The Employment Rights Act 2025 raises the standard from taking “reasonable steps” to taking “all reasonable steps” to prevent sexual harassment [2][3]. It also makes employers directly liable for harassment of employees by third parties, such as customers, clients and members of the public, unless they have taken all reasonable steps to prevent it [3][4]. 

For employers, this means reviewing existing arrangements and identifying whether further action is needed. Having a policy in place is important, but employers will need to consider how effectively their measures prevent harassment in practice. 

For background on the preventative duty introduced in October 2024, see our [roadmap for employers on sexual harassment legislation](https://www.natwestmentor.co.uk/news/sexual-harassment-legislation-a-roadmap-for-employers).  

## Summary

- From 30 October 2026, the duty to prevent sexual harassment requires employers to take “all reasonable steps”, rather than “reasonable steps” [1][2][3]. 
- The earlier “reasonable steps” duty has applied since 26 October 2024, so this is a higher standard built on obligations employers already have [2][5]. 
- Employers are also directly liable if a third party, such as a customer, client or contractor, harasses an employee, unless the employer took all reasonable steps to prevent it. This goes beyond sexual harassment and covers all other protected characteristics as well [3][4]. 
- There is no statutory list of what counts as “all reasonable steps”. Regulations are not expected until 2027 or 2028, so the Equality and Human Rights Commission (EHRC) technical guidance and eight-step guide remain the practical benchmark [3][4]. 
- Evidence matters. Employers should be able to show what they assessed, what they did, how they reviewed it, and why they decided not to take any step [6]. 
- The EHRC can enforce the duty, and a tribunal can increase compensation by up to 25% in a successful harassment claim where the duty was breached [2][5]. 
- Since 6 April 2026, disclosures about sexual harassment can qualify for whistleblowing protection [2][4]. Restrictions on confidentiality clauses are expected from 2027 [7]. 
- A written policy and a single round of training are unlikely to be enough on their own to meet the extended duty to prevent sexual harassment [2]. 

## What does the extended duty change?
 
Employers have had a legal duty to take “reasonable steps” to prevent sexual harassment of their employees since 26 October 2024 [2][5]. The Employment Rights Act 2025 changes that in two ways with effect from 30 October 2026 [1]. 

<table>
  <thead>
    <tr>
      <th scope="col">Area</th>
      <th scope="col">Before 30 October 2026</th>
      <th scope="col">From 30 October 2026</th>
    </tr>
  </thead>
  <tbody>
    <tr>
      <th scope="row">Standard</th>
      <td>Take “reasonable steps” to prevent sexual harassment of employees</td>
      <td>Take “all reasonable steps”</td>
    </tr>
    <tr>
      <th scope="row">Third parties</th>
      <td>Sexual harassment by third parties falls within the “reasonable steps” duty</td>
      <td>Employers are directly liable for harassment of employees by customers, clients, contractors and other third parties unless they took all reasonable steps. This covers harassment related to all protected characteristics, not just sexual harassment</td>
    </tr>
    <tr>
      <th scope="row">What counts as “reasonable”</th>
      <td>Judged on the facts, using EHRC technical guidance</td>
      <td>Still no statutory list. At the time of writing, regulations are expected after consultation in 2027 or 2028</td>
    </tr>
    <tr>
      <th scope="row">Enforcement</th>
      <td>EHRC enforcement, and compensation can be increased by up to 25% where the duty is breached</td>
      <td>The same, but measured against the higher standard</td>
    </tr>
  </tbody>
</table>
<br>

## What does “all reasonable steps” mean?
The legislation doesn’t define it, but some principles are clear. 

- **It is an objective test that depends on the employer.** The EHRC guidance points to factors such as the size and nature of the business and its working environment, and weighs the time, cost and disruption of a step against its benefit [5]. 
- **It is a higher bar.** It mirrors the standard employers already must meet to defend a vicarious liability claim, and employers cannot rely on having taken only some of the available steps [2][4]. 
- **It is not unlimited.** Employers are not expected to stop all harassment from ever occurring [7]. During the passage of the Act, a government minister said employers would not be penalised for failing to anticipate the unforeseeable or to take other unreasonable steps [8]. 
- **Third-party harassment has its own limits.** The government has indicated that trivial third-party conduct will not trigger liability, and that the steps an employer can reasonably take in relation to third parties are more limited than those it can take in relation to its own staff [7]. 
- **Reasoning matters.** Why an employer chose not to take a particular step, and what it did instead, could be decisive [6]. 

### Third-party harassment: Are employers liable for harassment by customers?

The third-party liability is worth separate attention, because it reaches situations employers have less control over. Employees do not need to show repeated incidents or that the employer knew about the problem beforehand [3][4]. It covers the characteristics protected from harassment under the Equality Act 2010: age, disability, gender reassignment, race, religion or belief, sex and sexual orientation [4]. Hospitality, retail and healthcare are among the sectors identified as particularly exposed [3]. 

## Eight practical steps to meet the duty

The steps below broadly mirror the structure of the [EHRC’s eight-step guide to preventing sexual harassment](https://www.equalityhumanrights.com/employer-8-step-guide-preventing-sexual-harassment-work) [9]. They are a framework, not a rigid checklist. How far you take each one should reflect the size of your business and the risks it faces. 

### Step 1: Carry out (or refresh) a risk assessment

The EHRC guidance says employers are unlikely to be able to meet the duty without one [5]. A good starting point is to assess where and when sexual harassment is most likely to occur in your organisation. Employers should not rely on a generic assessment or assume that existing arrangements remain adequate. Consider: 

- customer-facing roles, and anyone who deals with the public or visits other sites 
- lone working, night working and remote working 
- business travel, social events and work-related events away from the workplace 
- power imbalances, such as junior staff reporting to senior colleagues 
- online and messaging-based harassment 
- groups who may be more vulnerable, such as young, agency or newly hired staff. 

Complete separate assessments for sexual harassment by colleagues and for third-party harassment, ask staff what they see and experience, and record how you reached your conclusions [6]. Anonymous surveys can also help identify concerns that employees might be reluctant to raise directly [9]. 

Once you have identified the risks, decide what measures are needed to address them. Record your findings, the action you will take and when the assessment will be reviewed. 

[The Equality and Human Rights Commission's guidance on sexual harassment and harassment at work](https://www.equalityhumanrights.com/guidance/sexual-harassment-and-harassment-work-technical-guidance?) provides a useful framework for reviewing your approach. 

### Step 2: Update your anti-harassment policy

Your anti-harassment policy should reflect the extended legal requirements and explain how your organisation will prevent, report and respond to harassment. Check that it: 

- defines sexual harassment and gives clear examples, including online conduct 
- covers harassment by customers, clients, contractors and other third parties 
- extends to the other protected characteristics, not just sex 
- explains how to report concerns, how they will be investigated and what the possible outcomes are 
- links to your grievance, disciplinary and whistleblowing policies. 

A standalone sexual harassment policy can be more effective than a short paragraph in a general policy [7]. Make sure the policy is visibly backed by senior leadership, communicated to everyone and referenced in your handbook. Read our guide on [drafting an employee handbook](https://www.natwestmentor.co.uk/news/drafting-an-employee-handbook-what-employers-need-to-know) and how to keep it up to date. 

### Step 3: Make reporting easy

Workers may be reluctant to report harassment if they fear they will not be believed, that nothing will change or that raising a concern could damage their career. 

Employers should provide clear reporting routes and consider offering more than one way to raise concerns, including an option to report anonymously [9]. This is particularly important where the allegation involves a line manager or someone in a position of authority. 

Since 6 April 2026, a disclosure that sexual harassment has happened, is happening or is likely to happen can qualify as a protected disclosure, so managers need to recognise a report when they hear one and avoid any detrimental treatment of the person raising it [2][4]. The [employment law changes in April 2026 article](https://www.natwestmentor.co.uk/news/employment-law-changes-in-april-2026-what-you-need-to-know) covers that change. 

Review whether workers know who they can speak to, what happens after a report is made and how they will be kept informed. 

Employers should respond promptly and appropriately to concerns, even where no formal complaint has been submitted. Informal reports and patterns of behaviour may reveal risks that need to be addressed. 

### Step 4: Train everyone, and train managers properly

All workers should understand what is and isn’t acceptable and how to report it. Managers need more: how to spot problems, how to respond when someone raises a concern, when to escalate and how to avoid retaliation [9]. Customer-facing staff benefit from scenario-based training on handling third-party behaviour [6][7]. Keep records of who attended, what was covered and when, and refresh the training periodically rather than treating it as a one-off. Our [training services](https://www.natwestmentor.co.uk/training/) may help. 

### Step 5: Put measures in place for third parties

The third-party liability makes this step essential for any business that deals with the public or works on other people’s premises [7]. Practical measures include: 

- setting out expected standards of behaviour in contracts and terms with clients and suppliers 
- displaying clear notices in customer-facing areas 
- giving staff a simple escalation route and permission to step away from an abusive situation 
- offering support after an incident, and following up with the third party where appropriate 
- considering safety when staff attend work events or visit client sites [9]. 

### Step 6: Handle complaints promptly and fairly

Act quickly, ask the person raising the concern what outcome they want, and protect them from further harassment while the matter is dealt with [9]. Consider whether the conduct may be criminal and discuss police reporting with them. Treat complaints about third parties as seriously as complaints about colleagues and keep a log of each report and the action taken. Our article on [professional approaches to workplace conflict resolution](https://www.natwestmentor.co.uk/news/professional-approaches-to-workplace-conflict-resolution) covers grievance processes and investigations. 

### Step 7: Listen, monitor and review

A quiet inbox can mean under-reporting, not an absence of problems [6]. Use one-to-ones, staff surveys and [exit interviews](https://www.natwestmentor.co.uk/news/exit-interviews) to understand how people experience your workplace [9] and compare that with your complaints data to spot patterns. Review whether your steps are working, and update your policy, training and risk assessments after any incident or significant change to the business [5]. Exit interview comments should never replace a proper route for raising and investigating a harassment concern. 

### Step 8: Keep an evidence file

If the duty is ever tested, the question will be what you can show. Keep: 

- your risk assessments, with dates and who contributed 
- the steps you considered, the ones you took and your reasons for not taking any other steps 
- policy versions and review dates 
- training content and attendance records 
- complaint and incident logs, and the outcome of each 
- notes of reviews and any changes made as a result. 

Tribunals are likely to look for risk assessments that are specific to the employer’s circumstances and regularly reviewed, rather than generic, off-the-shelf documents [4]. 

## What happens if employers do not comply?

Employers who fail to meet their legal obligations may face significant consequences. The EHRC can take enforcement action in relation to the preventative duty [2]. Where an employee brings a successful discrimination claim involving sexual harassment, an employment tribunal may also increase compensation by up to 25% if the employer has failed to comply with the preventative duty [2][5]. 

Under the third-party harassment duty, an employer may also face liability where the statutory conditions are met, including a failure to take all reasonable steps to prevent the harassment [3]. 

The changes therefore make it important for employers to assess their actual practices rather than relying solely on written policies or reacting only when complaints arise. 

## Future changes: Confidentiality clauses and regulations

Two further developments are worth monitoring. The position may have moved on since this article was written, check [gov.uk legislation tracker](https://www.legislation.gov.uk/new) for updates. 

- Confidentiality clauses. The government has indicated that clauses preventing workers from making certain allegations or disclosures about harassment or discrimination will become legally unenforceable. A limited exception is proposed for agreements that meet specific conditions, including requirements relating to independent legal advice [7]. The implementation date has not been confirmed yet, although changes are expected sometime in 2027. The consultation outcome has also yet to be published. Employers should review confidentiality clauses in employment contracts and settlement agreements in preparation for the changes. 
- Regulations on “reasonable steps”. Further regulations are expected following consultation, alongside likely updates to the EHRC guidance [3][7]. In the meantime, the existing technical guidance and eight-step guide remain the best available benchmarks. 

## Final thoughts

The change from “reasonable steps” to “all reasonable steps” is not about adding paperwork for its own sake. It is about being able to show that prevention is part of how your business runs, not something that gets attention only after a complaint.  

Employers should review their risks, update their policies, train managers and workers, and ensure that effective reporting and response procedures are in place. The measures required will vary between organisations, but the underlying principle is the same: prevention needs to be active, proportionate to the risks and regularly reviewed. 

Taking these steps will help employers meet the extended requirements, support their workers and build a workplace culture in which harassment is recognised, challenged and addressed. 

## Further reading

[Sexual harassment legislation: a roadmap for employers](https://www.natwestmentor.co.uk/news/sexual-harassment-legislation-a-roadmap-for-employers)

[Employment Rights Act: October 2026 changes](https://www.natwestmentor.co.uk/news/employment-rights-act-october-2026-changes) 

[Employment law changes in April 2026: What you need to know](https://www.natwestmentor.co.uk/news/employment-law-changes-in-april-2026-what-you-need-to-know) 

[Drafting an employee handbook: What employers need to know](https://www.natwestmentor.co.uk/news/drafting-an-employee-handbook-what-employers-need-to-know)

[Professional approaches to workplace conflict resolution](https://www.natwestmentor.co.uk/news/professional-approaches-to-workplace-conflict-resolution) 

[Exit interviews: Getting useful insights from departing employees](https://www.natwestmentor.co.uk/news/exit-interviews) 

_This article is intended for informational purposes only and does not constitute legal advice. The information is accurate at the time of writing (October 2026) but may be subject to change. For advice specific to your situation, please consult a qualified professional._

[1] Business gov UK, [https://www.business.gov.uk/campaign/employment-changes/employers/workplace-sexual-harassment-and-third-party-harassment](https://www.business.gov.uk/campaign/employment-changes/employers/workplace-sexual-harassment-and-third-party-harassment). 

[2] Ward Hadaway, [Harassment law reform: What employers need to know before 30 October 2026](https://www.wardhadaway.com/insights/updates/harassment-law-reform-what-employers-need-to-know/). 

[3] Shoosmiths, [Employment Rights Act 2025: Tougher duties on employers to prevent harassment](https://www.shoosmiths.com/perspectives/stories/articles/employment-rights-act-2025-tougher-duties-on-employers-to-prevent-harassment). 

[4] Pennington Manches Cooper, [Harassment and the Employment Rights Act 2025: what employers need to know](https://www.penningtonslaw.com/insights/harassment-and-the-employment-rights-act-2025-what-employers-need-to-know/). 

[5] Addleshaw Goddard, [EHRC publishes updated technical guidance ahead of new duty to prevent sexual harassment coming into force on 26 October 2024](https://www.addleshawgoddard.com/en/insights/insights-briefings/2024/employment/ehrc-publishes-updated-technical-guidance-ahead-new-duty-prevent-sexual-harassment-coming-force-26-october/). 

[6] TLT, [October 2026 harassment reforms: why employers need to move from compliance to evidence](https://www.tlt.com/insights-and-events/insight/october-2026-harassment-reforms-why-employers-need-to-move-from-compliance-to-evidence). 

[7] Covington, [UK Employment Rights Act 2025: Harassment in the workplace: the compliance challenge just got bigger](https://www.cov.com/-/media/files/corporate/publications/2026/09/uk-employment-rights-act-2025--harassment-in-the-workplace-the-compliance-challenge-just-got-bigger.pdf), September 2026. 

[8] Clyde & Co, [How the Employment Rights Bill proposes to extend protections from harassment at work](https://www.clydeco.com/en/insights/2025/05/how-the-employments-rights-bill-proposes-to-extend) May 2025. 

[9] Equality and Human Rights Commission, [Employer 8-step guide: preventing sexual harassment at work](https://www.equalityhumanrights.com/employer-8-step-guide-preventing-sexual-harassment-work). 




news image (5).jpg

Preventing sexual harassment at work: How to meet the extended “all reasonable steps” duty 

Work-related musculoskeletal disorders: Duties, risks and controls

iStock-1370511233 (1).jpg

Candidate ghosting is now one of the most common frustrations employers raise about recruitment. [Research from Indeed](https://www.hrdconnect.com/2024/02/16/job-ghosting-is-rife-86-of-jobseekers-no-show-for-interviews/), based on a survey of 1,500 British workers and 1,500 employers, found that 86% of jobseekers have failed to attend a job interview without notice at some point, and 75% said they had ghosted an employer during a hiring process in the past year \[1\]. The same patterns appear on the employer side. The [CIPD and Omni RMS Resourcing and Talent Planning Report](https://businessnewswales.com/more-than-a-quarter-of-uk-employers-ghosted-by-new-recruits-day-one) found that 27% of employers had been ghosted by new starters who did not turn up on their first day, with 41% seeing new employees resign within the first 12 weeks \[2\]. The [CV Genius Employer Ghosting Report](https://workplacejournal.co.uk/2025/09/over-half-of-employers-admit-to-ghosting-job-applicants-cv-genius/) found that 56% of hiring managers had ghosted applicants, with 23% saying they had no problem doing so \[3\].

For an employer, each ghosting incident carries direct and indirect costs. The vacancy stays open longer, recruitment budgets are spent on candidates who do not convert, and hiring teams absorb additional workload.

## Summary

*   86% of British jobseekers have no-showed a job interview at some point, and 27% of employers have been ghosted on day one by a new starter \[1\]\[2\].
*   Ghosting runs both ways. [56% of employers admit to ghosting applicants](https://workplacejournal.co.uk/2025/09/over-half-of-employers-admit-to-ghosting-job-applicants-cv-genius/), and 23% of workers say they received a verbal offer that was then cut off \[1\]\[3\].
*   The [average cost per hire](https://www.cipd.org/uk/knowledge/reports/resourcing-talent-planning-survey/) sits around £6,125 for senior roles and £3,000 for junior roles, based on CIPD benchmark data \[2\], while [average time to hire](https://hrreview.co.uk/human-resources-news/hiring-slows-as-employers-take-twice-as-long-to-fill-vacancies/385111) has stretched to around eight weeks in late 2025 \[5\].
*   Lengthy or opaque recruitment processes are the most frequently cited drivers of candidate drop-out, followed by better offers elsewhere and pay misalignment.
*   The practical levers for reducing ghosting are structural: shorter time-to-hire, clearer timelines shared up front, regular communication between stages, early conversations about pay, and a managed handover between offer and day one.

## What ghosting in recruitment looks like

Ghosting is sometimes treated as a single behaviour, but the Indeed and CV Genius data describe a range of patterns across the hiring process \[1\]\[3\]. The most common include:

*   candidates withdrawing silently after submitting an application
*   new starters failing to appear on their first day
*   employers extending verbal offers and then cutting contact.

The scale varies by region and by industry. The [CIPD found that 61% of employers in the north and 56% in the Midlands](https://peninsulagrouplimited.com/resource-hub/dismissal/over-half-of-employers-in-the-north-and-midlands-have-been-ghosted) had candidates cancel interviews with little or no notice in the past 12 months, with 18% in both regions reporting day-one no-shows \[4\]. Hospitality, care and other sectors reliant on shift coverage tend to see higher rates. For senior and specialist roles, ghosting typically clusters at the offer stage, where counter-offers and competing processes are most intense.

