From 30 October 2026, employers will need to take “all reasonable steps” to prevent sexual harassment at work.

For health and safety professionals, the key point is simple... having a policy in place does not mean the risk is being properly managed.

The preventative duty has been in place since October 2024, so employers should already be taking steps to identify and reduce the risk of sexual harassment.

The focus now is on whether those steps are actually working.

Think of it as a workplace risk

An anti-harassment policy is important, but it is only one part of the picture.

As with any workplace risk, organisations need to understand where problems could happen and put practical controls in place.

This means asking:

• Where could workers be exposed to inappropriate behaviour?
• Are some roles or situations higher risk?
• Do workers know how to report a concern?
• Do managers know what to do if one is raised?
• Are workers dealing with customers, contractors or members of the public?
• Are incidents and concerns being recorded and reviewed?
• Are the controls still working?

The Equality and Human Rights Commission says employers are unlikely to meet the preventative duty without carrying out a risk assessment.

That assessment should lead to practical action, such as improving reporting processes, providing training or changing working arrangements where needed.

Keep evidence that it is being managed

If an organisation is asked what it has done to prevent sexual harassment, it should be able to show this.

Useful evidence could include:

✓ A current risk assessment
✓ An up-to-date policy that workers understand
✓ Training records
✓ Clear reporting procedures
✓ Records of concerns and incidents
✓ Evidence that issues have been dealt with
✓ Reviews showing that controls have been updated

The aim isn't to create paperwork for the sake of it. The evidence should show that the risk has been identified, action has been taken and the approach is being reviewed.

Don't forget third-party risks

From 30 October, employers will also have new responsibilities around harassment by third parties.

This is particularly relevant for organisations where workers regularly deal with customers, clients, contractors or members of the public.

For example, risks could arise through:

• Lone working
• Customer-facing roles
• Public-facing environments
• Work-related events
• Working with contractors or suppliers

These risks may need to be considered as part of existing risk assessments.

A simple check for health and safety teams

A useful way to review your approach is:

• Identify – Have we assessed where the risks are?

• Control – Do we have practical measures in place?

• Communicate – Do workers and managers know what is expected?

• Report – Do people know how to raise concerns?

• Monitor – Are concerns and incidents being recorded and reviewed?

• Review – Are we changing our approach when risks change?

Prevention needs to work in practice

The move to “all reasonable steps” isn't simply about updating a policy.

It is about making sure sexual harassment is treated as a workplace risk. Identify it, put controls in place and check that those controls work.

For health and safety teams, the approach is familiar. The important thing is making sure prevention works in practice, not just on paper.

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