

We also provide scheduled training throughout the year for school leaders and HR professionals. Learn more and book your place here.

To discuss how we can support you, visit our website or contact us directly at 01332 278032 or This email address is being protected from spambots. You need JavaScript enabled to view it..

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