## The business cost of a no-show

Each ghosted hire represents sunk cost without return. The [average cost per hire](https://www.cipd.org/uk/knowledge/reports/resourcing-talent-planning-survey/) is around £6,125 for senior roles and £3,000 for junior and admin roles, based on CIPD benchmark data \[2\]. These figures include direct spend on advertising, agency fees, assessment tools and background checks. They also absorb indirect costs such as interviewer time and lost productivity in the hiring team while the role sits vacant. The [total cost of a hire](https://www.natwestmentor.co.uk/news/how-much-does-it-cost-to-employ-someone) has been estimated at 135% of wages paid, so losing one late in the process has a knock-on effect on the surrounding budget as well as the recruitment one.

When a candidate ghosts at a late stage, after multiple interviews or after an offer has been accepted, most of that spend has already been committed. The vacancy also stays open longer. According to [Totaljobs' Q4 2025 data](https://www.totaljobs.com/recruiter-advice/hiring-people/hiring-trends-update-q4-2025/), average time to hire has stretched to around eight weeks in late 2025, and closer to nine for larger organisations \[5\]. Every additional week of vacancy adds workload to the existing team and often reopens the search from an earlier stage.

Research by [PageGroup and Cebr](https://onrec.com/news/news-archive/uk%E2%80%99s-biggest-businesses-risk-minimum-%C2%A31326-million-productivity-loss-from) put the minimum cost of recruitment inefficiencies and unfilled vacancies to the British economy at £132.6 million a year in lost productivity, with large organisations losing an average of nine working weeks per year to the problem \[6\].

The impact also extends to hiring teams themselves. Indeed's survey found 55% of employers said ghosting had increased stress in hiring teams, and 48% reported burnout \[1\]. Repeated no-shows erode the credibility of recruitment forecasts and damage trust between hiring managers and HR.

## Why candidates ghost employers

The reasons are consistent across British and international surveys. The clearest driver is the shape of the process itself. [Totaljobs' Q4 2025 hiring trends research](https://www.totaljobs.com/recruiter-advice/hiring-people/hiring-trends-update-q4-2025/) identified lengthy time-to-hire (55%) and time pressure to fill roles (61%) as the top challenges recruiters faced in 2025, and named "lengthy time-to-hire and unclear communication" as key drivers of candidate drop-outs \[5\]. A process requiring five interview rounds spread over six weeks will tend to lose candidates to competitors offering a decision in two.

Silence between stages has a similar effect. When a candidate hears nothing for ten or fourteen days after an interview, many assume the role has gone to someone else and start withdrawing attention. By the time the employer makes contact, the candidate has moved on. Pay plays into this too. Where salary bands are not discussed early, candidates can reach the offer stage only to find the number well below what they expected, and disengaging feels easier than negotiating or declining formally.

Prior experience of being ghosted as a candidate is itself a driver of future ghosting. The [CV Genius research](https://workplacejournal.co.uk/2025/09/over-half-of-employers-admit-to-ghosting-job-applicants-cv-genius/) reported that more than four in five jobseekers who had been ghosted by an employer said they felt down or depressed, with 17% describing severe depression \[3\]. Indeed's data showed 31% of jobseekers believe it is acceptable to ghost before an interview, and 28% say the same during active conversations with the hiring team \[1\]. Candidates who have been treated poorly in previous processes are more willing to treat employers the same way.

## Where ghosting happens in the recruitment funnel

Ghosting is not evenly distributed across the hiring process. Understanding where it clusters helps focus intervention.

Candidates abandon lengthy or clunky application forms before submitting. They lose interest when there is no acknowledgement or timeline after applying. Delays of more than a week between interview stages see noticeable drop-off. In the window between the final interview and the formal offer, candidates often accept competing offers. Between offer and start date, counter-offers from current employers or a slow pre-boarding experience drive late withdrawal. On day one and across the first 12 weeks, inadequate onboarding and the gap between offer expectations and actual experience drive early resignations and no-shows. Retention from day one onwards is covered in Mentor's guidance on [employee retention strategies](https://www.natwestmentor.co.uk/news/employee-retention-strategies).

## Practical steps to reduce candidate ghosting

The following adjustments cover the stages where ghosting most commonly occurs.

### Shorten and simplify the process

A long or multi-stage process gives candidates more opportunities to disengage, and more time for competitors to make an offer. If you are seeing drop-off between interview stages, review the current process and consider:

*   How many stages are genuinely required to assess fit for this role?
*   Can two shorter interviews be combined into one longer session?
*   Are any stages duplicative, with different interviewers asking the same questions?
*   Can decisions between stages be made within 48 hours rather than a week?

[SmartRecruiters' 2025 benchmark data](https://www.smartrecruiters.com/resources/article/united-kingdom-benchmark-recruiting-metrics/), based on nearly 90 million applications, found that UK employers interview more candidates on average than their global counterparts, suggesting room to tighten the funnel earlier \[8\]. The same analysis cited a retailer that reduced time-to-hire from 23 days to nine and saw 25% fewer candidate drop-offs as a result \[8\].

### Set expectations about timing from the start

Share the full process timeline at application stage, not just at interview invitation. A sentence in the job advert, such as "You can expect two interviews within three weeks, and a decision within five working days of the second," removes a major source of uncertainty for candidates. If a decision will take longer than promised, send a holding message before the deadline passes rather than after it.

### Keep communication consistent between stages

A short update keeps candidates engaged, even one that only says "we are still reviewing applications and will be in touch by Friday." Automated acknowledgements for applications, interview confirmations and templated status updates between stages are low-cost measures that reduce drop-off. Human follow-up can then be reserved for the stages where it matters most, such as shortlist invitations, interview feedback and the offer conversation.

### Have the pay conversation early

Pay misalignment is a common cause of late-stage ghosting. Publish salary ranges in job adverts where possible, or confirm the range in the first screening call. This filters out candidates whose expectations will not be met and avoids wasted time on both sides.

### Reduce friction in applications

Long application forms drive candidates away before they submit. So does the familiar irritation of uploading a CV only to retype its contents into form fields. [ACAS guidance on recruitment](https://www.acas.org.uk/recruiting-staff) notes that recruitment processes should be proportionate to the role, and that overcomplicated applications can disadvantage candidates and reduce the quality of the applicant pool \[9\].

### Make it easy for candidates to withdraw

Many candidates ghost because withdrawing feels awkward. Explicitly inviting candidates to opt out at each stage, with wording along the lines of "please let us know if you would rather not proceed, no explanation needed," removes some of that friction and gives you cleaner data on where the pipeline is losing people.

### Treat the offer-to-start-date period as part of recruitment

The period between acceptance and day one is where many hires are lost. [ACAS guidance on induction](https://www.acas.org.uk/starting-staff-induction) recommends that the period between offer and first day is treated with the same care as the recruitment process itself \[10\]. Practical actions in this window include:

*   A welcome message within 24 hours of acceptance
*   Light-touch contact once a week during the notice period
*   Early sharing of the contract and the employee handbook
*   A direct point of contact for questions
*   Confirmation of first-day logistics the week before

### Deliver rejections properly

A short, respectful rejection sent promptly costs very little and protects both reputation and future applicant pools. Candidates who are rejected well may reapply or recommend the employer to others. Candidates who are ghosted do neither. A rejection does not need to include detailed feedback to be useful; acknowledging the time invested and confirming the outcome is enough.

## Reducing day-one and early-tenure no-shows

Day-one no-shows are rarely spontaneous. They are typically preceded by weeks of thin communication, a counter-offer from the current employer, or a competing offer that landed after the acceptance. Keeping the hire warm during the notice period is the single highest-impact change. [The CIPD and Omni RMS research](https://cipd.org/uk/about/press-releases/over-quarter-of-uk-employers-been-ghosted-by-new-recruits-day-one/) found that dedicated engagement during the offer window reduced ghosting and dropouts by 30% in some organisations \[2\].

Early resignations within the first 12 weeks tend to come from a different source. In most cases they reflect a mismatch between how the role was described at interview and what it turns out to involve in practice. Realistic descriptions of workload and culture, backed by a structured first-month plan with regular check-ins, help close that gap. The CIPD's recommendation to employers is to invest in both engagement during recruitment and structured onboarding afterwards \[2\]. For a step-by-step approach to the first 90 days, see [Mentor's employer guide to effective employee onboarding](https://www.natwestmentor.co.uk/news/employers-guide-to-effective-employee-onboarding).

## Measuring whether changes are working

A handful of recruitment metrics indicate whether anti-ghosting efforts are having an effect:

*   **Application completion rate**: the proportion of started applications that are submitted.
*   **Interview no-show rate**: the proportion of confirmed interviews that candidates do not attend.
*   **Offer acceptance rate**: the proportion of offers that are accepted.
*   **Pre-start withdrawal rate**: the proportion of accepted candidates who withdraw before day one.
*   **Day-one no-show rate**: the proportion of expected starters who do not appear.
*   **Early resignation rate**: the proportion of hires who leave within the first 12 weeks.

Tracked over time, these metrics show where in the process candidates are being lost. A rising interview no-show rate usually points to slow scheduling or poor communication between application and interview. A rising pre-start withdrawal rate points to pre-boarding. An elevated early resignation rate suggests the role has been mis-sold at interview, or that onboarding is not holding up once new starters arrive.

## Final thoughts

The [CIPD's Winter 2025/26 Labour Market Outlook](https://www.cipd.org/uk/knowledge/reports/labour-market-outlook/ "https://www.cipd.org/uk/knowledge/reports/labour-market-outlook/") found that hiring intentions were at historically low levels outside the pandemic, with only 15% of employers anticipating significant difficulties filling vacancies in the next six months [11]. 

A weaker job market may give employers more choice and reduce the likelihood of candidates ghosting them, as candidates have fewer alternative opportunities. When vacancies are plentiful, the balance can shift: candidates have more options and may be more likely to disengage from a recruitment process if a better opportunity arises.

Whatever the market conditions, the principles for reducing ghosting remain the same: keep the recruitment process short, communicate consistently between stages, and treat the period between offer and start date as an integral part of recruitment, not an afterthought. Effective onboarding is equally important, helping new starters feel welcomed, engaged and committed from day one.

_This article is intended for informational purposes only and does not constitute legal advice. The information is accurate at the time of writing but may be subject to change. For advice specific to your situation, please consult a qualified professional._

\[1\] Indeed, _Job ghosting is rife: 86% of jobseekers no-show for interviews_, 2024.

\[2\] CIPD and Omni RMS, _Resourcing and Talent Planning Report_, 2025.

\[3\] CV Genius, _Employer Ghosting Report_, 2025.

\[4\] CIPD and Omni RMS, _Resourcing and Talent Planning Report - regional findings_, 2024.

\[5\] Totaljobs, _Hiring Trends Update Q4 2025_, November 2025.

\[6\] PageGroup Enterprise Solutions and Centre for Economics and Business Research, _Economic Cost of Hiring Delays and Inefficiencies_, 2025.

\[7\] University of South Australia, _Recruiters and jobseekers are ghosting each other - why?_, 2024.

\[8\] SmartRecruiters, _Recruiting Benchmarks 2025 Report - United Kingdom_, 2025.

\[9\] ACAS, _Recruiting staff_, 2025.

\[10\] ACAS, _Starting staff: induction_, 2025.

\[11\] CIPD, _Labour Market Outlook - Winter 2025/26_, 2026.

Ghosting in recruitment: How to reduce no-shows

1211640503 (1).jpg

Employment law draws a distinction between self-employed contractors, workers, and employees, and the category an individual falls into determines their rights, their tax treatment, and the obligations owed to them by the business engaging their services. A signed contract describing someone as self-employed does not settle the question on its own. Tribunals and HMRC assess how the working relationship operates in practice, and the label the parties give it carries limited weight where the day-to-day reality points to a different category \[2\].

Around [4.39 million people in the UK were self-employed in late 2025](https://legalvision.co.uk/employment/employees-contractors-differences/), representing roughly 13% of the workforce \[3\]. Contractor arrangements are used across most sectors of the economy. The [Employment Rights Act 2025](https://www.natwestmentor.co.uk/news/employment-rights-act-october-2026-changes), which [received Royal Assent on 18 December 2025](https://acuitylaw.com/employment-rights-act-2025-key-changes-employers/), introduced the Fair Work Agency as a single enforcement body with powers to conduct unannounced inspections and request documents. Where National Minimum Wage has been underpaid, the agency can recover arrears and impose penalties of up to 200% of the amount owed \[1\].

## Summary

*   The law recognises three categories of working person: employees, workers, and self-employed contractors. Each carries different rights, obligations, and tax treatment \[4\].
*   The written contract is only one factor in determining employment status. Tribunals assess the reality of the working relationship, and the label the parties choose carries limited weight \[2\].
*   Three tests are consistently identified in case law as central to status decisions: personal service, mutuality of obligation, and control. Integration and financial risk sit alongside them \[9\].
*   Off-payroll working rules (IR35) apply where a contractor works through their own limited company. Medium and large businesses must issue a Status Determination Statement; small businesses are exempt \[13\]\[16\].
*   The Employment Rights Act 2025 introduced the Fair Work Agency, launched on 7 April 2026, with powers including unannounced inspections and penalties of up to 200% of unpaid National Minimum Wage arrears \[1\]\[21\].
*   Financial exposure from misclassification includes back-dated PAYE and National Insurance (normally up to four years, extending to six for careless errors and twenty for deliberate non-compliance), plus holiday pay, pension contributions, and statutory payments owed to the individual \[14\]\[16\].
*   Employment status is not fixed at the start of an engagement. Where the working relationship changes over time, the applicable category may change with it \[16\].

## The three categories of working person

UK employment law recognises three distinct categories, each with different rights and obligations \[4\].

**Employees** work under a contract of employment with ongoing mutual obligations. They cannot generally send substitutes, work under the employer's direction, and receive the full range of statutory rights - protection from unfair dismissal (after the qualifying period), statutory sick pay, family leave, redundancy pay, and the right to a written statement of employment particulars.

**Workers** occupy an intermediate position. They must personally perform the work and receive core protections including the National Minimum Wage, paid holiday, rest breaks, and protection from unlawful deductions \[5\]. However, they do not receive the full suite of employment rights that employees do.

**Self-employed contractors** run their own businesses. They bear financial risk, control how they work, can typically send substitutes, and invoice clients for services \[6\]. Contractors have no statutory employment rights and manage their own tax and National Insurance through Self Assessment.

Case law such as _Autoclenz Ltd v Belcher_ (2011) UKSC 41 established that tribunals will look at the reality of the working relationship, not just what the written contract states \[7\]. This principle was reinforced in _Uber BV v Aslam_ (2021) UKSC 5, where [the Supreme Court held that Uber drivers were workers](https://www.blakemorgan.co.uk/supreme-court-rules-uber-drivers-are-workers/) despite contractual documentation describing them as self-employed \[8\]. The judgment made clear that tribunals should determine status by reference to the statutory definition, not the contractual label.

## The key status tests

There is no single test for employment status. Tribunals weigh several factors together and consider the relationship as a whole \[9\]. Three are consistently identified in case law as central: personal service, mutuality of obligation, and control.

### Personal service and substitution

If the individual must perform the work personally, this points towards employee or worker status. A genuine, unfettered right to send a substitute - as in the [Deliveroo model, where riders can pass any accepted job to a third party](https://farorelaw.co.uk/insights/recent-supreme-court-ruling-why-are-deliveroo-riders-not-workers) without restriction - points towards self-employment \[10\].

Tribunals examine whether the right operates in practice, not only whether it appears in the contract. In _Pimlico Plumbers Ltd v Smith_ (2018) UKSC 29, the Supreme Court held that plumbers were workers because their right to substitute was severely limited: they could only swap with another Pimlico plumber, and only in limited circumstances \[11\]. Substitution clauses that appear in the contract but are not exercised in practice have been treated by tribunals as inconsistent with genuine self-employment.

### Mutuality of obligation

This test examines whether the business is obliged to offer work and the individual obliged to accept it. Ongoing mutual obligations point towards employee status. A genuine ability to turn down offered work without penalty, and a lack of any commitment on the business to provide it, points towards self-employment or worker status.

### Control

The more control the business exercises over how, when, and where the work is done, the more the relationship resembles that of an employee or worker. Fixed hours, direct supervision, mandatory attendance at meetings, and prescribed methods of working all point in that direction. A contractor who decides their own hours, methods, and sequence of work - and who can accept or refuse individual assignments - sits closer to self-employment.

### Integration and financial risk

Beyond the three primary tests, tribunals consider how integrated the individual is into the business (whether they appear on internal directories, hold a company email address, or attend team meetings as a matter of course) and whether they bear genuine financial risk (providing their own equipment, carrying professional indemnity insurance, or losing money on unprofitable jobs).

In long-running engagements where a contractor has become embedded in delivery teams, integration factors have often been given significant weight by tribunals, and a contractual right of substitution that has not been exercised in practice has been given less \[12\].

## Off-payroll working rules (IR35)

Where a contractor provides services through their own limited company - often called a personal service company (PSC) - the [off-payroll working rules](https://www.gov.uk/government/collections/off-payroll-working-ir35-detailed-information) apply \[13\]. Introduced in 2000 and reformed for the private sector in April 2021, IR35 is designed to prevent "disguised employment," where a worker uses a company structure to reduce their tax bill despite operating effectively as an employee \[14\].

Under the reformed rules, the client organisation (not the contractor) is generally responsible for determining status. Medium and large businesses must issue a **Status Determination Statement (SDS)** explaining the decision and take reasonable care in reaching it \[15\]. If the client decides the engagement is "inside IR35," the fee-payer must deduct PAYE income tax and National Insurance before paying the contractor's company.

**Small businesses are exempt** from the client-side rules. A business qualifies as small by failing at least two of these tests: turnover above £15 million, balance sheet total above £7.5 million, or more than 50 employees \[16\]. In small-client engagements, the contractor's PSC remains responsible for assessing its own IR35 status.

### The financial exposure

Where HMRC determines that an engagement was wrongly classified as outside IR35:

*   All income received is reclassified as employment income \[17\].
*   The fee-payer becomes liable for unpaid PAYE income tax, employee and employer National Insurance, interest, and penalties \[14\].
*   HMRC can look back six years - or twenty years in cases of deliberate non-compliance \[16\].
*   From April 2025, the [employer National Insurance rate rose from 13.8% to 15%](https://danielwolfson.co.uk/inside-outside-ir35-contractors-guide/), and the threshold for employer NICs liability on earnings reduced from £9,100 to £5,000 \[17\].

Offset rules introduced from April 2024 mean that tax already paid by the contractor or their PSC can be credited against the client's liability, reducing the double-taxation risk that existed under the previous regime \[18\]. However, remaining tax, interest, and penalties still fall on the client.

