In The Pipeline - July 2025

Employment

• Apprenticeships

  August 2025 The apprenticeship system will be changed to increase flexibility. Employers now have the ability to choose whether to require minimum English and Maths qualifications for apprenticeships, and from August 2025, the minimum duration of an apprenticeship will be reduced from 12 to eight months.

• Financial Services

  2025/2026
  • In 2023, the Financial Conduct Authority (FCA) launched a consultation on proposed new persity and inclusion requirements in the financial sector and new rules on non-financial misconduct.
  • The FCA decided not to proceed with the persity and inclusion requirements, but to go ahead with the non-financial misconduct rules.
  • Under the proposals, non-financial misconduct will be incorporated into the FCA's Conduct Rules with effect from 1 September 2026. The FCA is currently consulting on draft guidance on how firms should treat non-financial misconduct, including in relation to fitness and propriety assessments for certified staff. This consultation closes on 10 September 2025.
  • Separately, the FCA has launched a consultation on proposals to improve the efficiency of the Senior Managers and Certification Regime. This consultation closes on 7 October 2025.

• Industrial action

  Autumn 2025 to April 2026
  • New measures in the Employment Rights Bill will make it easier for trade unions to call industrial action, including permitting electronic ballots and removing or reducing notice, information and turnout requirements for ballots brought in by the previous Government.
  • The minimum service levels introduced at the end of 2023 to limit the impact of industrial action in certain sectors (such as emergency services and rail transport) will be removed as soon the Bill is enacted.
  • The changes to notice and information requirements for industrial action ballots will take effect two months after the Employment Rights Bill is enacted, which is expected to be in autumn 2025.
  • Electronic balloting will be introduced in April 2026.

• Collective Bargaining

  Autumn 2025 to October 2026
  • The Employment Rights Bill will introduce various measures to increase trade union recognition, including:
    • requiring employers to inform employees of their rights to join a trade union
    • allowing trade union representatives reasonable access to the workplace
    • simplifying the statutory trade union recognition process and reducing thresholds for support.
  • The changes to the recognition process are expected to come into force in April 2026. The trade union information requirement and right of access are expected to take effect in October 2026.
  • In the adult social care sector there will be a new fair pay agreement (which could form the basis for similar agreements in other sectors in the future).

• Unfair Dismissal Compensation and Statutory Redundancy Pay

  April 2026
  • The maximum amounts for the unfair dismissal compensatory award and a week's pay normally increases every April.
  • The current maximum compensatory award for unfair dismissal is the lower of £118,223 and a year's pay.
  • The current maximum amount of a week's pay (for calculating the unfair dismissal basic award and statutory redundancy pay) is £719.

• National minimum wage

  April 2026
  • The rate of the national minimum wage normally increases in April each year.
  • The current hourly rates of the national minimum wage are:
    • £12.21 for workers aged 21 or over (this rate is referred to as the national living wage)
    • £10 for workers aged 18-20
    • £7.55 for apprentices and workers aged 16-17.
  • In the longer term, the Government plans to extend the national living wage to workers aged 18 or over, but there is no indication of when this change is likely to take place.

• Statutory Maternity, Paternity, Adoption, Shared Parental and Neonatal Care Pay

  April 2026 The rates of statutory pay for family leave normally increase every April. The current weekly rate of statutory maternity, paternity, adoption, neonatal care pay and shared parental pay is £187.18.

• Statutory Sick Pay

  April 2026
  • The rate of statutory sick pay (SSP) normally increases every April. The current weekly rate of statutory sick pay is £118.75.
  • Currently, workers must earn at least the lower earnings limit (£125 per week) to be eligible for SSP and there is a four-day waiting period before SSP is payable. These requirements will be removed under the Employment Rights Bill, from April 2026.

• Enforcement of employment rights

  April 2026 A new Fair Work Agency will be established to bring together the work of existing agencies and enforce certain employment rights including minimum wage and statutory holiday and sick pay, including by bringing an Employment Tribunal claim on an employee's behalf.

