Caroline Seear, Managing Director of Red Recruit Global, gives a practical guide for employers to the first wave of changes in the UK’s Employment Rights Act – landing in April and October.
On 18 December 2025, the UK Employment Rights Act 2025 received Royal Assent. It is now law, but most of the practical changes are being phased in through 2026 and 2027, with key commencement dates expected on 6 April and 1 October, 2026. For removals and storage businesses, this is not “just another HR update”. The sector is labour-intensive, operates under tight margins, and often relies on seasonal peaks, variable hours, weekend work and customer-facing crews.
That combination means the 2026 changes are likely to show up quickly in:
- Payroll cost
- Resourcing cover
- Customer-site behaviour risk
- Implementation of contractual change
A high-impact sector for these reforms
Several parts of the Act interact directly with everyday realities on the road and on site, especially these five areas:
- High customer contact: crews work in people’s homes and offices, meaning third-party behaviour (customers, neighbours, security staff, other trades) is a real factor.
- Variable hours and seasonal demand: peak season often brings longer days, overtime, and more short-notice labour.
- Multi-site and mobile work: managers are not always physically present, so you need clear systems for reporting, escalation and documentation.
- Use of agency labour, subcontractors or self-employed drivers/porters: compliance controls can be patchy unless they are designed in.
- Pay and deductions sensitivities: overtime, attendance bonuses, damage deductions and last-minute changes can quickly become employee-relations issues, especially with longer claim time limits.
The 2026 timetable
The Act is being implemented in phases. The Government and ACAS have indicated that the first wave is expected in April 2026, with a second wave in October 2026. Further reforms continue into 2027.
In practice, that gives removals and storage operators two planning windows: a payroll and policy window for April, and a higher-risk employee-relations window for October.
Wave 1: April 2026 – payroll and policy changes
From April 2026, the following measures are expected to take effect:
- Statutory Sick Pay (SSP): removal of the Lower Earnings Limit and removal of the waiting period, bringing more workers into scope and bringing payments forward.
- Day 1 paternity leave and Day 1 unpaid parental leave.
- Collective redundancy: doubling the maximum protective award for failures in collective consultation.
- Whistleblowing: stronger protections, including protection connected to reporting sexual harassment.
- Fair Work Agency: a new enforcement focus (establishment of the body).
- Trade union recognition: simplification of the recognition process and enabling electronic and workplace balloting.
Wave 2: October 2026 – higher-risk employee relations changes
From October 2026, the following measures are expected to take effect:
- Fire and rehire restrictions: tighter limits on dismissal and re-engagement for certain contractual changes.
- Harassment: employers must take all reasonable steps to prevent sexual harassment, and employers can become liable for third-party harassment (for example customers or clients) unless they have taken all reasonable steps to prevent it.
- Employment tribunal time limits: extension of the time limit for most claims to six months.
- Trade union measures: duty to inform workers of the right to join a trade union and strengthened right of access; new protections for trade union representatives.