## HMRC's CEST tool: what it does and doesn't do

The [Check Employment Status for Tax (CEST) tool](https://www.gov.uk/guidance/check-employment-status-for-tax) is HMRC's free online questionnaire for assessing status \[19\]. Users answer questions about the working arrangement - control, substitution, financial risk, and so on - and receive one of three outcomes: employed for tax purposes, self-employed for tax purposes, or "unable to determine."

HMRC has committed to standing by CEST determinations, provided the information entered is accurate and consistent with HMRC guidance \[19\]. The tool was [updated on 30 April 2025](https://www.twobirds.com/en/insights/2025/uk/spot-the-difference-a-closer-look-at-hmrcs-updated-cest-tool) to simplify the language of its questions and add a new question on whether a contract is in place \[20\]. The underlying decision-making logic was not changed.

HMRC data indicates the following.

*   Around **one in five CEST determinations returns an "unable to determine" outcome**, in which case the user must seek further guidance to reach a decision \[9\].
*   [Total CEST determinations fell from 458,894 in 2023/24 to 135,178 in 2025/26](https://www.ir35update.co.uk/cest-explained/), a decline of 71% over two years \[9\].

CEST covers tax status only. It does not determine worker or employee status for the purposes of employment rights, which sit under separate case law and statutory tests. A separate assessment is needed to establish whether an individual has worker rights under the National Minimum Wage Act 1998, the Working Time Regulations 1998, or the Employment Rights Act 1996.

## Arrangements that have attracted regulatory and tribunal attention

Certain patterns of engagement have featured repeatedly in HMRC enquiries and employment tribunal decisions \[12\].

*   **Long-running contractor engagements** where the individual has become embedded in a delivery team, uses company systems, and works alongside employees doing similar work.
*   **Care sector arrangements** using self-employed carers on set rotas taking direction from the provider. Multiple tribunal decisions in the sector have resulted in findings of worker status, and the FWA has identified care as a priority area for enforcement \[12\].
*   **Agile delivery teams** in technology and consultancy, where contractors and permanent staff work in mixed teams on ongoing product development.
*   **Freelance roles in production, design, and editorial**, particularly where a contractor works with a small number of repeat clients over extended periods.
*   **Sole-client contractors** - individuals who work exclusively or almost exclusively for one business, particularly over multiple years.

Duration alone does not determine employment status, but it is a factor tribunals consider alongside the other tests. A long-running engagement in which the individual uses client-provided equipment, attends internal meetings, and works under management direction combines several indicators associated with employee or worker status.

## Total exposure from misclassification

Misclassification exposure typically falls into three categories:

*   **HMRC recovery**: back-dated PAYE income tax and National Insurance for up to six years, plus interest and penalties. In cases of deliberate non-compliance, HMRC's look-back period extends to twenty years \[16\].
*   **Employment tribunal claims**: back-dated holiday pay, statutory sick pay, pension contributions, and, where the qualifying period is met, unfair dismissal awards. The compensatory award for unfair dismissal is currently capped at the lower of a statutory maximum or 52 weeks’ pay; the cap is removed from 1 January 2027. Certain claims, including discrimination, are already uncapped.
*   **Fair Work Agency penalties**: where an FWA investigation finds National Minimum Wage has been underpaid, penalties of up to 200% of the arrears, in addition to the arrears themselves \[1\].

Employment tribunal judgments are published on the government tribunal decisions database and are publicly searchable, meaning findings of misclassification enter the public record.

## The current position

Genuine contractor arrangements - those in which the individual runs their own business, bears financial risk, and controls how the work is performed - remain a lawful and widely used form of engagement across Great Britain. Status disputes generally arise in cases where the contractual documentation and the day-to-day operation of the relationship diverge, or where an engagement that started as a defined project has evolved into ongoing, integrated work.

Status is a question of fact, decided by a tribunal or by HMRC on the evidence of how the relationship operates. The written contract, the CEST tool result, and the label the parties give the arrangement are each factors in that assessment, but none is determinative on its own.

_This article is intended for informational purposes only and does not constitute legal advice. The information is accurate at the time of writing but may be subject to change. For advice specific to your situation, please consult a qualified professional._

\[1\] Acuity Law, _Employment Rights Bill receives Royal Assent_, January 2026.

\[2\] Supreme Court, _Autoclenz Ltd v Belcher_ \[2011\] UKSC 41.

\[3\] LegalVision UK, _What is the Difference Between Employees and Contractors?_, 2026.

\[4\] GOV.UK, _Employment status_.

\[5\] ACAS, _Employment status_.

\[6\] GOV.UK, _Employment status: self-employed and contractor_.

\[7\] Employment Cases Update, _Autoclenz v Belcher & Ors \[2011\] UKSC 41_.

\[8\] Blake Morgan, _Supreme Court rules Uber drivers are workers_, 2021.

\[9\] IR35 Update, _CEST explained: when HMRC's IR35 tool works - and when it doesn't_, June 2026.

\[10\] Farore Law, _Recent Supreme Court ruling - why are Deliveroo riders not workers?_, 2023.

\[11\] Howat Avraam Solicitors, _Pimlico Plumbers - A Cautionary Tale_.

\[12\] Policy Pros, _Contractor vs Employee Status 2026 - Avoiding Misclassification Claims_, May 2026.

\[13\] GOV.UK, _Off-payroll working (IR35): detailed information_, updated May 2025.

\[14\] Sage, _Guide to off payroll working rules and IR35_, July 2025.

\[15\] Crunch, _IR35 Changes in 2025 - A full guide to the Latest Off-Payroll Working Rules_.

\[16\] Rebox HR, _Employee vs Contractor: UK Employment Status Guide_, January 2026.

\[17\] Daniel Wolfson, _Inside vs Outside IR35: Complete UK Contractor Guide (2026)_, July 2026.

\[18\] Crunch, _IR35 Changes in 2025 - A full guide to the Latest Off-Payroll Working Rules_ (offset rules).

\[19\] GOV.UK, _Check Employment Status for Tax (CEST)_, updated 30 April 2025.

\[20\] Bird & Bird, _A Closer Look at HMRC's Updated CEST Tool_, 2025.

\[21\] CIPD, _Fair Work Agency: Changes under the Employment Rights Act 2025_, February 2026.

Contractor, worker or employee? Understanding employment status

iStock-1423646287 (1) (2).jpg

Post a job today and you can expect to hear back from far more people than a few years ago. For a graduate role, the average is now 140 applications \[1\]. For most other adverts, the figure sits at around 30, though sectors like Retail and Hospitality routinely pull over 100 applications per vacancy \[2\]\[3\].

It is tempting to read those numbers as good news. More applications mean more choice, and more choice means a better hire - or so the logic goes. In practice, the relationship between application volume and hiring outcomes is no longer as strong as it once was. The sectors receiving the most applications are not the ones that find hiring easy. And the reasons behind the volume increase have very little to do with candidates suddenly finding your role more attractive.

For smaller businesses without a dedicated talent function, understanding what your recruitment data is telling you can help you make better hiring decisions. This article looks at what is actually driving current volumes, how sector variation should shape expectations, and why more applications does not necessarily make it easier to hire.

## Summary

*   Application volumes are up market-wide, but the rise reflects structural changes - fewer vacancies, one-click platforms, AI-generated applications - rather than employer-specific interest.
*   The overall market average ran between 17 and 43 applications per job across recent quarters \[2\]\[3\], having peaked at 48.7 in late 2024 \[4\].
*   The sectors receiving the most applications are not the ones reporting hiring difficulty. Education attracted 10 applications per job in Q3 2025 whilst 72% of education employers anticipated significant problems filling vacancies \[5\]\[6\].
*   Graduate roles now attract 140 applications on average, up from 38 in 2002-03 - but graduate vacancy numbers are at their lowest level since 2012 \[1\]\[7\].
*   65% of graduates now use AI tools during applications \[8\]. Volume no longer maps cleanly to genuine interest.
*   Channel choice significantly affects volume: job boards averaged 11-20 applications per job across 2025, employer websites 2-3, social media 1-2 \[5\].

## What is driving current volumes

Three structural shifts sit behind the numbers, and none of them are about your role.

*   **The market has fewer vacancies to compete for.** ONS figures show vacancies falling for the best part of three years, standing at 705,000 in February to April 2026 - the lowest level since early 2021 \[9\]. The ratio of unemployed people to vacancies stood at 2.5 through the first half of 2026, up from 2.0 a year earlier \[9\]. Fewer roles mean each role concentrates more candidate attention, regardless of who's advertising it.
*   **Applying has become easier and quicker.** Platforms like LinkedIn Easy Apply and Indeed Apply let candidates submit applications to multiple roles in a matter of seconds. Analysis of the November 2024 surge, when applications per job hit 48.7, attributed part of the spike directly to these one-click channels \[4\].
*   **AI has changed the volume-to-effort ratio.** A Kahoot! survey found that [65% of graduates now use AI tools](https://www.theemploymentlawsolicitors.co.uk/news/2026/01/24/job-applications/) during job applications, up from 39% the previous year \[8\]. Raconteur reported similar levels across the broader jobseeker population, citing recruitment company Career Group \[10\]. On the employer side, CMI research found that [52% of managers suspected applicants](https://www.cityam.com/should-you-use-ai-for-job-applications-heres-what-uk-hiring-managers-think/) were using AI tools to craft CVs and cover letters, and equivalent proportions expressed concern about whether the resulting applications gave a fair representation of a candidate's actual skills \[11\].

None of these forces reflect anything specific about your business. They apply the same pressure to every open vacancy. So when applications flood in, the sensible reading is that the market conditions are driving more applications - not that your employer proposition has suddenly become irresistible.

## Sector variation

The overall market average conceals differences of an order of magnitude between sectors, and the sectors receiving the most applications are not the sectors reporting the greatest difficulty hiring.

| Sector | Applications per job |
| --- | --- |
| Insurance | 88 |
| Catering & Hospitality | 81 |
| Retail & Wholesale | 62 |
| Travel, Leisure & Tourism | 59 |
| Manufacturing | 32 |
| Education | 10 |
| Overall market average | 25 |

<br>

_Applications per job by sector, WaveTrackR \[5\]._

The CIPD's Labour Market Outlook winter 2025/26 reported that [72% of employers in compulsory education](https://www.cipd.org/globalassets/media/knowledge/knowledge-hub/reports/2026-pdfs/9094-lmo-winter-2025-26-report-web.pdf) and 62% in care and social work anticipated significant problems filling vacancies over the following six months \[6\]. These are the same sectors that sit at the bottom of the applications-per-job tables. At the other end, the CIPD data showed recruitment pressures easing in retail (64%), arts and entertainment (59%) and hospitality (55%) \[6\] - the sectors that consistently top the applications-per-job rankings.

The gap between volume and difficulty changes what your own numbers actually tell you. If retail applications are up 30% year-on-year in your business, that is the sector doing what the sector does, not evidence that your recruitment strategy has become more effective. If your nursing vacancy has attracted 15 CVs, that isn't the failure it looks like against the overall market average of 25 - it is above your sector norm.

## Graduate hiring shows the pattern most sharply

Every dynamic driving the wider market shows up faster and larger in graduate recruitment. The Institute of Student Employers' [Student Recruitment Survey 2025](https://ise.org.uk/_userfiles/pages/files/reports/student_recruitment_survey_2025.pdf), based on 155 member employers and 1.8 million applications, put the average graduate vacancy at 140 applications in the 2024-25 cycle \[1\]. Two years earlier the figure was 86. In 2002-03 it was 38 \[7\].

The trajectory is not evidence that graduate roles are becoming more attractive. Graduate vacancy numbers are at their lowest level since 2012, according to High Fliers Research's Graduate Market 2026 report, and ISE members forecast a further 7% drop in graduate hiring for 2025-26 \[7\]. AI use has moved faster among graduates than any other cohort - the same Kahoot! data that shows 65% of graduates using AI tools represents a substantial jump on the 39% recorded the year before \[8\]. And the ISE has flagged the assessment consequences: only 15% of graduate employers reported never having suspected or identified cheating in assessments in 2025, down from 22% the previous year \[1\].

Graduate employers are not seeing deeper interest in their roles. They are seeing the market's structural pressures compressed into a single applicant cohort - and the shortlist that results requires more filtering, not less.

## The effect of advertising channel

The channel you advertise through significantly shapes both the volume and the composition of your response. 

| Channel | Share of jobs posted | Share of applications | Applications per job |
| --- | --- | --- | --- |
| Job boards | ~85% | ~90% | 11 - 20 |
| Employer websites | ~13% | ~9% | 2 - 3 |
| Social media | ~3% | ~1% | 1 - 2 |

<br>

_Distribution channel performance, WaveTrackR \[5\]._

For employers weighing where to spend their [advertising budget](https://www.natwestmentor.co.uk/news/building-employer-brand)the volume they receive is partly based on choices they have made. A role advertised only via an employer website will produce a fraction of the applications the same role would attract on a job board - and comparing the two as if they measured the same thing leads to false conclusions about candidate interest.

## Conclusion

Application count on its own does not tell you much. It is shaped by structural factors that apply to every employer, by sector norms that vary significantly, and by recruitment channels that inflate or deflate the number before it even leaves the platform.

A busy inbox for job applications in 2026 is likely. Whether it represents a strong response depends entirely on the sector, the recruitment channel, and the seniority of the role - and none of those factors are visible from the application count itself.

_This article is intended for informational purposes only and does not constitute legal advice. The information is accurate at the time of writing but may be subject to change. For advice specific to your situation, please consult a qualified professional._

\[1\] Institute of Student Employers, _Student Recruitment Survey 2025_, October 2025.

\[2\] WaveTrackR, _Q2 2025 Recruitment Trends Report_, July 2025.

\[3\] WaveTrackR, _January 2026 Recruitment Trends Snapshot_, February 2026.

\[4\] Tribepad, _Applications per Job Up 286% YOY - UK Job Market Insights_, December 2024.

\[5\] WaveTrackR, _Q3 2025 Recruitment Trends Report_, October 2025.

\[6\] CIPD, _Labour Market Outlook - Winter 2025/26_, February 2026.

\[7\] Whali, _Graduate Scheme Deadlines 2026-2027: UK Calendar by Industry_, April 2026.

\[8\] The Employment Law Solicitors, _Job Applications: 65% Of Graduates Use AI_, January 2026.

\[9\] Office for National Statistics, _Vacancies and jobs in the UK: May 2026_, May 2026.

\[10\] Raconteur, _How are hiring teams coping with the influx of AI-generated job applications?_, March 2025.

\[11\] City AM, _Should you use AI for job applications? Here's what UK hiring managers think_, February 2025.

\[12\] WaveTrackR, _Q1 2025 Recruitment Trends Report_, April 2025.

\[13\] WaveTrackR, _Q4 2025 Recruitment Trends Report_, February 2026.

How many applications does the average job advert receive?

iStock-1060624050 (1).jpg

An ex employee's new employer emails asking for a reference. A line manager takes a quick phone call from a recruiter and answers a few "off the record" questions about someone who left last year. HR receives a template from a bank requesting six years of employment history for a candidate applying to a senior role.

Each of these scenarios carries different legal risks, yet some businesses handle them informally, inconsistently, or without a written policy. That inconsistency is often where risk creeps in. Handled badly, a reference can expose the former employer to claims and leave future employers hiring someone whose history has been fabricated.

Reference practice has also become more scrutinised as data protection regulators tighten guidance. The Information Commissioner's Office updated its right of access guidance in [December 2025](https://ico.org.uk/media2/5txar1ff/right-of-access.pdf) \[1\], and the Data (Use and Access) Act 2025 came into force in February 2026, changing how employers must respond to subject access requests that touch on reference material \[2\].

## Summary

*   GB employers are generally not legally required to provide references. Exceptions apply for FCA- and PRA-regulated firms, roles under the Senior Managers and Certification Regime, and any contractual or settlement obligations \[3\].
*   Once an employer chooses to provide a reference, it should be true, accurate, fair, and not misleading \[4\].
*   Employers may owe a duty of care to both the subject and the requesting employer. Providing incorrect information about a dismissed employee can expose employers to claims \[5\].
*   Centralised handling may reduce risks. Informal verbal references from line managers are one of the most common sources of reference-related claims \[5\].
*   Data protection rules apply. Personal data in references require a lawful basis, and confidential references are treated differently under UK GDPR \[6\].
*   Reference fraud is a growing concern. Cifas research published in 2025 found that 19% of UK professionals have either used a fraudulent reference house or know someone who has, and 30% consider the practice justifiable \[7\].
*   FCA rules under [SYSC 22](https://handbook.fca.org.uk/handbook/sysc22) require regulatory references covering six years, with no time limit on serious misconduct \[8\].

## Is there a duty to provide a reference?

For most employers in Great Britain, there is no general obligation to provide a reference. An employer may therefore decide, as a matter of policy, whether it will provide references on request, provide only limited factual references, or decline reference requests altogether. However, there are circumstances in which a reference may be required.

*   **Contractual obligation**. If the employment contract or a separate agreement requires a reference in a specified form, the employer must provide it. Settlement agreements commonly contain an agreed form of reference annexed to the agreement. Where this occurs, an employer should take care to comply with the agreed wording and any associated obligations. Departing from that wording - even verbally - could, depending on the circumstances and the terms of the agreement, create contractual risk \[9\].
*   **Regulatory obligation**. Firms authorised by the Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA) may be required to provide regulatory references in prescribed form for candidates entering specified regulated roles. These are governed by [FCA Handbook SYSC 22](https://handbook.fca.org.uk/handbook/sysc22) and cover a minimum of six years of employment history, with no time limit on the disclosure of serious misconduct \[8\].
*   **Risks associated with discrimination**. Refusing selectively in a way that ties back to a [protected characteristic](https://www.natwestmentor.co.uk/news/sexual-harassment-legislation-a-roadmap-for-employers) could give rise to a discrimination or victimisation claim under the Equality Act 2010, or could amount to a detriment on other protected grounds such as whistleblowing or trade union activity. Whether a claim could arise, and the nature of that claim, will depend on the facts \[10\].

The practical implication tends to be straightforward: consistency might matter more than the decision itself. An employer may be able to decide to provide references for everyone, provide references for no one, or provide only factual "tombstone" references. What can create risk is providing detailed references for some employees and refusing or downgrading for others.

## The duties that apply once a reference is given

Once an employer chooses to provide a reference, three distinct duties apply.

### The duty to the subject of the reference

In [Spring v Guardian Assurance (1994)](https://www.bailii.org/uk/cases/UKHL/1994/7.html), the House of Lords established that an employer providing a reference owes a duty of care in the tort of negligence to the subject of that reference \[4\]. The employer must take reasonable care in preparing it, which typically involves making reasonable enquiries into the factual basis of any statements before including them. A former employee who suffers financial loss - typically the withdrawal of a job offer - because of a negligently prepared reference can bring a claim for damages.

### The duty to the requesting employer

The employer receiving a reference also may have legal recourse if it is misled. A referring employer who provides a glowing reference for someone dismissed for misconduct, and the new employer relies on it and suffers loss, may face a claim from the new employer for negligent misstatement \[5\]. This is part of the reason why many organisations have moved to short, factual references only - it reduces the temptation to soften the reality of a departure to help someone move on.