• Family Leave Rights

  April 2026 to 2027
  • Paternity leave and unpaid parental leave will become day one rights under the Employment Rights Bill, which will remove the current qualifying service requirements. The six-month service requirement for shared parental leave will remain in place.
  • Employees will be able to take paternity leave following shared parental leave (currently an employee who takes shared parental leave loses the right to any untaken paternity leave).
  • The changes to parental and paternity leave are expected to come into force in April 2026.
  • Employees will have a new right to unpaid bereavement leave, in respect of certain family relationships (which are yet to be specified). This will be in addition to the current two-week parental bereavement leave entitlement.
  • It will also become unlawful to dismiss an employee during pregnancy or during maternity, adoption or shared parental leave or within six months of return to work.
  • The right to bereavement leave and protection from dismissal during or after family leave are expected to come into force in 2027.
  • In July 2025, the Government launched a review of the parental leave system, beginning with a call for evidence which is open for responses until 25 August 2025. The Government is expected to complete its review in early 2027.
  • The Government has also stated that it intends to review the new right to unpaid carers' leave (which came into effect in April 2024) including considering whether this should be paid.

• Equality and Pay Reporting

  April 2026 to 2027
  • Employers with 250 or more employees will be required to report on their ethnicity and disability pay gaps. The Government recently consulted on the detail of the new reporting requirements. There is no confirmed date for when these requirements will come into force.
  • Employers will also have to publish an equality action plan setting out the steps they are taking in relation to gender equality including (i) to address the gender pay gap action and (ii) to support employees through the menopause.
  • Equality action plans will be introduced on a voluntary basis in April 2026, and become mandatory in April 2027.

• Collective redundancies

  April 2026 to 2027
  • Currently, employers must carry out collective consultation with employee representatives where they are making 20 or more redundancies within a 90-day period at a single establishment. In many cases this means that where there are fewer than 20 redundancies at any one site, the collective consultation obligations will not apply.
  • Under the Employment Rights Bill, the collective redundancy rules will change so that the consultation obligations apply where either there are 20 or more redundancies at one site or there are redundancies across more than one site above a certain threshold. This threshold, which could be a specific number or a percentage of the workforce, will be set out in regulations. This change is expected to take effect during 2027.
  • Following consultation the Government plans to increase the protective award for breach of the collective consultation requirements from 90 days' pay to 180 days' pay. This increase is expected to take effect in April 2026.

• Harassment

  October 2026
  • The previous Government brought in the Worker Protection (Amendment of Equality Act 2010) Act 2023 which introduced a new duty on employers to take reasonable steps to prevent sexual harassment at work, with a 25% uplift in compensation where the employer has breached this duty. This came into force on 26 October 2024.
  • The EHRC has updated its technical guidance on sexual harassment and harassment at work to reflect the new duty, and has also published an eight step guide for employers on preventing sexual harassment at work.
  • Under the Employment Rights Bill, this duty will become a duty to take "all" reasonable steps to prevent sexual harassment and regulations will be produced to set out the steps which employers should take in order to comply with the duty.
  • In addition, employers will be liable for harassment of employees by third parties, such as clients or suppliers. This is not limited to sexual harassment but applies to all types of harassment.
  • These changes are expected to take effect in October 2026.

• Confidentiality and NDAs

  October 2026
  • Under the Employment Rights Bill, employers will be unable to use confidentiality provisions (for example in a settlement agreement) to prevent an employee from disclosing information relating to harassment or discrimination. Further detail will be set out in regulations, which may allow for exceptions in certain circumstances.
  • There is no confirmed date for this change but it is likely that it would come into effect at the same time as the other harassment provisions (see above) in October 2026.

• Changing Terms ("fire and rehire")

  October 2026
  • The previous Government introduced a new Code of Practice on the use of "fire and rehire" to change terms of employment, which came into force on 18 July 2024. Where an employer fails to follow the Code, the Employment Tribunal has the power to increase compensation awarded for any relevant claim by up to 25%.
  • Under the Employment Rights Bill, the ability to use "fire and rehire" to change terms fairly will be restricted to situations in which the employer is in serious financial difficulties and has no alternative but to change terms of employment. The current Code of Practice will continue to apply until the new rules come into effect, which is expected to be in October 2026, at which time the Code will be revised.

