What “All Reasonable Steps” Means for L&D: Preventing Sexual Harassment at Work
Quick answer:
From 30th October 2026, employers in Great Britain must take all reasonable steps to prevent sexual harassment at work. They could also be held liable when clients, customers or contractors harass their staff, unless they’ve taken all reasonable steps to prevent it. For L&D, this means training needs to reflect real risks, be revisited regularly and change how people behave.
Most organisations have a harassment policy, and many have some form of training in place. But from 30th October, the question becomes whether those initiatives go far enough.
Research suggests many organisations aren’t there yet. In a 2025 WorkNest survey, 54% of HR professionals were concerned not enough had been done to comply with the existing duty, and 34% said their organisation hadn’t delivered any sexual harassment training since it came into force in October 2024.
The Employment Rights Act 2025 raises the bar, requiring employers across England, Scotland and Wales to “take all reasonable steps” to prevent sexual harassment. That puts L&D in a central position because training is one of the most visible and valuable steps an organisation can take to prevent harassment.
Here’s what’s changing, where the risk tends to sit and what good training looks like under the new standard.
What changes on 30th October 2026?
There are two changes, and both come into force on the same day:
1.”Reasonable steps” becomes “all reasonable steps”
Since October 2024, employers have had a legal duty to take reasonable steps to prevent sexual harassment of their workers. From 30th October 2026, the Employment Rights Act 2025 strengthens this to all reasonable steps.
And that one extra word makes a real difference. Acas explains that employers who previously chose some reasonable steps will now be expected to take all of them.
According to the government’s factsheet, steps “can include developing effective anti-harassment policies, undertaking risk assessments, engaging and training staff, ensuring effective reporting and complaints systems are in place, and evaluating steps taken on an ongoing basis.”
Acas adds that steps should apply across the whole organisation, and cover online as well as in-person harassment. But what counts as all reasonable steps depends on the organisation’s size, its sector and the work its people do.
The government may also set specific reasonable steps in future regulations, expected in 2027/28 after consultation.
2. A new duty covers third parties
From the same date, employers could be liable if a third party harasses one of their workers, unless they’ve taken all reasonable steps to prevent it – and this covers all harassment related to protected characteristics, not only sexual harassment. A third party could be anyone a worker is in contact with through work who isn’t directly employed by the organisation. That includes customers, contractors, service users (such as patients in a healthcare setting), people at conferences and other members of the public.
Why employers need to show the steps they’ve taken
Tribunals can already increase compensation by up to 25% where they find an employer has breached the preventative duty, so keeping evidence matters.
Acas recommends recording the reasons for any step you’ve decided isn’t reasonable, including where a step only applies to some workers (for example, using bodycams for specific teams working in vulnerable positions). The CIPD’s member resources include a useful checklist for documenting all reasonable steps.
Put simply, good intentions are no longer enough. Employers need to show what they did, why they did it and how they know it’s working.
Where does the risk sit in practice?
Harassment is more likely under certain conditions. The EHRC’s technical guidance lists risk factors that include gendered power imbalances, night working, staying away from home overnight, working alone with a third party and a culture that tolerates sexist “banter”.
In everyday terms, that might look like:
- a junior employee travelling home late after a client dinner
- an engineer working alone on a client’s site
- a new starter whose manager controls their shifts
- a work conference or party where alcohol is flowing
The EHRC’s latest research adds to that picture. It identifies hierarchical structures, male-dominated workforces and insecure contracts as further risk factors, and finds that workers on low wages and precarious contracts face the highest risk.
One more point is worth remembering. A lack of reported incidents doesn’t always mean a safe workplace. In a 2025 Unite survey of more than 6,600 women members, three-quarters of those who had experienced sexual harassment at work didn’t report it. The EHRC’s research found that low reporting can reflect fear of retaliation rather than an absence of harassment. And reports often rise when an organisation first tackles the problem, as people start to trust the process and speak up.
Why is a forgettable module a compliance risk?
When the law changes, many organisations follow a familiar routine. They buy a training module, assign it to everyone and track completions. We’ve all been on the receiving end of that kind of training. Most of us have clicked “next” without fully taking it in.
The problem is that this approach struggles to change behaviour. The EHRC’s research found broad agreement among experts that general, standardised, one-off training can’t deliver sustained behaviour change where harassment is ingrained. Some also warned of a “check box mentality”, where organisations focus on having interventions in place more than on what those interventions achieve.
Acas illustrates this with a worked example. After a serious complaint, an employer brings in harassment training only for the team involved. But its policy hasn’t been reviewed in years, and a wider culture of “banter” goes unchallenged. For the employee who complained, nothing feels different, and they resign and take legal action. Acas concludes it’s very unlikely the employer took all reasonable steps.