### The duty under data protection law

References contain personal data. Under UK GDPR and the Data Protection Act 2018, employers need a lawful basis to process that data - typically legitimate interests or, where health information is involved, more specific conditions \[6\].

The ICO recognises an exemption for confidential references - these may be exempt from disclosure under a subject access request when given for the purposes of education, training, employment, appointment to office, or the provision of a service. The exemption applies whether the reference was given or received. However, it only applies where the reference is genuinely treated as confidential, which the employer should make clear in privacy notices, [staff handbooks](https://www.natwestmentor.co.uk/news/drafting-an-employee-handbook-what-employers-need-to-know), or a reference policy \[6\].

Since the Data (Use and Access) Act 2025 took effect in February 2026, employers must apply a "reasonable and proportionate" search standard when responding to subject access requests, but the confidential reference exemption continues to apply \[2\].

## Handling outgoing reference requests

### Decide on the standard format

The policy should specify the type of reference the business provides. A typical factual reference might confirm:

*   the individual's job title
*   start and end dates of employment.

One important point is consistency. If the standard is factual references, that standard should apply to everyone - including senior leavers, popular leavers, and those the business would rather see move on.

### Handle requests for detail

When a requesting employer pushes for more information than the standard policy provides, the answer may be a polite refusal: "It is our policy to provide factual references only" \[5\].

If the business does choose to answer specific questions, the answers should be based on documented fact, supportable by contemporaneous records (performance reviews, disciplinary notes, attendance data), limited to what is genuinely relevant to the role, and handled carefully where sensitive information is involved.

An employer providing a reference may disclose the number of days an employee has been absent due to sickness without necessarily breaching data protection legislation, as this information does not, in itself, reveal special category health data. However, caution should be exercised when disclosing the reasons for an absence or any details relating to an employee's illness, injury, or medical condition.

Information about an individual's health is classified as special category data under the UK General Data Protection Regulation (UK GDPR) and should only be shared where it is necessary, proportionate, and supported by a lawful basis, such as the employee's explicit consent or a specific employment law obligation. Medical records or detailed health information should not be included in a reference without the employee's express consent.

Employers should also ensure that any information disclosed does not give rise to unlawful discrimination, including disability discrimination under the Equality Act 2010.

## Handling incoming references from candidates

The rise of fake reference services means the receiving employer also needs a robust process.

The Cifas _Workplace Fraud Trends Report 2025_, based on a nationally representative survey of 2,000 UK employees, found that 19% of UK professionals have either used a fraudulent reference house or know someone who has, and 30% consider the use of reference houses to fabricate qualifications to be justifiable \[7\]. The Better Hiring Institute, Cifas, and Reed Screening have identified reference houses and AI-assisted fraud as among the fastest-growing risks in the hiring process \[12\]. Some of these services - companies that sell fabricated references, complete with functioning websites, phone numbers, and fake company presence - have reportedly become sophisticated enough to pass casual verification.

Here are a few practical steps to verify a reference.

*   **Contact the referee through independently verified channels**. Use a phone number from the company website, not one supplied on the reference itself, or an email address on the company domain.
*   **Cross-check the referee's identity**. LinkedIn profiles, corporate directories, or a direct call to the switchboard can confirm the person exists and holds the role claimed.
*   **Look for red flags**. Generic phrasing, mismatches between the reference address and the company's registered address, personal email domains for what should be a corporate contact, and reluctance to speak by phone.
*   **Verify the company itself**. A quick Companies House check confirms whether the business exists and whether the trading history is consistent with the candidate's claimed role.
*   **Consider a specialist screening provider for higher-risk roles**. Roles involving financial responsibility, safeguarding, or access to sensitive data may justify the additional cost.

[Conditional offers](https://www.natwestmentor.co.uk/news/how-to-employ-someone) should specify that they are subject to satisfactory references. This preserves the ability to withdraw the offer if references cannot be verified or contain material concerns.

## Building a reference policy

An effective policy does not need to be lengthy. It should cover:

1.  Who is authorised to provide references (usually HR or a named individual).
2.  The standard form of reference the business provides.
3.  The confidentiality position, so the UK GDPR exemption applies.
4.  How verbal reference requests are handled (typically declined, with a request to submit in writing).
5.  How the business verifies incoming references.
6.  What happens with settlement-agreement references and regulatory references, where applicable.
7.  [Record-keeping](https://www.natwestmentor.co.uk/news/hr-records-retention): what copy is retained, for how long, and in what system.

The policy should be referenced in the [staff handbook](https://www.natwestmentor.co.uk/news/drafting-an-employee-handbook-what-employers-need-to-know) and covered during manager training. Templates for standard responses can save time and help ensure consistency across the business.

_This article is intended for informational purposes only and does not constitute legal advice. The information is accurate at the time of writing but may be subject to change. For advice specific to your situation, please consult a qualified professional._

\[1\] Information Commissioner's Office, _Right of access guidance_, December 2025.

\[2\] Data (Use and Access) Act 2025, in force February 2026.

\[3\] ACAS, _References for work_.

\[4\] _Spring v Guardian Assurance plc_ \[1994\] UKHL 7; \[1995\] 2 AC 296.

\[5\] EmployerKit, _Employment References: What UK Employers Can and Cannot Say_, 2026.

\[6\] Information Commissioner's Office, _Subject access request Q and As for employers_.

\[7\] Cifas, _Workplace Fraud Trends Report 2025_, November 2025 (survey of 2,000 UK employees conducted by Opinion Matters).

\[8\] FCA Handbook, _SYSC 22 - Regulatory References_.

\[9\] Sprintlaw UK, _Providing References in the UK: Employer Obligations and Risks_, December 2025.

\[10\] Equality Act 2010.

\[11\] ACAS, _References for work - employer guidance_.

\[12\] Better Hiring Institute, Cifas and Reed Screening, _Tackling Hiring Fraud_, 2024-2025.

Employer's guide to reference requests

The cost of a workplace accident is spread across multiple categories: sick pay, lost output, cover for absent staff, insurance excesses, investigation time, regulatory fees, legal costs, and, in the most serious cases, fines that can reach several million pounds. Some of these costs are recoverable through insurance, and many are not.

The Health and Safety Executive (HSE) estimates the total annual cost of workplace injuries and new cases of work-related ill health in Great Britain at [£22.9 billion for 2023/24](https://www.hse.gov.uk/statistics/cost.htm), based on its three-year rolling cost model published in January 2026 \[1\]. That figure covers around [680,000 workers](https://www.hse.gov.uk/statistics/overview.htm) who sustained an injury at work during 2024/25, alongside 1.9 million experiencing work-related ill health \[2\].

For individual employers, the more relevant figures are the average cost per case and the additional costs that arise once regulatory action or civil claims are involved.

In this article, we’ll discuss the current data on the cost of workplace accidents in the GB: the HSE's unit cost estimates, the share borne by employers, the enforcement landscape as of 2025 and 2026, and the categories of expense that often fall outside standard insurance cover.

## Summary

*   The HSE estimates workplace injuries and new cases of work-related ill health cost Great Britain £22.9 billion in 2023/24, split £6.5 billion for injury and £16.4 billion for ill health \[1\].
*   The average unit cost is approximately £10,000 per injury and £24,200 per case of work-related ill health \[1\].
*   Individuals bear the largest share (£13.4 billion), followed by government (£5.2 billion) and employers (£4.3 billion) - though employer costs are magnified by uninsured losses \[1\].
*   HSE estimates uninsured losses of £8 to £36 for every £1 recovered from insurers, equivalent to around £315 per employee per year in smaller firms \[3\].
*   The Fee for Intervention rate stood at £183 per hour in April 2025 and rose to £188 per hour from April 2026, applied when a material breach is identified \[4\]\[5\].
*   Average HSE prosecution fines reached £170,000 in the 12 months from August 2024, with total annual fines averaging £44.1 million between 2021 and 2025 \[6\]\[7\].
*   The largest single fine of 2025 was £6 million (Cambridgeshire County Council), followed by £3.2 million (British Airways) and £2.5 million (Industrial Chemicals Ltd) \[8\].
*   Slips, trips and falls on the same level account for 30% of non-fatal workplace injuries, followed by manual handling at 17% and being struck by a moving object at 10% \[9\].
*   Compensation for serious workplace injuries can range from a few thousand pounds for minor cases to over £250,000 for severe permanent harm, based on Judicial College Guidelines \[10\].
*   The cost model excludes long-latency illness such as occupational cancer, meaning the true economic cost of workplace exposure is higher than the headline figure suggests \[1\].

## The HSE cost model: What £22.9 billion covers

The £22.9 billion headline figure comes from the HSE's _Costs to Britain of workplace fatalities and self-reported injuries and ill health_, updated in January 2026 with data covering 2023/24 \[1\]. It represents new cases arising from current working conditions and uses a three-year rolling average, so the 2023/24 reference year captures data from 2021/22 through 2023/24.

The two categories that make up the total include:

*   **injury**: £6.5 billion, equivalent to a unit cost of around £10,000 per case
*   **ill health**: £16.4 billion, equivalent to a unit cost of around £24,200 per case \[1\].

Ill health accounts for approximately 72% of total costs despite injury cases being more visible in day-to-day operations - ill health cases typically involve longer absence and greater long-term impact.

The model includes both financial costs (loss of output, healthcare, benefits payments) and human costs - the monetary valuation applied to pain, grief, suffering and loss of life. It excludes long-latency conditions such as occupational cancer and asbestos-related disease, meaning the actual economic burden of workplace exposure is materially higher than £22.9 billion.

### Who pays

The HSE's distributional analysis for 2023/24 shows the £22.9 billion is not borne evenly \[1\]:

*   **individuals and their families**: £13.4 billion (approximately 59%)
*   **government and taxpayers**: £5.2 billion (approximately 23%)
*   **employers**: £4.3 billion (approximately 19%).

Individuals bear the largest share, driven primarily by human costs and financial losses that fall outside employer sick pay or insurance cover. Government costs include NHS treatment, benefits payments, and lost tax revenue. Employer costs cover sick pay, cover for absent staff, insurance premiums, uninsured losses, and administrative time. The 19% aggregate share reflects average cost distribution across the economy rather than what any individual employer pays when an incident occurs at their premises.

## Uninsured losses

Employers' Liability insurance is a legal requirement and covers compensation, medical costs, and defence legal fees. It does not cover the majority of costs that arise from a workplace accident. The HSE estimates that for every £1 an employer recovers from insurers, [uninsured losses run at £8 to £36](https://riskassessmenttraining.co.uk/blog/cost-of-workplace-injury-and-ill-health-statistics-uk) \[3\].

Uninsured costs typically include [statutory sick pay](https://www.natwestmentor.co.uk/news/statutory-sick-pay-ssp-changes) and any enhanced contractual sick pay, cover for absent employees, lost production and disrupted schedules, damaged product or materials, overtime for existing staff, recruitment and training costs where an injured worker cannot return, management time spent on investigation, increased insurance premiums at renewal, and reputational impact with customers or contractors.

Applying the HSE and RoSPA costing model, uninsured accident costs are estimated at around £315 per employee per year in smaller firms, before any fine, insured claim, or one-off compensation payment is factored in \[3\].

## The most common causes and where costs concentrate

Five causes account for the majority of non-fatal workplace injuries in Great Britain, according to 2024/25 HSE data drawn from [RIDDOR employer reports](https://ukc-word-edit.officeapps.live.com/we/...) \[9\]:

*   slips, trips and falls on the same level: 30%
*   handling, lifting or carrying: 17%
*   struck by moving object: 10%
*   acts of violence: 10%
*   falls from height: 8%.

[Slips, trips and falls](https://www.manualhandlingtraining.org.uk/blog/slips-trips-and-falls-statistics-uk) remain the single largest cause of non-fatal workplace injury and have been for many years \[11\]. Applied to the 680,000 non-fatal workplace injuries in 2024/25, approximately 204,000 were slips, trips or falls on the same level. Falls from height account for a smaller share of non-fatal injuries but a much larger share of fatalities - [35 of 124 worker deaths](http://www.safeworkforce.com/insights/news/hse-accident-incident-statistics-2024-25/) in 2024/25 \[12\].

Cost concentration follows sector risk profiles. Accommodation and food services now has the highest rate of workplace non-fatal injuries, with construction, transportation and storage, and retail also showing above-average rates \[12\]. [Construction accounted for 35 fatalities](https://www.freshlawblog.com/2025/09/30/latest-hse-work-related-fatal-injury-statistics/) in 2024/25, making it the sector with the highest number of worker deaths \[13\].

## Regulatory costs: Fee for Intervention and prosecution fines

Where an HSE inspector identifies a material breach of health and safety law, the Fee for Intervention (FFI) scheme allows the regulator to recover the cost of its investigation directly from the business. The hourly rate has increased steadily since the scheme was introduced in 2012 at £124 per hour. It reached [£183 per hour](https://www.weightmans.com/media-centre/news/hse-investigations-and-fee-for-intervention-why-health-and-safety-breaches-will-now-cost-organisations-more/) on 1 April 2025 \[4\] and rose to [£188 per hour](https://www.hse.gov.uk/enforce/charging/rates.htm) on 1 April 2026 \[5\].

FFI charges apply from the point a material breach is identified through to closure of the case, covering inspector time on site, follow-up work, statement-taking, notice-issuing, and specialist support. The [average FFI invoice](https://www.haspod.com/blog/management/hse-fee-intervention-charges-explained) is around £700 to £875 \[14\]\[15\], and more complex cases involving multiple visits or extended investigation can result in higher figures. Businesses receive an invoice every two months and are expected to pay within 30 days of receipt.

### Prosecution fine levels

The HSE achieved a [96% conviction rate](https://www.healthandsafetyinternational.com/article/1941130/hse-achieves-96-conviction-rate-reports-33m-fines-2025) in 2024/25, securing 246 prosecutions and reporting £33 million in fines during that period \[16\]. Analysis covering the 12 months from August 2024 puts the [average prosecution fine at £170,000](https://www.citation.co.uk/health-and-safety/fees-for-intervention/) \[6\]\[17\].

Freedom of Information data covering 2021 to 2025 shows British businesses were fined [an average of £44.1 million](https://www.cfwaccountants.co.uk/news/britain-s-yearly-ps44m-health-safety-violations-bill) per year for health and safety breaches, with 2025 recording £40.9 million \[7\]. The number of serious breaches resulting in prosecution charges rose year on year: 428 in 2023, 446 in 2024, and 496 in 2025 \[7\].

The [largest fines of 2025](https://shepwedd.com/knowledge/2025s-five-most-important-uk-health-safety-prosecutions/) included \[8\]:

*   **Cambridgeshire County Council**: £6 million plus £300,000 costs, following three deaths on the Guided Busway over a ten-year period
*   **British Airways**: £3.2 million, following serious injuries to baggage handlers
*   **Industrial Chemicals Ltd**: £2.5 million, following a major acid leak

Under the Sentencing Council guidelines for health and safety offences, fine levels are scaled to organisational turnover and to the level of culpability and harm involved. Large organisations (turnover above £50 million) can face fines in the millions for equivalent offences that would attract lower penalties for an SME.

## Civil claims and compensation

Beyond regulatory action, employers face civil liability for injuries their employees suffer as a result of workplace failings. Compensation awards are calculated in two parts: general damages (for pain, suffering, and loss of amenity) and special damages (for actual financial losses including lost earnings, medical costs, and rehabilitation).

General damages are assessed against the [Judicial College Guidelines](https://www.jflaw.co.uk/list-of-compensation-payouts-uk/) (JCG), currently in their 18th edition published in April 2026 \[18\]. Illustrative brackets from the JCG show the scale of exposure:

*   Minor injury (e.g. mild concussion): £3,000-£12,000 general damages, with total awards often reaching £4,000-£13,000 once special damages are added
*   Moderate injury: £15,000-£36,000 general damages, with total awards reaching £26,000-£48,000
*   Serious permanent injury: £50,000-£120,000 general damages, with total awards potentially exceeding £150,000
*   [Severe back injuries](https://www.fentons.co.uk/list-of-compensation-payouts-in-the-uk/): up to £196,450 in the most serious cases \[10\]\[19\]
*   [Brain injury and loss of limb](https://www.mrhsolicitors.co.uk/list-of-compensation-payouts-uk/) cases: over £250,000 \[20\]

Individual settlements can reach much higher figures where lifelong care, home adaptations, or permanent loss of earnings are involved.

## Working days lost

In 2024/25, an estimated [40.1 million working days](https://press.hse.gov.uk/2025/11/20/hse-publishes-annual-workplace-health-and-safety-statistics/) were lost across Great Britain due to workplace injury and ill health \[21\]. Of these, approximately 35.7 million were lost to work-related ill health and 4.4 million to workplace injuries. That total is [equivalent to 200,000 full-time workers](https://www.nvlegal.co.uk/the-real-cost-of-workplace-harm-in-the-uk-22-9-billion/) missing an entire year of work \[22\]. For individual employers, the average injury results in several days off, with more serious cases leading to weeks or months of absence, often followed by phased returns.

CIPD data for 2025 puts [average sickness absence](https://www.natwestmentor.co.uk/news/supporting-employees-during-long-term-sickness) at 9.4 days per employee, the highest in more than 15 years, up from 7.8 days in 2023 \[3\]. Public sector absence averaged 13.3 days against 9.1 in the private sector.

## Under-reporting of workplace injuries

There is a persistent gap between self-reported and formally reported workplace injuries. The Labour Force Survey records around 680,000 self-reported non-fatal injuries in 2024/25, but employers formally reported only 59,219 under RIDDOR during the same period \[12\]. Many less serious injuries fall below the RIDDOR reporting threshold, which generally requires injuries resulting in more than seven days of incapacity, or specified injuries such as fractures and amputations. Some incidents that should be reported are not. The operational impact on any given business is often larger than RIDDOR figures alone would indicate.

## Small business exposure

For smaller employers, a serious injury can absorb a disproportionate share of resources through cover requirements, management time, and operational disruption. Where multiple staff are involved in a single incident, the effect compounds.

Applying the HSE cost model, a 20-person business carries an implicit uninsured accident cost of roughly £6,300 annually before any specific incident occurs \[3\]. A single [prosecution fine at the average level](https://www.natwestmentor.co.uk/news/how-much-could-a-disciplinary-process-cost-your-business) (£170,000) would exceed a full year of typical operating profit for many SMEs. Employers' Liability insurance premiums also vary considerably by sector and claims history: office-based businesses typically pay from £60-£150 per year for basic cover, while construction, manufacturing, and care businesses can pay several thousand pounds annually for equivalent policies.

## Costs not included in the HSE model

The HSE cost model does not capture every category of expense an employer may incur. Areas not included or understated in the £22.9 billion figure are long-latency illness (occupational cancer, asbestos-related disease, hearing loss from exposure decades earlier), reputational cost (lost customers, contractor de-listing, difficulty recruiting), management time spent on investigation and liaison, staff turnover following a serious incident, and legal or consultancy fees incurred defending regulatory action.