• Employment Tribunal claims

  October 2026 Most statutory claims must be brought in the Employment Tribunal within a three-month time limit. Under the Employment Rights Bill this will be extended to six months, from October 2026

• Unfair dismissal rights

  2027
  • Employees currently need to have two years' service to qualify for unfair dismissal protection (except for whistleblowing dismissals where there is no qualifying period). The qualifying service requirement will be removed for all unfair dismissal claims, although there will be a probationary period (expected to be nine months) for new employees during which a lighter touch dismissal process will apply.
  • The changes are set out in the Employment Rights Bill and will be subject to consultation in due course. The current two-year service requirement will remain in force until it is removed, which is expected to be in 2027.

• Flexible working

  2027
  • The service requirement for the statutory right to request flexible working was removed in April 2024 (under the previous Government), so all employees have the right to request flexible working from day one.
  • The Employment Rights Bill will introduce a new requirement for an employer's refusal of a flexible working request to be "reasonable". There will be regulations to set out further detail on the process for considering requests. The changes are expected to take effect in 2027.
  • The Government also pledged (prior to the election) to introduce a "right to disconnect" alongside the changes to flexible working. This new right is reportedly to be introduced in a code of practice (and does not form part of the Employment Rights Bill) but there have been reports that it may not proceed.

• Casual/zero hours workers

  2027
  • Zero hours and minimum hours workers will have a new right to be offered a regular hours contract if their working hours regularly exceed the zero/minimum level over a set reference period.
  • Zero hours and irregular hour workers will also have a right to receive reasonable notice of shifts, and compensation if shifts are cancelled or curtailed.
  • These changes are set out in the Employment Rights Bill, and there will be consultation on the detail before the changes come into effect, which is expected to be in 2027.

• Employment Status

  No date
  • In 2017, the Independent Review of Employment Practices in the Modern Economy (known as the Taylor Review) was published and in response, the previous Government published the Good Work Plan setting out a number of reforms aimed at improving the position of workers. It decided not to introduce legislation on employment status, but instead produced guidance for employers.
  • The Government pledged (prior to the 2024 general election) to create a single worker status, with all workers having the full range of employment rights including parental leave and unfair dismissal. These proposals will be subject to consultation at a future date.

EU Employment Law Developments

Following Brexit, the UK is not required to implement new EU directives, but EU laws will have implications for UK businesses with operations in Europe.

• Whistleblowing

  December 2021 Onwards
  • The EU Whistleblowing Directive introduces various measures to protect whistleblowers, which cover not just employees and workers but also self-employed contractors, former employees and workers, and job applicants.
  • Key features of the Whistleblowing Directive include:
    • Employers with 50 or more staff are required to establish secure internal whistleblowing channels and procedures
    • Employers must provide feedback to whistleblowers within a reasonable time (and a maximum of three months)
    • A whistleblower may choose to report to a regulator without reporting internally to their employer first
    • A whistleblower does not need be acting in good faith or in the public interest to gain protection under the law
  • EU countries were required to implement the Whistleblowing Directive by 17 December 2021 (although private sector employers with 50 to 249 employees had until 17 December 2023 to establish internal whistleblowing channels).
  • The UK already has comprehensive whistleblowing laws in place, but some elements of the directive are wider than UK laws. For example, the directive requires employers to put in place internal whistleblowing channels, and it applies to job applicants and self-employed contractors as well as employers and workers.

• Parents and Carers

  August 2022 onwards
  • The EU Directive on work-life balance for parents and carers grants new rights including:
    • Ten days of paid leave for fathers or second parents, to be taken around the birth of a child
    • A right to four months' parental leave, of which two months are paid and non-transferable between parents
    • Up to five working days' unpaid leave per year for carers
    • The right for working carers to request flexible working arrangements.
  • EU member states were required to implement the Directive by August 2022.
  • In the UK, employees may take paternity leave and shared parental leave. In April 2024, a new to unpaid carers' leave came into force, and all employees can request flexible working from day one. The UK Government plans to make changes to the flexible working process and review the family leave system (see Family Leave Rights and Flexible Working above).

• Zero Hours and Irregular Hours Workers

  August 2022 onwards
  • An EU Directive on Transparent and Predictable Working Conditions aims to introduce more certainty for zero hours or irregular hours workers, and includes:
    • A requirement for employers to provide workers who have an unpredictable work pattern with a written statement of the number of guaranteed hours and pay
    • A ban on probationary periods longer than six months (unless justified)
    • A right to request more predictable working conditions after six months
    • A right to compensation if an assignment is cancelled at short notice.
  • EU member states were required to implement the Directive by August 2022.
  • The UK Government plans to give zero hours workers the right to a regular hours contract and the right to notice of shifts and cancellation compensation (see Casual/Zero Hours Workers above).