Whether it’s a generic module for everyone or a quick fix for one team, training that doesn’t change behaviour or culture is unlikely to meet the new standard. A completion rate can tell you who finished the course, but not who would step in to prevent a harassment incident.
What does effective sexual harassment training look like?
The evidence gives L&D teams a clear brief. According to research commissioned by the EHRC, effective training is timely, repeated and tailored to the underlying causes of harassment in each organisation. Interactive, behaviour-based training that uses real scenarios improves engagement, and training works better when leaders support it.
We’ve unpacked what this means in practice:
- Short and easy to revisit. A ten-minute refresher before a client event or an overnight work trip will do more than a long course people last saw a year ago. Short modules also fit more easily around shifts and client work, which helps them reach frontline and field-based teams. The EHRC’s 8-step guide recommends reviewing how effective training is and offering refreshers at regular intervals; bite-sized learning makes that easier to keep up. We’ve written more about why microlearning works.
- Built around real scenarios. People remember situations they recognise far better than policy wording. Watching a situation unfold, from the first uncomfortable comment to the moment someone steps in, helps people spot the signs in their own workplace. Recognisable situations are one of the things that make behavioural training stick.
- Matched to the risks in each role. Harassment often shows up differently across teams, so training rolled out identically everywhere can feel irrelevant.
- A chance to practise difficult conversations. Saying “that’s not OK” to a senior colleague or a valued client takes confidence. People build that confidence by rehearsing what they’d say in a safe space before they need to say it in a real situation. Bystander training teaches people to notice harmful behaviour and speak up.
- Visibly backed by leaders. Leaders set the tone for what an organisation tolerates. The research recommends behaviour-based training for leaders and managers too, so they can model the standards they expect.
- Delivered with care. Harassment training isn’t abstract for everyone in the room. In the Unite survey, a quarter of women surveyed said they had been sexually assaulted at work. Signpost support, such as an employee assistance programme, helplines and mental health resources, before and after the training.
This thinking shapes Video Arts’ Ready To Go e-learning. Each course takes as little as ten minutes and uses storytelling to bring realistic workplace situations to life. An integrated AI coach gives learners a safe, judgement-free space to practise their response, using scenarios tailored to their role.
Five practical steps for L&D
1. Start with a risk assessment
Work with HR and health and safety colleagues to understand where risk sits across your organisation; as part of this assessment, look at your organisation’s harassment reporting log. Use what you find to decide the approach to training. Rather than giving everyone the same course, you might have a core module that everyone takes, and add modules for frontline teams, people in higher-risk roles, and specific training for anyone who handles complaints, including managers, HR and fair treatment contacts.
2. Set expectations beyond your own walls
The third-party duty means your people need protection from clients, contractors and suppliers as well as colleagues. Acas suggests reviewing contracts and terms with clients and suppliers, telling customers what happens if they harass staff, and training workers in areas such as staff safety and de-escalation. L&D can help client-facing teams know how to respond, when to leave a situation and how to report it.
3. Review the learning you already have
It’s worth checking when training was last updated. Does it cover third parties, online harassment and bystander skills? Does it reflect the situations people face? If the honest answer is “it’s the same module we’ve used for years”, that’s a gap worth closing as soon as possible.
4. Equip line managers
Line managers shape everyday behaviour more than any policy document. Experts interviewed for the EHRC’s research said an employee’s relationship with their immediate supervisor can matter more than the influence of senior leadership.
Help managers spot early warning signs, respond well when someone raises a concern and challenge poor behaviour in their teams. Since April 2026, reporting sexual harassment has counted as a protected disclosure under whistleblowing law, so managers also need to know how to respond when someone speaks up.
5. Measure what matters
Completions are a starting point. Look for signs that behaviour and culture are shifting, such as confidence to report and intervene, awareness of reporting routes and results from culture surveys. The EHRC recommends combining employee culture surveys with data on turnover, progression and absence to understand where problems may be entrenched.
Keep a record of what you’ve done and why. For L&D, that means knowing who completed which training and when, which version they saw, when refreshers are due and how the training links back to your risk assessment.
The takeaway
The new standard comes down to one question. Did you do everything reasonable to stop harassment before it happened?
For L&D, that means moving beyond the annual module. Training needs to reflect real risks, give people the confidence to act and show evidence that it’s working.
New Sexual Harassment training coming soon
We’re adding new Sexual Harassment training to our Ready To Go collection, designed to help organisations turn expectations into behaviours people can recognise and use at work.
Want to know when the new courses drop?
Get in touch to hear more about what’s coming, or to discuss how we can support your wider learning needs.
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