These costs are difficult to quantify at aggregate level but often represent a substantial portion of the total bill from a specific incident.

## Preventive spend as a comparison point

Basic risk assessments, staff training, equipment inspections, and [workplace adjustments](https://www.natwestmentor.co.uk/news/reasonable-adjustments-in-the-workplace) typically cost a fraction of what a single serious incident will cost to manage. Manual handling training sessions run from around £30-£175 per person, and a workplace needs assessment through the [Access to Work scheme](https://www.gov.uk/access-to-work) is available at no cost to eligible employees \[23\]. Noise-cancelling equipment, adjustable workstations, and improved lighting all fall well below the £315-per-employee uninsured cost estimate for accidents.

The HSE reports that most workplace incidents are preventable. The cost ratio between prevention and response varies by sector and incident type.

_This article is intended for informational purposes only and does not constitute legal advice. The information is accurate at the time of writing but may be subject to change. For advice specific to your situation, please consult a qualified professional._

\[1\] Health and Safety Executive, _Costs to Britain of workplace fatalities and self-reported injuries and ill health, 2023/24_, updated January 2026.

\[2\] HSE, _Key figures for Great Britain 2024/25_, 2025.

\[3\] Risk Assessment Training, _Cost of workplace injury and ill health statistics UK_, 2026.

\[4\] Weightmans, _HSE Investigations and Fee for Intervention: new rates effective 1 April 2025_, 2025.

\[5\] HSE, _HSE fees and charges: current rates_, updated 1 April 2026.

\[6\] Citation, _Fee for Intervention (FFI) Support_, October 2025.

\[7\] CFW Accountants, _Britain's yearly £44m health & safety violations bill_, July 2026.

\[8\] Shepherd and Wedderburn, _2025's five most important UK health and safety prosecutions_, January 2026.

\[9\] Arinite, _HSE Statistics 2025: complete guide to workplace health and safety data_, May 2026.

\[10\] Fentons, _List of Compensation Payouts in the UK - 2026 Update_, May 2026.

\[11\] Manual Handling Training, _Slips, Trips & Falls Statistics UK 2026_, April 2026.

\[12\] SafeWorkforce, _HSE Accident & Incident Statistics 2024/25: What they mean for UK businesses_, November 2025.

\[13\] fresh, _Latest HSE Work-related Fatal Injury Statistics_, September 2025.

\[14\] InstallerSHOW, _HSE Fee for Intervention_, 2026.

\[15\] HASpod, _HSE Fee For Intervention Charges Explained_, October 2025.

\[16\] Health and Safety International, _HSE achieves 96% conviction rate and reports £33m in fines for 2025_, November 2025.

\[17\] Manual Handling Training, _Cost of Workplace Injuries to UK Businesses 2026_, April 2026.

\[18\] JF Law, _A Complete List of Compensation Payouts in the UK_, 2026.

\[19\] UK Legal Guides, _How Workplace Injury Compensation Is Calculated (2026)_, March 2026.

\[20\] MRH Solicitors, _List of Compensation Payouts UK_, 2025.

\[21\] HSE Media Centre, _HSE publishes annual workplace health and safety statistics_, 20 November 2025.

\[22\] Nv Legal, _The real cost of workplace harm in the UK - £22.9 billion_, February 2026.

\[23\] GOV.UK, _Access to Work factsheet for customers_, 2025.

Average cost of workplace accidents: What GB employers actually pay

GettyImages-1134027904-cropped.jpg

Average cost of workplace accidents: What employers actually pay

Section 48 of the Border Security, Asylum and Immigration Act 2025 [comes into force on 1st October 2026](https://www.legislation.gov.uk/uksi/2026/683/contents/made), alongside a revised [Code of Practice](https://assets.publishing.service.gov.uk/media/6a608779f869f6a53d0c89e7/30_June_-_Code_of_practice_on_preventing_illegal_working_-_Right_to_Work_Scheme_for_employers.pdf) on preventing illegal working. Together, they mark one of the most significant changes to UK immigration compliance in years, extending illegal working civil penalty risk well beyond the traditional direct employer relationship - reaching into labour supply chains, subcontracting arrangements and online job-matching platforms.  

In practice, this means agency workers, individual subcontractors, zero-hours staff, gig economy workers and platform-based labour will all fall within scope, regardless of how the engagement is labelled. Businesses that have only ever run [right to work checks](https://www.natwestmentor.co.uk/news/right-to-work-checks-your-duties-as-an-employer) on direct employees will need to map their entire labour supply chain and reassess where their compliance obligations now sit. 

## Summary

- From 1 October 2026, the definition of "employer" for right to work purposes widens to include certain subcontracting arrangements, worker's contracts, individual sub-contractors and online matching services - not just direct employment relationships. 
- Civil penalties for illegal working can reach up to £60,000 per worker, and businesses with complex labour supply chains, subcontractors or agency arrangements face the greatest exposure. 
- Employers facing extended liability must meet new "prescribed requirements" - written contractual terms, substitution controls and identity verification - to establish a statutory excuse against penalty. 
- Right to Work Digital Verification Service Providers (RtW DVSPs) must be registered.  

## What's changing on 1st October 2026?

### Who counts as an "employer" under the new rules?

Section 48 of the Border Security, Asylum and Immigration Act 2025 inserts a new section 14A into the Immigration, Asylum and Nationality Act 2006. From 1st October 2026, references to an "employer" of an "individual" for right to work purposes will include a business that: 

- employs someone under a contract of employment (a contract of service or apprenticeship) 
- engages someone under a worker's contract 
- engages an individual sub-contractor 
- operates an online matching service and puts individual service providers in touch with clients or customers. 

This goes well beyond the traditional direct employer, and organisations that don't consider themselves to be "employing" anyone in the conventional sense - because they rely on subcontractors, agency staff or an online platform to connect workers with clients - may still fall within scope. 

The Code of Practice also introduces a set of new defined terms, including "individual sub-contractor" (someone providing work or services under a contract, where that work ultimately fulfils a separate third-party contract they aren't party to) and "online matching service" (a business that keeps a register of service providers and charges a fee when it matches them with clients). Businesses using complex supply chains should expect these definitions to require careful, case-by-case interpretation. 

### How to establish a statutory excuse

Where extended liability applies, an employer can still protect itself from a civil penalty by completing “prescribed requirements” to obtain a statutory excuse - but doing so now requires more than completing a standard right to work check. Depending on the arrangement, businesses may need to put in place the following arrangements: 

- **Written contractual terms** with other employers or service providers in the supply chain, requiring them to carry out right to work checks, restricting further subcontracting without consent, and allowing audits and enforcement action.
- **Substitution controls**, where a contract allows a worker to be substituted by someone else, ensuring that any substitute has their right to work verified before starting.  
- **Identity verification systems**, to confirm that the person actually doing the work is the person whose right to work was checked - this could include ID passes, biometric systems or facial verification. 

The Code is not prescriptive about exactly which systems to use, but employers relying on another party's checks (such as a Right to Work Digital Verification Service Provider) must take reasonable steps to satisfy themselves that those checks are effective. 

### Registration requirements for digital verification providers

The Code also renames "Digital Verification Service" (DVS) providers as "Right to Work Digital Verification Service Providers" (RtW DVSPs). From 1st October 2026, it becomes mandatory for any RtW DVSP an employer uses to be registered on the Office for Digital Identities and Attributes (OFDIA) register, with confirmation that it's authorised to carry out right to work checks. Employers are not required to use a RtW DVSP if another appropriate checking method is available. 

## What are the penalties for illegal working?

The consequences for getting this wrong are significant. Civil penalties can reach up to £45,000 per illegal worker for a first breach, rising to £60,000 for repeat breaches within three years, and licensed sponsors risk having their sponsor licence revoked entirely. Where a business knew, or had reasonable grounds to suspect, that a worker lacked the right to work, the matter can escalate to criminal liability - carrying an unlimited fine and a prison sentence of up to five years. Immigration Officers also hold the power to issue a closure notice, shutting down business premises immediately for up to 48 hours. That closure can then be extended for up to 12 months through an illegal working compliance order granted by the Court.  

## What should employers be doing before 1st October 2026?

Here’s a list of actions employers could be taking now to ensure future compliance with these changes.  

- [**Mapping labour supply chains**](https://www.natwestmentor.co.uk/news/workforce-planning-basics), identifying where subcontractors, agency workers or online platforms are used, and assessing which arrangements could bring the business into scope of the wider "employer" definition. 
- **Reviewing and updating contracts with agencies, subcontractors and service providers** to include the required written terms. 
- Checking RtW DVSP registration for any digital verification providers used, to confirm they're on the OFDIA register and authorised to carry out right to work checks. 
- **Reviewing identity verification processes**, particularly where substitution clauses exist in contracts. 
- **Training relevant teams** - HR, procurement, contract management and operational managers - so they understand the wider scope of liability. 
- **Retaining evidence of compliance**, since the Code expects businesses to be able to demonstrate the steps they've taken on request. 

## The bottom line for employers

Taken together, these changes represent the most significant expansion of UK illegal working liability since the Immigration Act 2016. The core message for businesses is simple: right to work compliance can no longer be treated as an HR-only, direct-employee exercise. Any organisation that engages labour through subcontractors, agencies, or platforms needs to trace those relationships now, tighten its contracts, and confirm its verification processes meet the new prescribed requirements - because from 1st October 2026, "we didn't employ them directly" will no longer be a defence. 

  
_This article is intended for informational purposes only and does not constitute legal advice. The information is accurate at the time of writing but may be subject to change. For advice specific to your situation, please consult a qualified professional._

Colleagues reading and signing a legal contract

news image (4).jpg

Preventing illegal working and right to work checks: New rules from 1st October 2026 

The October reforms build on changes already introduced in February and [April 2026](https://www.natwestmentor.co.uk/news/employment-law-changes-in-april-2026-what-you-need-to-know), including reforms to statutory trade union recognition. They are also accompanied by further changes from August 2026, when statutory trade union ballots may be conducted electronically. Together, these measures represent a significant shift in the UK's trade union framework and may have important implications for employers.

The main package of changes taking effect on 30 October 2026 includes a new statutory right for trade unions to access workplaces, enhanced facilities for trade union representatives, stronger protections for workers taking industrial action, and changes to the trade union recognition framework. From January 2027, employers will also have a new duty to inform workers of their right to join a trade union.

With several of the underlying regulations and codes of practice only recently published, and some details still to be finalised, employers should start reviewing their policies and practices now rather than waiting until the last minute.

## Summary

- From October 2026, trade unions gain a new statutory right to request access to workplaces - physically and digitally - to meet, support, represent, recruit or organise workers. Employers with fewer than 21 workers are exempt.
- Employers must provide reasonable facilities and accommodation to trade union officials, learning representatives and the newly created role of equality representatives.
- Workers taking part in lawful industrial action gain new protection from detriment, not just dismissal.
- An updated Code of Practice on trade union recognition takes effect, alongside new restrictions on unfair practices during recognition ballots.
- From January 2027, employers must provide workers with a written statement setting out their right to join a trade union.

## October 2026 changes

### A new right of access to workplaces

Trade unions will gain a general right to request access to workplaces for the purpose of meeting, supporting, representing, recruiting or organising workers, and facilitating [collective bargaining](https://www.gov.uk/working-with-trade-unions/collective-bargaining). 

Employers and unions will remain free to agree access arrangements voluntarily, and any agreed arrangements can continue to operate outside the statutory regime, without needing to be formalised through it. However, a union will not be required to pursue voluntary discussions before using the statutory process.

This is a significant change. Unlike the current position, a union will be able to seek workplace access through a formal statutory procedure where agreement cannot be reached voluntarily. Ultimately, the Central Arbitration Committee (CAC) will have the power to determine the terms of access and impose a binding access arrangement.

Access can be physical or digital - for example, a union may ask to hold meetings on site, or to communicate with workers by email or virtual meeting. Importantly though, the statutory access purposes do not include organising industrial action. 

The government has published a [Code of Practice: Right of trade unions to access workplaces](https://assets.publishing.service.gov.uk/media/6a4b9abad200ca05e289e5e5/code-of-practice-right-of-trade-unions-to-access-workplaces.pdf), which sets out how the new right is expected to operate, including the standard forms for making and responding to a request. Employers should treat this Code as an important reference point when preparing for October.

The statutory process is subject to strict time limits:

1. The union submits a written access request to the employer.
2. The employer has 15 working days to respond in writing.
3. If the employer does not agree in full to the request, a 25 working-day negotiation period follows, during which the parties attempt to agree the terms of access.
4. If no agreement is reached, the union can refer the matter to the Central Arbitration Committee (CAC) within 55 working days of the original request. 
5. The CAC may determine the terms of access and impose a binding access arrangement.

In limited circumstances, the overall timetable could be extended to 70 working days. [1]

Employers with fewer than 21 workers are exempt from the access regime. The 21-worker threshold is assessed by reference to associated employers, meaning a business employing fewer than 21 workers may still be within scope if it forms part of a wider associated employer with 21 or more workers. 

For employers within scope, a blanket policy of refusing access to union representatives will no longer be a realistic option. Statutory access requests will need to be managed carefully and within the statutory timetable.

### Digital access

Digital access can include communications through channels the employer normally uses to communicate with staff, such as email, messaging systems, intranets or collaboration platforms. It can also involve facilitating online meetings between the union and workers. Where an employer cascades union communications, the Code says these should be provided in a standalone format rather than being incorporated into an unrelated workforce update.

Importantly, unions will not generally be given direct access to an employer's IT systems. Where a union wants to contact individual workers directly using their personal contact details, consent will generally be required for those details to be shared.

### Enforcement of access

The union or employer can complain to the CAC about a breach of an access agreement within three months of the breach.

If the complaint is upheld, the CAC can order steps to be taken to ensure compliance.

If there is another breach within 12 months, the CAC may impose the following financial penalties:

- The first penalty for breach of an access agreement will be capped at £75,000.
- The second penalty for repeated non-compliance will be capped at £150,000.
- The maximum penalty for each further breach of the same access agreement will be £500,000.

The three-tier framework will apply even if the subsequent breaches are of a different nature to the previous breaches. Breaches at multiple workplaces covered under the same access agreement can be treated cumulatively and enable a higher penalty to be imposed, though the penalty must be proportionate to the breach.

### Facilities and time off for union representatives

Employers who recognise a trade union already have to give union officials paid time off for union duties and related training. The ERA goes further, introducing a new duty to provide reasonable accommodation and facilities where a representative reasonably requests this to carry out their role.

This facilities duty applies not just to trade union officials, but also to trade union learning representatives and to the newly created category of trade union equality representatives, who support members on matters relating to equality in the workplace.

### Enhanced protection from detriment for industrial action

Dismissing a worker for taking part in lawful industrial action has long been automatically unfair, but the law has not, until now, protected workers from lesser detriments - such as action short of dismissal.

From 30 October 2026, workers will have a new right not to be subjected to a detriment where the employer's sole or main purpose is to prevent, deter or penalise them for taking part in protected industrial action. The protection is intended to cover detriments imposed for the purpose of penalising, preventing or deterring workers from taking protected industrial action. The detailed scope of prohibited detriments will be set out in the regulations. 

### Revised Code of Practice on trade union recognition

Following the simplification of the statutory recognition process introduced in April 2026, a revised Code of Practice on access and unfair practices during trade union recognition and derecognition processes is expected to come into force in October 2026, subject to final parliamentary approval. The revised draft Code has already been published and laid before Parliament. Alongside this, new restrictions on unfair practices during recognition ballots will apply, aimed at ensuring the process is conducted fairly by both employers and unions. [2]

The October reforms will also freeze the bargaining unit at the point a statutory recognition application is received. Workers who join the bargaining unit after the application date will generally be disregarded for the purposes of the recognition process. This is intended to prevent changes to the workforce from altering the composition of the bargaining unit after a recognition application has been made.

Employers who are, or may become, subject to a recognition claim should familiarise themselves with the revised Code now and monitor its progress through Parliament, as it is expected to set the benchmark for what regulators and tribunals consider reasonable conduct during a recognition campaign.

## January 2027 changes

### Duty to inform workers of their right to join a trade union

For the first time, employers will have a proactive legal duty to tell workers that they have the right to join a trade union - regardless of whether the employer recognises a union or has any unionised staff.

This must be provided as a written statement. Government proposals for the statement include an explanation of what trade unions do, a summary of workers' statutory rights relating to union membership, details of any unions recognised by the employer and a signpost to further government information. The precise requirements will be set by secondary legislation, and the Government intends to provide the statement for employers to issue. 

Crucially, this is not a one-off task for new starters. The duty is expected to extend to the existing workforce too, and the statement will need to be reissued at prescribed intervals, so employers will need a process for keeping this current.

**Please note** - employers cannot be sued solely for failing to provide this information. However, where a worker successfully brings another relevant employment tribunal claim, the tribunal may award an additional two to four weeks' pay for the failure, subject to the statutory cap on a week's pay. This mirrors the enforcement mechanism that applies to section 1 statements of employment particulars.

## What should employers do now?

Several of these reforms are still subject to final regulations, so some detail may shift before October. That said, employers shouldn't wait for every last piece of guidance before acting. Sensible steps now include:

- **Identifying whether your organisation is within scope of the new statutory access regime**, including considering associated employers and the 21-worker threshold.
- **Reviewing internal communication channels and data-sharing arrangements** so you can respond appropriately to requests for digital access.
- **Reviewing recognition procedures and ensuring HR teams understand the changes to the statutory recognition process**, including the new rules on bargaining units and unfair practices.
- **Reviewing the relevant Code of Practice and supporting guidance**, including any template letters and forms as they become available.
- **Identifying the individuals or teams responsible for managing trade union access requests** and ensuring that any requests are promptly escalated to them.
- **Briefing managers on the organisation's approach** so that requests are not refused informally or handled inconsistently.
- **Training managers, HR teams and visitor-facing staff** (such as receptionists and security guards) to ensure union visits are handled appropriately (once arrangements are in place).