• Minimum Wage

  November 2024
  • The EU Directive on adequate minimum wages requires EU member states to provide an adequate statutory minimum wage, promote collective bargaining and improve enforcement and monitoring.
  • EU member states were required to implement the Directive by 15 November 2024.
  • The UK has had minimum wage laws in place since 1998. The UK Government is planning to make some changes to minimum wage rates (see National Minimum Wage above).

• Corporate Sustainability Reporting

  2025
  • The Corporate Sustainability Reporting Directive (CSRD) came into force on 5 January 2023. Organisations which are covered by the Directive will be required to report on various ESG matters, including in relation to their workforce and in their value chains (see our briefing for more detail on the requirements).
  • EU member states had to implement the directive by 6 July 2024, and the first reports, for larger organisations already reporting non-financial information, will apply for financial years beginning on or after 1 January 2024. We have produced a briefing on the progress of member states in implementing CSRD.
  • The Directive does not have to be implemented in the UK, but non-EU businesses could have reporting requirements if they have significant business in the EU, and even those not in scope can expect to receive CSRD-related requests for information.

• Equal Pay

  June 2026
  • The EU Directive on equal pay and pay transparency introduces various measures to improve equal pay enforcement and transparency.
  • Under the Directive, employers with at least 250 employees will be required to publish gender pay gap information annually, and employers with at least 100 employees will have to publish this information every three years.
  • The Directive also introduces measures relating to pay in recruitment and promotion including:
    • A requirement for employers to inform job applicants about the starting salary/pay before interview
    • A ban on asking job candidates about their pay history
    • A right for workers to ask employers for information about pay levels and pay and promotion criteria
  • EU member states are required to implement the Directive by 7 June 2026.
  • UK employers with 250 or more employees have been required to publish annual gender pay gap reports since 2018. The UK government will require employers to publish an equality action plan to address their gender pay gap (see Pay and Equality Reporting) above.
  • We have published a briefing on the Directive and how employers can prepare.

• Board persity

  June 2026
  • A new Directive on improving gender balance among directors of listed companies requires listed companies in the EU to have at least 40% female non-executive directors or at least 33% female executive and non-executive directors, by 30 June 2026.
  • There are voluntary targets for female representation on boards in the UK but no indication that there will be any compulsory targets in the foreseeable future.

• Artificial Intelligence

  2026
  • The European Parliament has approved an AI Act to harmonise AI rules across the EU, which would cover AI systems used by employers in the EU. Most of the provisions in the Act are expected to come into force in 2026.
  • Separately, the European Commission adopted a proposal for a Directive to introduce liability for damage related to the use of artificial intelligence (AI), including the use of AI in employment (such as discrimination arising from a recruitment process using AI technology), but this has since been withdrawn.
  • The UK Government has pledged to work with workers, trade unions and employers to ensure that there are adequate safeguards for the use of AI in employment.

• Corporate Sustainability Due Diligence

  2027
  • The Corporate Sustainability Due Diligence Directive will introduce new due diligence duties for organisations to take active steps to identify and manage adverse human rights and environmental impacts in their operations (including their workforce) and chains of activities.
  • Both EU and non-EU companies with significant EU turnover are covered by the Directive.
  • The Directive is in final form and must be implemented by member states by 26 July 2026. The first compliance deadline for the very largest companies is 26 July 2027, with all in-scope companies needing to comply by 26 July 2029.
  • We have published a briefing on the new Directive and how businesses can prepare.

• Gig Economy "platform workers"

  No Date
  • A new EU Directive will improve working conditions for inpiduals working through digital labour platforms (such as taxi or food delivery apps).
  • Under the Directive:
    • There would be a list of criteria to decide whether the platform operator is an "employer"
    • Businesses would be required to inform workers of the ways in which they use algorithms for example for monitoring and work allocation
    • Workers would have the right to contest automated decisions and have them rectified
  • Member states are required to implement the Directive by 2 December 2026.
  • In the UK, the new Government has pledged to create a single worker status which would improve the rights of all workers, including those in the gig economy (see Employment Status above).

