ERA 2025 Changes - Third-Party Harassment

If one of your employees was harassed by a customer, contractor, service user, volunteer, or member of the public, would you feel confident that your organisation had taken reasonable steps to prevent it?  

The Employment Rights Act is bringing further changes to UK legislation that affect businesses, charities and churches of all sizes. From 30th October 2026, employers will be expected to take ‘all reasonable steps’ to prevent third-party harassment towards their staff. The focus of this change is on prevention, so employers will need to show they have thought ahead rather than simply responding once something has gone wrong. This does not need to feel overwhelming, but it is something worth preparing for.  

Every organisation will have different third parties that staff come into contact with as part of their roles, so the right approach will not look exactly the same for every organisation. Third parties could include customers, site or office visitors, contractors, volunteers, service users, congregation members or the general public. It is also worth remembering that this is not just about face-to-face interaction; it can include online, virtual or digital too. 

Why this matters for you  

At Cornerstone Resources, we support small to medium organisations across business, charity and church settings, so we know that legal updates can sometimes feel like “one more thing” to deal with for already stretched leaders. For organisations like yours, this change is especially relevant because teams are often smaller, roles are often broader, and staff may have regular direct contact with customers, clients, suppliers, service users, volunteers or members of the public.

The key is not to panic, but to start thinking ahead, understand where the risks might arise and take reasonable steps to protect your staff. 

What could third-party harassment look like? 

In practice, this could look different from one organisation to another.  

For example, it might be a café worker dealing with inappropriate comments from customers, an office-based employee being harassed by a delivery driver, a charity worker receiving inappropriate messages from a service user, or a church Pastor experiencing unacceptable behaviour from a congregation member. It could also include contact through email, message, or social media. 

What is reasonable for your organisation will depend on its size, sector, budget, working environment and the nature of the third parties your staff interact with. For many organisations, taking all reasonable steps does not need to mean expensive or complicated measures. It is about putting practical, proportionate safeguards in place and being able to show that you have thought about the risks. 

What might reasonable steps include? 

Breaking it down, then, reasonable steps at a very general level might include: 

• Reviewing your anti-harassment policy to make sure it clearly covers third-party harassment. 
• Identifying where staff interact with third parties and where risks could arise. 
• Training managers and team leaders to recognise concerns and respond appropriately. 
• Making reporting routes clear so staff know who to speak to and what will happen next. 
• Putting up signs in and around your workplace, so it’s clear for third parties that everyone should be treated professionally and with respect. 
• Adding a clause in your agreements with third parties on expected conduct. 
• Setting expectations with contractors, visitors, clients, customers, volunteers or service users. 
• Keeping records of concerns raised and the action taken in response. 

A preparation checklist 

For your peace of mind, here’s a mini checklist to get you thinking: 

• Do we know which third parties our staff interact with? 
• Have we assessed where harassment risks could arise? 
• Have we updated our policies to clearly cover third-party harassment? 
• Do staff know how to report concerns? 
• Are managers confident about responding to complaints? 
• Are we keeping clear records of concerns raised and the action taken? 
• Have we set expectations with contractors, customers, volunteers, visitors or service users? 

Although the change does not come into force until 30 October 2026, there is no need to wait until the deadline is close. Starting early gives you time to look calmly at where risks might arise, update policies, brief managers, and put practical safeguards in place in a manageable way. 

At Cornerstone Resources, we are helping organisations get in the know about upcoming legislation so employers can feel prepared, not panicked.  

We can also help you look at the risks your organisation may face and identify practical actions that are realistic for your setting. If you are not sure what “all reasonable steps” should look like for your workplace, why not get in touch and arrange a third-party harassment risk assessment? A little preparation now can make it much easier to respond confidently later.