## Further reading

For more information on the wider changes taking effect throughout 2026, you may find the following articles helpful:

- [Employment Rights Act: October 2026 changes](https://www.natwestmentor.co.uk/news/employment-rights-act-october-2026-changes)
- [Employment law changes in April 2026: What you need to know](https://www.natwestmentor.co.uk/news/employment-law-changes-in-april-2026-what-you-need-to-know)
- [The Fair Work Agency: What this new enforcement body means for employers](https://www.natwestmentor.co.uk/news/the-fair-work-agency)
- [Statutory Sick Pay (SSP) changes from April 2026](https://www.natwestmentor.co.uk/news/statutory-sick-pay-ssp-changes)
- [Unfair dismissal changes 2027: The six-month qualifying period explained](https://www.natwestmentor.co.uk/news/unfair-dismissal-changes-2027)

## Frequently asked questions

- **When do the new trade union rules take effect?** The main package of reforms takes effect on 30 October 2026. It builds on earlier changes introduced in February and April 2026 (including reforms to statutory trade union recognition), and is accompanied by separate changes from August 2026, when statutory ballots may be conducted electronically. 
- **Do employers need to tell staff about their right to join a trade union?** Yes. From January 2027, employers have a new proactive legal duty to give workers a written statement setting out their right to join a trade union - even if the employer doesn't recognise a union or have any unionised staff. The statement is expected to cover what trade unions do, a summary of workers' statutory rights on union membership, details of any recognised unions, and a signpost to further government information.
- **Is this a one-off requirement for new starters?** No. The duty is expected to extend to the existing workforce as well as new joiners, and the statement may need to be reissued at prescribed intervals, so employers will need an ongoing process to keep it current.
- **What happens if an employer fails to provide the statement?** An employer cannot be sued solely for failing to provide it. However, if a worker successfully brings another relevant employment tribunal claim, the tribunal may award an additional two to four weeks' pay for the failure, subject to the statutory cap on a week's pay.
- **Do trade unions now have a right to access workplaces?** Yes. Unions gain a general statutory right to request access to workplaces from 30 October 2026 - physically or digitally - to meet, support, represent, recruit or organise workers, and to facilitate collective bargaining. Where a voluntary agreement can't be reached, the union can use a formal statutory procedure, and the Central Arbitration Committee (CAC) can ultimately determine and impose binding access terms. 
- **Which employers are exempt from the access regime?** Employers with fewer than 21 workers are exempt. This threshold includes workers from any associated companies, so a business with fewer than 21 workers could still be in scope if it's part of a wider group with 21 or more workers overall.
- **What are the time limits for a workplace access request?** The union submits a written request; the employer has 15 working days to respond; a 25-working day negotiation period follows; if unresolved, the union can refer the matter to the CAC within 55 working days of the original request; and in limited circumstances the overall timetable can extend to 70 working days.
- **What does "digital access" cover?** It can include communication through channels the employer already uses with staff - email, messaging systems, intranets or collaboration platforms - as well as facilitating online meetings. Union communications cascaded by the employer should be sent in a standalone format rather than folded into an unrelated staff update. Unions won't generally get direct access to an employer's IT systems, and sharing individual workers' personal contact details will generally require their consent.
- **What happens if an access agreement is breached?** Either party can complain to the CAC within three months of a breach, and the CAC can order compliance steps. If a further breach occurs within 12 months, the CAC can impose escalating financial penalties: up to £75,000 for the first breach, up to £150,000 for a second, and up to £500,000 for each further breach of the same agreement - even if the nature of the breaches differs, and potentially cumulative across multiple workplaces under the same agreement.
- **Do employers need to provide facilities to union representatives?** Yes. Employers already have to give union officials paid time off for union duties and training where a union is recognised. The ERA adds a new duty to provide reasonable accommodation and facilities on request, and this now extends beyond union officials to trade union learning representatives and the newly created role of trade union equality representatives.
- **Are workers protected if they take industrial action?** Dismissal for lawful industrial action has long been automatically unfair. From 30 October 2026, workers also gain a new right not to be subjected to a detriment (short of dismissal) where the employer's sole or main purpose is to prevent, deter or penalise them for taking part in protected industrial action. The detailed scope will be set out in regulations.
- **Is the trade union recognition process changing too?** Yes. A revised Code of Practice on access and unfair practices during recognition and derecognition processes is expected to come into force in October 2026, alongside new restrictions on unfair practices during recognition ballots. The bargaining unit will also be "frozen" at the point a recognition application is received, so workers joining afterwards are generally disregarded for that process.
- **What should employers do to prepare?** Key steps include checking whether the organisation is in scope of the access regime (including the 21-worker threshold and associated employers), reviewing internal communication and data-sharing arrangements, updating recognition procedures, reviewing the relevant Codes of Practice and template forms, assigning responsibility for handling access requests, updating internal policies, and training managers and visitor-facing staff.

_This article is intended for informational purposes only and does not constitute legal advice. The information is accurate at the time of writing but may be subject to change. For advice specific to your situation, please consult a qualified professional._

[1] Department for Business & Trade.  [Code of Practice: Right of trade unions to access workplaces](https://assets.publishing.service.gov.uk/media/6a4b9abad200ca05e289e5e5/code-of-practice-right-of-trade-unions-to-access-workplaces.pdf), July 2026. 

[2] GOV.UK. Consultation outcome. [Make Work Pay: recognition code of practice and e-balloting unfair practices](https://www.gov.uk/government/consultations/make-work-pay-recognition-code-of-practice-and-e-balloting-unfair-practices), February 2026. 

Colleagues discussing workplace issues with a trade union representative

New trade union rules coming in October 2026

New trade union rules coming in October 2026: What employers need to know 

Display Screen Equipment assessments for hybrid workers

iStock-1396082125 (1).jpg

Display Screen Equipment assessments: Are your hybrid workers covered?

How much could a disciplinary process cost your business?

GettyImages-937103108 (1).jpg

A Skilled Worker visa is rarely one fee. By the time a business has paid for a sponsor licence, a Certificate of Sponsorship and the Immigration Skills Charge - and the worker has paid their application fee and Immigration Health Surcharge - a single three-year hire can run from £6,500 to over £10,000.

This article breaks down what each one costs in 2026, who pays it, and when it falls due. It's intended as an informational overview for a business weighing [its first sponsored hire](https://www.natwestmentor.co.uk/news/how-to-employ-someone), rather than guidance on how to sponsor someone, which is a specialist area in its own right.

Sponsorship has also become less common as it has become more expensive. Applications on the Skilled Worker and Health and Care Worker routes fell from 228,917 for main applicants in the year ending December 2023 to 55,704 in the year ending December 2025, while the proportion refused rose from 7% to 19% over the same period \[8\]. For employers who still need skills the domestic labour market isn't supplying, and who would otherwise [leave roles vacant for months](https://www.natwestmentor.co.uk/news/time-to-hire-in-the-uk), the arithmetic is worth understanding properly.

## Summary

*   Sponsorship has become more expensive and less common: applications on the Skilled Worker and Health and Care Worker routes fell from 228,917 to 55,704 between the years ending December 2023 and December 2025, with refusals rising from 7% to 19% \[8\].
*   Sponsorship costs are split across several charges rather than one headline fee, and the total varies with sponsor size, visa length, and who covers the worker's own costs.
*   The employer pays for the sponsor licence, the Certificate of Sponsorship, and the Immigration Skills Charge. The worker typically pays the visa application fee and the Immigration Health Surcharge, though employers sometimes cover these.
*   A sponsor licence costs £611 for small or charitable sponsors and £1,682 for medium or large sponsors from 8 April 2026 - a one-off charge, not a per-hire cost \[1\].
*   The Certificate of Sponsorship sits at £525 per worker, and must be paid again for every hire \[1\].
*   The Immigration Skills Charge rose by around a third on 16 December 2025, to £480 per year for small or charitable sponsors and £1,320 per year for medium or large sponsors \[5\].
*   The Immigration Health Surcharge holds steady at £1,035 per year per person and is often the single largest cost across a multi-year visa \[3\].
*   Worked examples below show a three-year hire costing around £6,500 through a small sponsor and just over £10,000 through a medium or large one, split between employer and worker.
*   Costs fall per head as hiring volume rises, because the licence is a fixed one-off outlay spread across every worker sponsored.

## Why there's no single "sponsorship fee"

The first thing to understand is that sponsorship is a bundle of charges rather than one transaction. Some businesses budget for the headline visa fee, discover the additional charges midway through, and find their forecast wide of the mark.

Broadly, the costs fall into two groups. There are the **charges the sponsoring employer pays** - the sponsor licence, the Certificate of Sponsorship, and the Immigration Skills Charge. And there are the **charges the worker usually pays** - the visa application fee and the Immigration Health Surcharge \[6\].

The other reason there's no single figure is that the total flexes with several variables: whether the business counts as a small or a large sponsor, how long the visa runs, whether the role qualifies for a discounted route, and whether the employer chooses to cover the worker's own costs. Two businesses hiring for the same role can end up with very different bills.

With that framing in place, here's what each individual charge looks like in 2026.

## The sponsor licence: A one-off entry cost

Before a business can sponsor anyone, it needs a sponsor licence. This is a one-off application rather than a per-worker charge, and it's the first outlay in the process.

[From 8 April 2026](https://www.gov.uk/government/publications/visa-regulations-revised-table/home-office-immigration-and-nationality-fees-8-april-2026), the licence costs £611 for a small or charitable sponsor and £1,682 for a medium or large sponsor. These figures replaced the previous rates of £574 and £1,579 respectively - increases of £37 and £103, part of a wider round of immigration fee rises that spring \[1\].

Which rate applies depends on the organisation's size, assessed against the small companies regime in the Companies Act 2006. A business generally counts as a small sponsor if it meets [at least two of three tests](https://www.gov.uk/uk-visa-sponsorship-employers): an annual turnover of £15 million or less, a balance sheet total of £7.5 million or less, or 50 employees or fewer. Those thresholds rose on 6 April 2025 from £10.2 million and £5.1 million respectively, so older figures still circulate - worth knowing if a business is working from previous guidance \[7\]. Registered charities qualify for the lower rate regardless of size \[2\].

One point worth noting for smaller businesses: the licence is a fixed cost that doesn't scale with the number of workers sponsored. Whether a business sponsors one person or ten, the licence fee is the same. The cost per head therefore falls as hiring volume rises - a business sponsoring several workers effectively spreads that initial outlay across all of them.

There's also an optional priority service. For an additional £750, a business can request expedited processing of a sponsor licence application \[1\]. It's optional, and it's a cost some businesses factor in when timing matters.

## Certificate of Sponsorship

Once a business holds a licence, it assigns a Certificate of Sponsorship (CoS) to each worker it wants to sponsor. –This is an electronic record carrying a unique reference number that the worker uses to make their visa application, setting out the job, the salary, and the start and end dates \[6\].

The cost of assigning a Certificate of Sponsorship for a Skilled Worker is £525 per worker. That figure rose steeply from £239 in April 2025 - an increase of roughly 120% - and, notably, did not change in the April 2026 round \[1\].

Two things are worth noting. First, this is a per-hire charge: it applies every time a worker is sponsored, and again if a certificate needs reissuing. Second, employers are prohibited from recovering the CoS fee from the sponsored worker. This cost sits firmly with the employer \[6\].

## Immigration Skills Charge

The Immigration Skills Charge (ISC) is often the charge that catches businesses out, both because of its size and because it's paid upfront for the entire length of the visa.

The ISC rose by around a third on 16 December 2025 - its first increase since the charge was introduced in 2017. The current rates are £480 per year for small or charitable sponsors, up from £364, and £1,320 per year for medium or large sponsors, up from £1,000. For each additional six-month period beyond the first year, small sponsors pay £240 and large sponsors pay £660 \[5\].

Because the charge is paid in one go when the Certificate of Sponsorship is assigned, the numbers add up quickly over a multi-year visa. A small sponsor issuing a five-year certificate pays £2,400 in ISC upfront; a large sponsor pays £6,600 - due immediately, per worker, before the visa application is even made \[5\].

Like the CoS fee, the ISC is an employer cost that cannot be passed on to the worker. It's also worth knowing that the charge doesn't apply in every situation - certain occupations and circumstances fall outside it, including some PhD-level roles and workers switching from the student route \[6\].

## Visa application fee

The visa application fee is the charge most people picture when they think of a visa - and it's typically paid by the worker rather than the employer, though some businesses cover it as part of a competitive offer.

From 8 April 2026, the Skilled Worker visa application fee is £819 for a visa of three years or less applying from outside the UK, rising to £1,618 for a visa of over three years. Applying from inside the UK, the equivalent fees are £943 and £1,865. These replaced previous rates of £769 and £1,519 from outside the UK, and £885 and £1,751 from inside \[1\].

Reduced fees apply in certain cases. A role on the Immigration Salary List attracts a fee of £628 for three years or less and £1,235 for longer, while the Health and Care Worker route is cheaper still at £324 and £628 respectively - and these reduced rates apply whether the application is made from inside or outside the UK \[1\].

## Immigration Health Surcharge

The Immigration Health Surcharge (IHS) gives the worker access to the NHS during their stay, and across a multi-year visa it's frequently the single largest cost in the whole process.

[The IHS holds steady in 2026](https://www.gov.uk/healthcare-immigration-application) at £1,035 per year for an adult applicant, with a lower rate of £776 per year for under-18s. It's paid upfront and in full for the entire length of the visa. For a three-year visa, that's £3,105; for five years, £5,175. And it applies per person - so a worker bringing dependents attracts a separate surcharge for each one, which multiplies the figure considerably \[3\].

Like the visa application fee, the IHS is usually the worker's cost. But it frequently surfaces in salary negotiations, particularly for [senior or hard-to-fill roles](https://www.natwestmentor.co.uk/news/what-uk-employees-want-from-work), and some employers choose to cover it to make an offer more attractive. Applicants on the Health and Care Worker route are exempt from the surcharge altogether, along with their dependents - a substantial saving over the life of a visa \[3\].

## What a realistic total looks like

Individual figures are one thing; the combined total is what businesses actually need to plan for. Here's how the charges stack up for a typical scenario - a small sponsor, hiring one worker on a three-year visa from outside the UK, with no dependents and no priority service.

On the employer side: a sponsor licence at £611 (a one-off), a Certificate of Sponsorship at £525, and the Immigration Skills Charge at £480 per year, or £1,440 across three years. That comes to £2,576.

On the worker side: a visa application fee of £819 and the Immigration Health Surcharge at £1,035 per year, or £3,105 across three years. That's £3,924.

Combined, this example totals £6,500 - though the split means the employer's direct outlay is closer to £2,600 where the worker covers their own application fee and IHS.

The same hire at a medium or large sponsor looks rather different. The licence rises to £1,682 and the ISC to £1,320 per year, or £3,960 across three years, taking the employer's share to £6,167 against an unchanged £3,924 for the worker - a combined total of just over £10,000.

Stretch either scenario to five years and the numbers climb again, since both the ISC and the IHS are paid upfront for the full period. For a small sponsor that already holds a licence, a five-year hire means £2,400 in ISC and £525 for the certificate on the employer side, against £5,175 in IHS and £1,618 in application fees on the worker's - close to £9,700 between them.

## A few things that shift the total

Beyond the core charges, several factors move the final figure:

*   **Sponsor size.** The gap is significant - £611 versus £1,682 on the licence, and £480 versus £1,320 per year on the Immigration Skills Charge. Establishing which category a business falls into is the starting point for any accurate estimate.
*   **Visa length.** Because the ISC and IHS are both paid upfront for the full period, a longer visa means a larger day-one outlay.
*   **Dependents.** The Immigration Health Surcharge applies per person, and dependents also pay their own application fee, so a worker bringing a partner or children can add several thousand pounds.
*   **Discounted routes.** A role on the Immigration Salary List cuts the application fee substantially, and the Health and Care Worker route reduces it further while removing the IHS entirely - which changes the total dramatically.
*   **Who pays what.** The single biggest swing is often whether the employer covers the worker's application fee and IHS.
*   **Hiring volume.** Because the licence is a fixed one-off cost, the per-head figure falls as a business sponsors more workers.

## The wider cost picture

It's worth remembering that the Home Office charges are only part of the story. Businesses and workers also encounter [costs that fall outside the official fee schedule](https://www.gov.uk/skilled-worker-visa): English language tests, biometric appointments, document translations, and, where they choose to use it, professional advice to navigate the process \[4\]. These vary considerably by provider and circumstance, but they belong in any realistic budget - as does the fact that every one of these charges sits on top of the [ordinary cost of employing someone](https://www.natwestmentor.co.uk/news/how-much-does-it-cost-to-employ-someone), from salary and employer National Insurance to pension contributions.

There's also the matter of getting it right. Sponsorship carries ongoing responsibilities, and errors can prove costly - not just in fees, which are largely non-refundable once an application is decided, but in delays and the risk to a sponsor licence itself. Several of the figures here changed within the past eighteen months, and the rules around who pays which charge have tightened. Given that pace of change, the published rates are the only reliable reference point, and the complexity involved leads many businesses to seek specialist support.

## The case for sponsoring

The charges are the price of reaching candidates the domestic labour market can't supply. For roles where the skills genuinely aren't available at home - and the fall in application volumes suggests employers are now reserving sponsorship for exactly those cases - the alternative isn't a cheaper hire, it's an unfilled vacancy, with its own cost in lost output and overstretched colleagues. There are also other factors worth considering.

*   **Access to skills in genuine shortage.** Sponsorship is most often used where a role has proved hard to fill locally. Technology, engineering, healthcare and finance are among the sectors that have historically drawn most heavily on the route, reflecting persistent domestic shortages in those fields.
*   **A retention structure built into the visa.** A sponsored worker's permission is tied to their sponsoring employer, and the [Skilled Worker route is designed as a pathway to settlement](https://www.gov.uk/skilled-worker-visa) - workers can typically apply for indefinite leave to remain after a qualifying period of continuous residence \[4\]. That gives many sponsored employees a strong incentive to stay and progress with the employer who sponsored them, which can translate into lower turnover than a comparable open-market hire.
*   **A predictable, upfront cost.** Unlike some recruitment costs, most of the sponsorship charges are known in advance and paid at the outset. Once budgeted, they don't produce surprises later in the visa - which makes the total, however large, straightforward to plan around.
*   **A widening cost-per-head at volume.** The licence is a one-off, so a business that sponsors regularly spreads that fixed cost across every hire - making each additional sponsored worker cheaper than the first.

### The NHS case study

The NHS is the UK's biggest visa sponsor, and international recruitment has become structural to how it staffs itself rather than a stopgap. [As of September 2025](https://commonslibrary.parliament.uk/research-briefings/cbp-10568/), around 209,800 nurses, midwives and nursing associates on the Nursing and Midwifery Council register - roughly 24% - had trained overseas, while approximately 138,400 licensed doctors, some 42% of the total, qualified abroad. In 2024, around 20,100 internationally trained doctors joined the register, two-thirds of all new joiners that year. \[9\]

Those figures reflect a simple reality: training a doctor or nurse domestically takes years, and demand for care hasn't waited. For all the cost and administration sponsorship carries, it has given the health service a way to fill roles it could not otherwise fill.

_This article is intended for informational purposes only and does not constitute legal advice. The information is accurate at the time of writing but may be subject to change. For advice specific to your situation, please consult a qualified professional._

\[1\] GOV.UK, _Home Office immigration and nationality fees, 8 April 2026_, UK Visas and Immigration, March 2026.

\[2\] GOV.UK, _UK visa sponsorship for employers: apply for a licence_, 2026.

\[3\] GOV.UK, _Pay for UK healthcare as part of your immigration application_, 2026.

\[4\] GOV.UK, _Skilled Worker visa_, 2026. \[5\] Legislation.gov.uk, _The Immigration Skills Charge (Amendment) Regulations 2025_ (SI 2025/1078), 2025.

\[6\] GOV.UK, _Workers and Temporary Workers: guidance for sponsors (sponsorship costs, Certificates of Sponsorship and Immigration Skills Charge exemptions)_, 2026.

\[7\] Legislation.gov.uk, _Companies Act 2006, Part 15 - company size thresholds, as amended April 2025_, 2025.

\[8\] GOV.UK, _Immigration system statistics, year ending December 2025: why do people come to the UK? Work_, Home Office, 2026.

\[9\] House of Commons Library, _International recruitment in the NHS workforce_ (CBP-10568), 2026.