• Remote Working

  No Date
  • In April 2024, the European Commission launched a consultation on possible new EU legislation to ensure fair remote working and the right to disconnect. The consultation closed in June 2024 and the response is awaited.
  • The UK Government previously pledged to introduce a right to disconnect, under a code of practice, but it is unclear whether this will be taken forward.

Immigration

• Immigration sponsored work visa reforms

  Ongoing 12 May 2025 onwards
  • In May 2025, the Government published an Immigration White Paper (Restoring control over the immigration system) which outlined the Government's approach to immigration policy in a number of areas including in relation to its plans to reducing net migration levels.
  • As part of the new approach, new Immigration Rules have been brought in, effective 22 July 2025, which bring in some of the proposals in the White Paper including in relation to increasing the minimum skill level and salary level thresholds for sponsored work visas.
  • Other changes outlined in the White Paper are expected later in 2025, including a planned increase in the level of English language required to qualify for certain UK visas and an increase to the Immigration Skills Charge payable by employer sponsors when they sponsor work visas. The government also proposes to double the qualifying period to apply for indefinite leave to remain in the UK from five years to ten years in future. This proposal is expected to be subject to consultation later in 2025.
  • The Migration Advisory Committee (MAC) has issued its report following its review of Professionals in IT and engineering. Whilst the MAC made no formal recommendations in its report its observations and suggestions are expected to be factored into future immigration changes.
  • The MAC is also being strengthened to work with other bodies such as Skills England, the Industrial Strategy Council and the Labour Market Advisory Board, to consider ways of addressing labour market shortages through not only migration but also by addressing local skills shortages.

• Continuing digitalisation of UK visas

  15 July 2025 onwards
  • Physical visa documents (including biometric residence permit ('BRP) and biometric residence card ('BRC')) have been phased out and replaced with digital immigration status (known as an eVisa).
  • Since 15 July 2025, main applicants for certain visa categories of UK visas (including Students, sponsored worker and Youth Mobility Scheme applicants) no longer receive a physical vignette or visa endorsement in their passports.
  • Visa holders are required to register for an eVisa to confirm their status. Applicants for UK visas are now issued with eVisas and are given access to their UK immigration status via an online portal. They are then able to share information on their visa status online with prospective employers, landlords or other relevant third parties to evidence of their right to remain in the UK.
  • This is part of the streamlining and increasing digitilisation of the UK's visa system, with a move towards a 'digital by default' border and immigration system.

• Electronic Travel Authorisations

  Ongoing – phased programme
  • The Electronic Travel Authorisation (ETA) is a universal 'permission to travel' requirement is now fully rolled out in the UK. The ETA is similar to the ESTA system in the United States.
  • Everyone wishing to travel to the UK (except British citizens, Irish citizens and legal residents of Ireland who are travelling to the UK from Ireland, Guernsey, Jersey or the Isle of Man) must now apply for an ETA in advance unless they hold a UK visa or UK residence status.

• Introduction of European Exit/Entry System (EES) and European Travel Information and Authorisation System (ETIAS)

  October 2025 to final quarter of 2026
  • The EES is an automated IT system for registering non-EU nationals for visits (up to 90 days in any 180-day period) to any of the European countries using the system (which will include most EU countries, e.g., France, Germany, Spain, the Netherlands, and will exclude Cyprus and Ireland).
  • The EES will retain a record of entry/exit data as well as any period of overstaying within the EU countries which implement the EES. It is due to open sometime in October 2025.
  • Separately, the EU is introducing a new visa waiver programme (similar to the ESTA programme which applies in the US). Under the new European Travel Information and Authorisation System (ETIAS), all non-EU nationals travelling to the EU will need to apply online or via a mobile app prior to travel.
  • It will apply to non-EU nationals (including UK nationals) and to stays of up to 90 days in every 180 days, while longer stays will require a visa. The ETIAS is expected to cost EUR7 and last for three years. It will initially cover all European Economic Area countries (except for Ireland and Cyprus).
  • The launch date has now been pushed back to the last quarter of 2026 with a specific date not yet confirmed.
  • British citizens do not require visas to visit the EU or Schengen countries, but post-Brexit, they must qualify for entry under the visitor rules, with activities subject to strict limits, including a prohibition against undertaking productive work.

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