How much does it cost to sponsor a skilled worker visa in 2026?

991443798 (3).jpg

How much does it cost to sponsor a Skilled Worker in 2026?

Somebody in your business has probably pasted something into a chatbot this week. They may have used it to draft a customer email, summarise a long document, or make sense of a spreadsheet. They will have decided for themselves whether that was acceptable, how far to trust what came back, and whether to mention it to anyone.

Those decisions get made whether or not you have written anything down. A policy determines whether they are made consistently, and whether you know they have been made at all.

Employees in 76% of UK organisations are now using AI tools at work, and 62% among SMEs \[1\]. While 61% of employers permit staff to use generative AI, only 31% have worked on a formal policy for it in the past year \[2\]. That number has doubled in two years, so employers are catching up, but a substantial number are still permitting a technology they have set no rules around.

This article sets out what belongs in an AI policy, how to write one your staff will actually follow, and how to introduce it.

## Summary

*   Employees in 76% of UK organisations use AI tools at work, and 62% of SMEs, but only 31% of employers worked on a formal AI policy in the past year \[12\].
*   Restricting AI use does not reliably reduce it. Microsoft research found 71% of UK employees have used unapproved consumer AI tools at work, and 51% do so weekly \[3\].
*   The reasons employees give are practical rather than rebellious: 41% say consumer tools are what they use at home, and 28% say their employer offers no approved alternative \[3\].
*   The absence of a policy tends to penalise the most cautious staff, who avoid AI entirely while less cautious colleagues proceed without guidance.
*   A workable policy answers four questions: which tools may be used, what must never be entered into them, who checks the output, and what to do when something goes wrong.
*   Naming the specific tool and account type matters, because free and paid tiers differ in whether the information entered is used to train the model.
*   The list of information that must never be entered is the most important section, and it works only if it is specific enough to be recalled under time pressure.
*   The level of checking should be proportionate to consequence. Fabricated figures, quotes and citations appear in the same confident register as accurate ones.
*   Time savings depend heavily on the task. A DWP trial found average savings of 19 minutes a day, but on some tasks verification cancelled the benefit out \[4\].
*   Training is where most employers fall short. Despite sessions being available, most staff in the DWP trial taught themselves by trial and error \[4\].
*   A policy is only as good as its distribution: it needs acknowledgement records, a place in induction, and a six-month review cycle.

## Why the gap between use and policy matters

### Restriction does not remove the behaviour

A quarter (25%) of UK organisations do not allow employees to use generative AI and have no plans to \[2\]. The evidence suggests this is less effective than it appears.

[Microsoft research conducted by Censuswide](https://ukstories.microsoft.com/features/rise-in-shadow-ai-tools-raising-security-concerns-for-uk/) among 2,003 UK employees in October 2025 found that 71% had used unapproved consumer AI tools at work, and 51% continued to do so every week \[3\]. The reasons employees gave were practical. Four in ten (41%) said consumer tools are what they are used to in their personal life. More than a quarter (28%) said their employer provided no work-approved option \[3\].

![image (1).png](https://www.natwestmentor.co.uk/media/image_1_bcabcead03.png)
_Reported use of free versus paid-for AI tools by UK employers. Source: CIPD, Labour Market Outlook Autumn 2025. \[1\]_

### The absence of a policy affects cautious staff most

Where no policy exists, employees tend to divide into two groups. Some treat the absence of a rule as permission and use AI freely, while others treat it as a risk and avoid AI altogether. The dividing line is disposition rather than seniority or competence.

The employees who abstain work more slowly as a result, while colleagues who are more comfortable making their own judgement calls are the ones deciding what customer information is safe to enter into a chatbot. The business gets neither the productivity benefit from the first group nor any oversight of the second.

### The time saved depends on the task

AI output has to be checked, and checking takes time. Where that time exceeds the time saved, the tool has cost the business rather than helped it.

The DWP published an [evaluation of its Copilot trial](https://www.gov.uk/government/publications/an-evaluation-of-dwps-microsoft-copilot-365-trial/an-evaluation-of-dwps-microsoft-365-copilot-trial) in January 2026 \[4\]. 3,549 staff took part, and outcomes were compared against a group of 2,535 non-users rather than relying on users' impressions alone. The findings relate to office-based staff using a paid licence, so a smaller business on free tools should read them as indicative rather than directly transferable.

Copilot users saved an estimated average of 19 minutes per day across eight routine tasks.

The savings were not evenly distributed. They were largest for searching for existing information (26 minutes) and writing emails (25 minutes), and smallest for transcribing or summarising meetings (9 minutes) \[4\]. Users also reported that Copilot performed poorly on data-heavy work in Excel.

![image (2).png](https://www.natwestmentor.co.uk/media/image_2_b777662b3f.png)
_Estimated daily time saved by task. Source: DWP, An Evaluation of DWP's Microsoft 365 Copilot Trial, 2026. \[4\]_

The evaluation records the other side of this directly. Some users found that verifying the output removed the benefit, with one participant reporting that having checked the result, they concluded the task would have been quicker done manually from the start \[4\]. The report also found that output accuracy depended heavily on how the request was phrased, and that vague prompts produced fabricated or irrelevant results.

These findings are the reason guidance is worth writing. Employees given no direction on which tasks AI handles well will establish that individually, and some will spend longer checking a poor output than the task would have taken to do directly. Setting out which tasks the tool suits, which it does not, and what must always be checked against a source allows the organisation to apply what it has learned rather than requiring each employee to learn it separately.

## What an AI policy is for

An AI policy is a set of decisions made centrally so that employees do not have to make them individually. It should answer four questions:

*   Which tools may I use?
*   What information must never be entered into them?
*   Who checks the output before it leaves the business?
*   What do I do if something goes wrong?

If the document answers those questions in plain English, it is doing its job. A policy that needs a contents page is unlikely to be read, and an unread policy provides no protection.

## The sections a policy needs

### 1\. Purpose and scope

One paragraph covering who the policy applies to - including contractors and temporary staff - and why it exists.

Decide at this point whether the AI policy sits as a standalone document or as a section within your [employee handbook](https://www.natwestmentor.co.uk/news/drafting-an-employee-handbook-what-employers-need-to-know). A standalone document is easier to update on a six-month cycle, which matters more here than for most policies. It should be cross-referenced from the handbook and from your IT and data protection policies for ease of access.

### 2\. Approved tools

Name the tools. "Employees may use approved AI tools" is not a usable rule, because nobody knows which tools have been approved. "Employees may use Microsoft Copilot on their company account. Personal accounts must not be used for work tasks" can be followed or breached, and both the employee and the employer can tell which.

Specify the account type as well as the product. The distinction between a free consumer account and a paid business account usually determines whether the information entered is used to train the underlying model. Free tiers commonly do this; business and enterprise tiers commonly allow it to be switched off. Check the current terms with each provider rather than assuming, and check again at each review, because they change.

This is a common situation rather than an edge case. The [CIPD's Labour Market Outlook](https://www.cipd.org/globalassets/media/knowledge/knowledge-hub/reports/2025-pdfs/9024-lmo-autumn-2025-report-web.pdf), a survey of more than 2,000 UK employers, found that 54% said their employees use free versions of AI tools, compared with 42% using paid-for versions \[1\].

Include a process for adding tools to the approved list. Employees will find tools that are useful and not yet approved. If the only options are to use them without telling anyone or not to use them, the policy will be worked around rather than followed. A named contact and a short request process brings these tools into view.

### 3\. Information that must never be entered

This is the most important section, and it should be specific.

General wording does not work here, because it returns the judgement to the employee. "Employees must not enter confidential or sensitive data into AI tools" requires each member of staff to decide what counts as sensitive, and their definitions will vary. Compare:

**General**: "Employees must not enter confidential or sensitive data into AI tools."

**Specific**: "Never enter any of the following into any AI tool: customer names, addresses or account numbers; employee records, including pay, performance or absence; anything covered by an NDA; passwords or logins; unpublished financial results; supplier pricing."

### 4\. Human review and accountability

A named person is accountable for every output, regardless of how it was produced. AI use does not transfer responsibility away from the employee or the business.

Review should be proportionate to consequence. Applying the same level of scrutiny to an internal draft and a customer-facing financial summary wastes time on the first and provides insufficient protection on the second.

**Example:**

| Output type | Review needed |
| --- | --- |
| Internal drafts, brainstorming, summarising your own notes | Author's judgement |
| Internal documents others will rely on | Author checks facts and figures against source |
| Anything customer-facing | Named second person checks before it goes out |
| Any figures, quotes, statistics or citations | Verified against the original source, always |

The final row is the one that causes the most problems in practice. Generative AI tools produce fabricated figures, quotations and references in the same confident register as accurate ones, and there is no reliable way to identify them from the output alone. The DWP evaluation found that users were most cautious precisely where the tool drew on external sources or unfamiliar material, and that poorly framed requests produced fabricated results \[4\]. One participant summarised the position: the output is useful for starting research, but cannot be treated as a source in itself.

Any number, quotation or source that appears in AI output should be checked against the original before it is used.

### 5\. Disclosure

Decide when AI use should be declared, and to whom.

Some businesses require disclosure on any customer deliverable. Others require it only where AI made a substantive contribution, rather than assisting with drafting or formatting. Some customers and sectors will have their own expectations that override yours, and public sector or regulated clients increasingly ask the question directly at tender stage.

There is no single correct answer, and the right one depends on what you do and who you do it for. What causes problems is leaving the question open. Where the policy is silent, each employee answers it for themselves, which means your business gives different answers to different customers, and you may discover your own position for the first time when a customer asks.

Apply whatever you decide to the leadership team as well. A disclosure rule that exempts senior staff will not hold, because the people it exempts are the ones producing the most customer-facing material.

### 6\. AI in people decisions

If AI is used in recruitment, promotion, performance management or disciplinary processes, that use should be deliberate, documented, and subject to a human decision rather than human confirmation of an AI recommendation. State which of these processes AI may be used in, in what capacity, and who holds the decision.

The most common unplanned use is a manager entering a candidate shortlist into a chatbot and asking it to rank them. If the policy does not address this, it will happen without the employer's knowledge.

### 7\. What to do when something goes wrong

Employees need a route for reporting mistakes.

If someone enters customer data into a consumer chatbot, the employer needs to know quickly. That will only happen if the reporting route is clear and the response is proportionate. If employees expect disciplinary action, they are unlikely to report the error, and the business is more likely to find out from the customer.

### 8\. Ownership and review

Name the policy owner and the review date. Six months is a reasonable interval, as both the tools and their pricing tiers change frequently. Include a version number and date on the document.

## Writing the policy

### Establish current use first

Ask each team which AI tools they currently use and what they use them for. Phrase this as a question rather than an audit, or the answers will be incomplete.

This has two benefits. The policy will reflect how people actually work, which makes it more likely to be followed. It also corrects for the fact that senior teams often have an inaccurate picture of AI use in their organisation.

### Write for someone working under time pressure

The policy will usually be recalled from memory by someone with a deadline, not consulted at leisure. Use short sentences, specific examples, and concrete terms rather than general principles.

### Record who has read it

A policy only helps you if you can show that the current version reached the people it covers. Record acknowledgements, and build it into your [onboarding process](https://www.natwestmentor.co.uk/news/employers-guide-to-effective-employee-onboarding) so that new starters read it alongside your other day-one documentation. When the policy is updated, reissue it rather than relying on staff to notice the change.

## Introducing the policy

A policy sets out the rules. It does not explain what AI is reliable for, where it fails, or how to identify a fabricated statistic. Without that, review requirements become a formality.

[CIPD analysis of generative AI adoption](https://www.cipd.org/en/about/blogs/can-ai-deliver-productivity-boost-uk-needs/) found that 35% of employers had provided training and support to help employees use generative AI in the past 12 months \[2\], meaning the majority had not, including many who permit its use.

The DWP evaluation is useful on what training should look like. Despite formal sessions being available, 89% of participants learned to use the tool through self-directed exploration, and most did not recall attending any training \[4\]. What they asked for was training tailored to their own role and job function, practical examples of what worked, short sessions covering one feature at a time, and a reference sheet of prompts they could keep to hand \[4\].

![image (3).png](https://www.natwestmentor.co.uk/media/image_3_3ac098edd3.png)
_How staff actually learned to use the tool, despite training being available. Source: DWP, An Evaluation of DWP's Microsoft 365 Copilot Trial, 2026. \[4\]_

A short session in which each team works through examples from their own workload is more effective than general theory, and it surfaces situations the policy has not covered. Treat it as part of your wider approach to [employee development](https://www.natwestmentor.co.uk/news/best-practices-for-effective-employee-development) rather than as a one-off exercise attached to the policy launch.

### Address the effect on jobs

Employees are likely to be concerned about whether AI will affect their roles. If the employer does not address this, staff will draw their own conclusions, and that will shape how they respond to the policy.

The position for smaller businesses is genuinely different from the one reported in the headlines, and it is worth setting out. The CIPD found that 49% of employers expect AI to make no difference to their headcount over the next 12 months, and 17% expect it to reduce headcount. Among SMEs, however, only 7% expect a reduction, compared with 26% of large private sector employers \[1\]. The CIPD's own reading of this is that SMEs appear to be doing more with the same number of people, while large private sector employers appear to be streamlining \[1\].

If you are an SME, that is a fair thing to tell your staff: the intention is to remove work that nobody enjoys, not to remove people. Where that is your position, say so plainly, and be equally plain about what you cannot promise. Where AI does change what roles look like over time, that belongs in your [workforce planning](https://www.natwestmentor.co.uk/news/workforce-planning-basics) rather than being handled through an AI policy.

## Getting the balance right

Employers responding to AI tend to focus on constraining their use. On its own, restriction tends to move the activity out of view rather than stop it, which leaves the business without either the productivity benefit or the oversight.

The policies that work are short enough to be remembered, specific enough to be followed, based on how employees actually work, and supported by training that allows staff to exercise the judgement the policy asks of them. Employees are already making decisions about AI use. The policy determines the basis on which they make them.

_This article is intended for general informational purposes only and does not constitute legal, compliance or professional advice. While it highlights some key considerations for organisations developing an AI policy, Mentor does not provide AI policy creation services or advice tailored to individual organisations. We recommend seeking appropriate independent advice to ensure any AI policy is suitable for your organisation’s needs._

\[1\] CIPD, _Labour Market Outlook: Autumn 2025_, November 2025.

\[2\] CIPD, _Generative AI at work: can it deliver the productivity boost UK employers need?_, January 2026.

\[3\] Microsoft UK, _Rise in 'Shadow AI' tools raising security concerns for UK organisations_, October 2025.

\[4\] Department for Work and Pensions, _An Evaluation of DWP's Microsoft 365 Copilot Trial_, January 2026.

Oasis-Southbank-0122 (1).jpg

How to write an AI policy for your business

As the UK enters its third heatwave of 2026, with amber heat-health alerts issued across much of England, many employers are fielding a familiar question from staff: when is it too hot to work? The answer surprises most people. There is no temperature at which the law says work must stop.

That absence catches many employers off guard, because the assumption runs deep that a fixed threshold exists - 30°C is the figure most often cited - beyond which work must stop. No such threshold exists. What employers have instead is a broader and arguably more demanding duty: to keep the workplace at a "reasonable" temperature and to manage the health risks that heat creates \[1\]. A thermometer reading tells you very little on its own. What matters is whether staff are safe, comfortable enough to work effectively, and protected when conditions turn genuinely dangerous.

This article explains why no maximum exists, what "reasonable" means in practice, how to judge thermal comfort properly, and the concrete steps that keep staff healthy and working through hot spells - whether they sit at a desk, stand in a warehouse, or work outdoors.

## Summary

*   There is no legal maximum workplace temperature in the UK, and no temperature at which work must legally stop.
*   Employers must ensure indoor workplaces are maintained at a reasonable temperature during working hours and must assess and control any risks arising from excessive heat.
*   For outdoor workers, employers should consider providing shaded rest areas, access to drinking water, flexible working hours where practicable, and employee information on recognising the signs of heat-related illness.
*   Guidance sets a minimum of around 16°C for sedentary work and 13°C for physical work, but there is no equivalent ceiling.
*   "Thermal comfort" is the real test - HSE notes that this is often best judged by the level of employee dissatisfaction rather than by a single thermometer reading alone.
*   Six factors determine comfort: air temperature, radiant heat, humidity, air movement, how hard people are working, and what they are wearing.
*   A risk assessment is the starting point; from there, practical low-cost controls usually solve most problems.
*   Some workers face higher risk - including pregnant employees, older staff, and those with certain health conditions or medications.
*   Change may be coming: the Climate Change Committee and the TUC are both pressing the government for maximum-temperature rules, and a review of the guidance is underway.

## Why there is no maximum temperature

The absence of a maximum can seem like an obvious gap. If guidance sets a recommended minimum, why not a maximum to match?

The reason lies in how greatly workplaces differ. A temperature that would be alarming in an open-plan office is entirely normal in a commercial kitchen, a foundry, a bakery, or a glasshouse. A single national ceiling pitched for a call centre would either shut down legitimate industries or be set so high that it protected no one. Rather than impose a figure that suits nobody, the framework asks employers to keep conditions "reasonable" for their particular workplace and to control the risks that arise \[1\].

This is why guidance offers a minimum but not a maximum. For indoor workplaces, the [recommended floor](https://www.gov.uk/workplace-temperatures) is normally at least 16°C for sedentary work such as office tasks, or around 13°C where the work is physically demanding \[2\]. These are guideline figures rather than hard limits, and there is deliberately no figure at the top end. The duty to act does not switch on at a set reading - it applies whenever heat could foreseeably cause harm.

For employers, this represents a crucial shift in thinking. The question is not what the thermometer reads, but whether conditions are reasonable and whether the risk has been managed.

**Outdoor working**

Employees working outdoors may face additional risks from direct sunlight, radiant heat, and prolonged physical exertion. Employers should consider providing shaded rest areas, increasing access to drinking water, adjusting working hours where practicable, and ensuring workers understand the signs of heat-related illness.

## Thermal comfort: The test that actually matters

The concept that replaces a maximum temperature is "thermal comfort" - and it is worth understanding properly, because it reframes the whole problem.

Thermal comfort describes how satisfied people are with the temperature around them. The [official guidance](https://www.hse.gov.uk/temperature/thermal/) puts it memorably: thermal comfort is not measured by the temperature of the room, but by how many of your employees are complaining of thermal discomfort \[3\].

This matters because comfort depends on far more than air temperature. Six factors combine to determine whether a space feels comfortable \[3\]:

*   **air temperature** - the figure most people focus on, but only one part of the picture
*   **radiant heat** - warmth radiating from machinery, ovens, or direct sunlight through glass, which can make a space feel far hotter than the air temperature suggests
*   **humidity** - high humidity stops sweat evaporating, which is how the body cools itself, making moderate temperatures feel oppressive
*   **air movement** - a breeze or fan aids cooling; still, stagnant air traps heat against the body
*   **work rate** - physical effort generates body heat, so the same room is far hotter for someone lifting boxes than for someone typing
*   **clothing** - uniforms, protective equipment, and heavy fabrics all trap heat and limit the body's ability to cool

The practical lesson is that two workplaces at the same air temperature can pose completely different levels of risk. A humid, still warehouse where staff do heavy lifting in protective gear is a far greater concern than an airy office at the same reading.

## Why heat is a genuine safety issue, not just discomfort

There is a temptation to treat workplace heat as a question of comfort rather than safety. That underestimates it.

When people feel uncomfortably hot, their ability to make good decisions and perform tasks deteriorates, and they are more likely to behave unsafely - cutting corners to escape the heat, or wearing protective equipment improperly because it is uncomfortable \[3\]. In physically demanding or hazardous settings, that drop in judgement and compliance is where accidents happen. The [CIPD](https://www.cipd.org/en/about/press-releases/employers-should-consider-flexibility-as-temperatures-soar/), the professional body for HR, makes the same point about everyday roles: sustained heat causes fatigue and reduced concentration, and the effect is felt most acutely by those in safety-critical jobs such as driving or construction \[11\].

Beyond performance, heat carries direct health risks. [Heat exhaustion](https://www.nhs.uk/conditions/heat-exhaustion-heatstroke/) brings heavy sweating, dizziness, headache, muscle cramps, and nausea. Left unmanaged, it can progress to heatstroke - a medical emergency marked by confusion, a very high body temperature, or loss of consciousness, which requires an immediate 999 call \[9\]. These are not remote possibilities during a heatwave; they are foreseeable outcomes that employers are expected to plan for.

The wider context makes the point sharper. The UK [recorded a temperature of 40.3°C](https://www.metoffice.gov.uk/about-us/news-and-media/media-centre/weather-and-climate-news/2022/july-heat-review) in July 2022, the first time 40°C had been reached \[10\]. That summer's heat was associated with more than 3,000 excess deaths across England and Wales - a population-wide figure rather than a workplace one, but a measure of how dangerous extreme heat has become \[8\]. The country saw four heatwaves in the summer of 2025, each triggering official heat-health alerts \[7\]. Extreme heat is no longer an occasional freak event to be weathered - it is a recurring planning scenario, and workplaces that prepare for it fare considerably better than those that improvise each time.

## A practical framework for managing workplace heat

Managing heat does not require expensive engineering in most workplaces. It requires a considered process and a set of sensible controls. The approach below moves from assessment to action.

### 1\. Start with a risk assessment

Heat is one of the [risks an employer should assess](https://www.hse.gov.uk/temperature/employer/heat-stress.htm), indoors or outdoors. A heat risk assessment identifies where high temperatures are likely, who is most exposed, and what could go wrong. It should weigh the environmental factors (temperature, humidity, radiant heat, air movement), the work factors (how strenuous the task is, how long shifts run, what protective clothing is required), and the individual factors (who among your staff may be more vulnerable) \[4\]. This assessment is the foundation everything else builds on, and it should be revisited when conditions change rather than written once and filed away.

### 2\. Apply practical controls

Most heat problems are solved with straightforward, low-cost measures. The aim is to reduce the temperature, improve air movement, lower the physical demand, and give people the means to cool down \[5\]. Effective options include:

*   improving ventilation - opening windows, using fans, or running air conditioning where available
*   shading windows with blinds or reflective film to cut radiant heat from the sun
*   relaxing dress codes so staff can wear cooler, lighter clothing
*   providing ready access to cool drinking water and encouraging regular hydration
*   introducing more frequent breaks, ideally in a cooler area away from the heat source
*   rescheduling the most strenuous tasks to the cooler parts of the day
*   moving workstations away from direct sunlight or hot machinery
*   allowing flexible or remote working where the role permits, so staff avoid the hottest conditions entirely.

Employers are not expected to apply every measure in every workplace. The expectation is that heat risk has been assessed and suitable controls have been considered and put in place - a proportionate response to a foreseeable hazard.

### 3\. Pay attention to clothing and protective equipment

Protective equipment is a common and overlooked cause of heat stress. It adds weight, traps body heat, and stops sweat evaporating. Where protective gear is essential it cannot simply be removed, but employers can lighten the load: encouraging staff to take equipment off as soon as a task is finished so trapped heat can disperse, considering lighter or breathable alternatives, and in some settings looking at specialist clothing with built-in cooling \[5\]. The principle is to avoid people working hard, in heavy gear, in hot and humid conditions for long unbroken stretches.

### 4\. Protect those most at risk

Heat does not affect everyone equally. Some staff need extra consideration - including pregnant employees, older workers, those new to a hot environment and not yet acclimatised, and people whose health conditions or medications make them more susceptible \[4\]. Once a worker has notified you that they are pregnant, you should carry out an individual risk assessment and make any adjustments it identifies. For others, the same [reasonable adjustments](https://www.natwestmentor.co.uk/news/reasonable-adjustments-in-the-workplace) that help everyone apply with extra care: more frequent breaks, access to cooler areas, reduced exertion, and a watchful eye for early symptoms.

### 5\. Brief managers and first aiders

Controls only work if the people on the ground know what to watch for. Managers and first aiders should be able to recognise the signs of heat exhaustion and heatstroke and know what to do - move the affected person somewhere cool, give them fluids, and escalate to emergency services if serious symptoms appear. Briefing them before a heatwave, rather than during one, ensures the response is prompt.

## Talking to your team

One of the simplest and most effective measures costs nothing: asking staff directly. Because comfort is subjective and varies from person to person, the people best placed to tell you whether conditions are reasonable are the ones working in them. [Consulting staff](https://www.natwestmentor.co.uk/news/top-tips-for-effective-workplace-communication) on how to cope with high temperatures surfaces problems early, produces better solutions, and demonstrates that the issue is being taken seriously. The CIPD makes the same recommendation, advising that employers who speak to staff and establish their needs are best placed to keep them both comfortable and productive \[11\].

It also heads off the resentment that builds when people feel ignored. An employee who has been asked for their input, offered a fan, and told they can dress down responds very differently from one left to suffer while management debates whether 28°C counts as too hot - even when the temperature is identical.

## What might change

The lack of a maximum temperature is increasingly contested, and employers should expect movement in this area.

The [Trades Union Congress](https://www.tuc.org.uk/news/employers-must-keep-workers-safe-first-heatwave-2026) has long campaigned for legal limits, proposing that employers should be required to act once temperatures climb above 24°C and staff feel uncomfortable, and that a ceiling of 30°C - or 27°C for strenuous work - should trigger a right to stop \[7\]. In May 2026 the [Climate Change Committee](https://www.theccc.org.uk/publication/a-well-adapted-uk/), the government's independent climate adviser, recommended that ministers set maximum-temperature rules for work to address the growing risks that heat poses to workers, though it did not propose a specific figure \[8\].

The government has [acknowledged the issue](https://commonslibrary.parliament.uk/research-briefings/cbp-10925/), committing to modernise health and safety guidance on extreme temperatures, and a review of the relevant code of practice is underway with a consultation expected \[6\]. Nothing has changed in law yet, and any new rules would take time to arrive. But the direction of travel is clear, and employers who build sensible heat management into their practices now will be well ahead of whatever guidance eventually lands.

## The bottom line

The instinct to look for a maximum temperature is understandable, but it misreads the obligation. There is no number that releases an employer from responsibility, and equally none that defines the limit of it. What exists is a continuous duty to keep conditions reasonable and to manage the risks heat creates - a duty that is met through assessment, sensible controls, and genuine attention to how staff are coping.

That is more demanding than a single threshold would be, but it is also more useful. A workplace that manages heat well is safer, more comfortable, and more productive than one waiting for a thermometer to hit a figure that never comes - and heat management sits naturally within broader [employee wellbeing initiatives](https://www.natwestmentor.co.uk/news/developing-employee-wellbeing-initiatives-in-the-workplace) rather than apart from them. As hot summers become the norm rather than the exception, the employers who treat heat as a foreseeable, manageable risk - rather than an annual surprise - are the ones whose people stay safe and keep working.

_This article is intended for informational purposes only and does not constitute legal advice. The information is accurate at the time of writing but may be subject to change. For advice specific to your situation, please consult a qualified professional._

\[1\] Health and Safety Executive, _Temperature in the workplace: What the law says_.

\[2\] GOV.UK, _Workplace temperatures_.

\[3\] Health and Safety Executive, _Thermal comfort: the six basic factors_.

\[4\] Health and Safety Executive, _Temperature in the workplace: Heat stress_.

\[5\] Health and Safety Executive, _Managing workplace temperatures_.

\[6\] House of Commons Library, _Working in hot weather: What does the law say?_, June 2026.

\[7\] Trades Union Congress, _Employers must keep workers safe in the first heatwave of 2026_, June 2026.

\[8\] Climate Change Committee, _A Well-Adapted UK_, May 2026.

\[9\] NHS, _Heat exhaustion and heatstroke_.

\[10\] Met Office, _UK temperature records._

\[11\] CIPD, _Employers should consider flexibility and adjustments as temperatures soar_, May 2026.

GettyImages-1134027904 (1).jpg

Maximum workplace temperature: What employers need to know

Every year, the same pattern repeats across thousands of UK businesses. Demand climbs sharply for a few intense weeks, existing teams stretch to breaking point, and managers scramble to bring in extra hands at exactly the moment they have least time to do it properly. Shelves go unstocked, queues lengthen, and the temporary staff brought in to ease the pressure often leave before they've become useful.

The scale of seasonal hiring is considerable. For Christmas 2025 alone, [Tesco opened 28,500 temporary positions](https://www.networkrevolution.co.uk/christmas-brings-a-hiring-wave/) \[1\], while the John Lewis Partnership ran [its largest ever seasonal drive](https://www.retailgazette.co.uk/blog/2025/09/john-lewis-seasonal-roles/) at around 13,700 roles across John Lewis, Waitrose, and its distribution network \[2\]. These are the headline figures, but the same dynamic plays out in smaller businesses everywhere: the garden centre staffing up for spring, the seaside café doubling its team for August, the events company providing crew for thesummer festival.

Yet seasonal staffing is rarely treated as a discipline in its own right. Many businesses approach each peak as a one-off emergency rather than a predictable, recurring event that rewards planning. The result is rushed recruitment, thin onboarding, and a workforce that never quite reaches full productivity before the season ends.

It doesn't have to work this way. Businesses that forecast demand early, recruit ahead of the rush, and invest even modestly in onboarding consistently get more from their seasonal teams - and build a pool of proven people they can call on again. This article sets out how to manage seasonal workers effectively from forecasting through to the end of the season and beyond.

## Summary

*   Seasonal hiring is predictable, not exceptional - the businesses that plan months ahead consistently outperform those that wait until demand hits.
*   Forecasting from previous years' data lets you size your team accurately and recruit before the talent pool tightens.
*   Job-seeker competition for seasonal roles has intensified, with applicant interest up significantly year on year, so clear adverts and fast processes matter more than ever \[7\].
*   Effective onboarding is the single highest-return investment: structured induction can lift new-hire productivity by over 70% and retention by 82% \[4\].
*   Treating temporary staff as genuine team members - through buddies, check-ins, and recognition - drives both performance and the likelihood they'll return.
*   A returning seasonal worker needs far less ramp-up time, making your seasonal pool a cost-effective, ready-made talent pipeline.
*   Pay, flexibility, and a positive experience are the main levers for attracting and keeping seasonal staff in a competitive market.

## Why seasonal workforce planning matters more in 2026

The UK labour market has shifted in ways that make casual, last-minute seasonal hiring riskier than it once was. The reliable December boost that retail and hospitality used to count on has weakened: [small-business employment in these sectors contracted by 2%](https://employmenthero.com/uk/news/consequences-of-retail-hospitality-hiring-slump-2026/) in December 2025, with year-on-year growth in the sector falling from 13.5% the previous December to just 0.5% \[3\]. Summer hiring has shown a similar caution, with [employers slower to add seasonal headcount](https://www.hiringlab.org/uk/blog/2026/06/02/slow-summer-hiring-another-blow-for-young-workers/) than in previous years \[6\].

At the same time, demand for seasonal work from job-seekers has climbed. [Interest in seasonal roles](https://orgshakers.com/2025/12/03/seasonal-hiring-and-onboarding-how-to-make-temporary-teams-feel-permanent/) at the end of September 2025 was up 27% year on year and 50% above 2023 levels \[7\]. More applicants might sound like good news, but it also means more competition between employers for the best of them, and a larger volume of applications to sift through under time pressure.

There's a broader pattern worth noting too. As permanent recruitment has cooled, many organisations have leaned into flexible staffing: [contract and temporary recruitment grew by around 11%](https://ixceed-solutions.com/uk-hiring-trends-august-2025-contract-recruitment-rises-despite-permanent-hiring-slowdown/) year on year in August 2025, even as permanent hiring slowed \[9\]. Seasonal and temporary workers are becoming a more central part of how UK businesses manage fluctuating demand, not just a festive afterthought.

The practical implication is straightforward. Seasonal staffing deserves the same forward planning you'd give any significant operational commitment, much like the [workforce planning basics](https://www.natwestmentor.co.uk/news/workforce-planning-basics) that underpin any growing team. The businesses that treat it strategically - mapping demand early and building relationships with returning workers - are far better placed than those still hoping to fill gaps in the final fortnight.

## Forecasting demand and sizing your team

Good seasonal management starts well before the first advert goes out. The foundation is an honest forecast of what you'll actually need.

Start with your own history. Last year's sales data, footfall, transaction volumes, or order numbers tell you when your peak begins, how steep it is, and when it tapers off. Look at where things went wrong, too: the days you were understaffed, the shifts nobody wanted, the points where service slipped. These gaps are your planning priorities for the coming season.

Translate that demand into specific staffing needs rather than a vague sense that you'll "need more people." There are a few things worth considering.

*   **Volume**: How many additional people, and in which roles? Front-of-house, stockroom, delivery, and customer service may all scale at different rates.
*   **Timing**: When does each role need to start? Warehouse and logistics teams often need to be in place before the customer-facing peak, not alongside it.
*   **Shift patterns**: Which shifts are hardest to cover? Evenings, weekends, and bank holidays typically need the most attention and the strongest incentives.
*   **Lead time**: How long does it take you to recruit, check, and train someone to a useful standard? Work backwards from your peak to set a recruitment start date.

Retailers typically begin recruiting for Christmas in October, and [many larger employers open applications](https://www.personneltoday.com/hr/seasonal-hiring-drives-growth-in-uk-jobs-market/ as early as September \[8\]. For summer roles, the [planning window often runs from January through March](https://successknocks.com/summer-hiring-strategies-for-retail-hospitality/) \[5\]. The principle holds at any scale: the earlier you start, the wider the talent pool and the less you'll pay - in money or stress - to fill roles at the last minute. With the [time to hire in the UK](https://www.natwestmentor.co.uk/news/time-to-hire-in-the-uk) stretching across many sectors, building in that lead time is rarely wasted effort.

## Recruiting ahead of the rush

With a forecast in hand, the goal is to recruit efficiently while the pool is still deep. Three things make the biggest difference.

### Write adverts that are clear and specific

Seasonal applicants are often weighing several roles at once and skim quickly. State the essentials plainly: the dates of the contract, the hours and shift patterns, the pay, the location, and what the work actually involves. Vagueness costs you - both in unsuitable applicants and in good candidates who move on to a clearer listing. Be honest about the demands, too; overselling a role simply produces disappointed starters who leave early.

### Keep your process fast

In a competitive market, a slow recruitment process loses good people to quicker rivals. Streamline applications, batch your interviews, and make decisions promptly. Many large seasonal employers have moved to simplified, mobile-friendly applications precisely because speed and ease convert more candidates \[1\].

### Target the right talent pools

Seasonal work suits particular groups especially well - students on holiday, people seeking flexible hours, those wanting extra income around a specific period, and career-changers testing a new sector. Different channels reach different pools. Local social media groups, your own networks, colleges and universities, and word-of-mouth referrals from existing staff are often more effective and far cheaper than blanket job-board spend. Referrals carry an added advantage: people recommended by your current team tend to arrive with a realistic picture of the work and integrate faster - and a strong [employer brand](https://www.natwestmentor.co.uk/news/building-employer-brand) makes every one of these channels work harder.

One source frequently overlooked is your own past seasonal staff. People who worked a previous peak and performed well are the warmest leads you hav.

## Onboarding: The highest-return investment you'll make

It's tempting to cut corners on onboarding for someone who'll only be with you a few weeks. This is the most common and most costly mistake in seasonal staffing. The shorter the contract, the more important it is that people become productive quickly - and thin induction guarantees the opposite.

The evidence is striking. [Structured onboarding can improve new-hire productivity](https://workbright.com/blog/how-seasonal-worker-onboarding-streamlines-your-hiring-process/) by over 70% and retention by 82% \[4\]. Organisations with standardised onboarding processes achieve markedly higher retention and productivity from new joiners than those that leave people to find their own feet \[10\]. For a seasonal worker whose entire tenure might be six or eight weeks, the difference between productive on day three and productive on day twelve is enormous.

Effective seasonal onboarding doesn't require a lengthy programme. It requires structure and clarity, and the same principles set out in our [guide to employee onboarding](https://www.natwestmentor.co.uk/news/employers-guide-to-effective-employee-onboarding) apply just as much to temporary teams.

*   **Prepare before they arrive.** Have their equipment, logins, uniform, and workspace ready for day one. Nothing erodes early confidence like standing around waiting for access that should have been sorted in advance.
*   **Break the role into clear, digestible modules.** Rather than overwhelming people with everything at once, focus on the core competencies they need first and layer in the rest over the opening days.
*   **Assign a buddy.** Pairing each new starter with an experienced team member gives them someone to ask the small questions they'd never raise formally. [Buddy systems consistently improve early retention](https://www.sage.com/en-gb/blog/employee-onboarding-process/) and job satisfaction \[15\].
*   **Build in early check-ins.** Brief, regular conversations in the first days - even just fifteen minutes - let you catch confusion or skill gaps before they affect the operation, and signal that you're invested in their success.

A short, well-designed induction pays for itself many times over in the days of productive work it unlocks.

## Turning seasonal hires into a year-round asset

The end of the season is where most businesses stop thinking about their temporary staff - and where the biggest opportunity is quietly lost.

A seasonal worker who performed well represents enormous value beyond the weeks they've already given you. They know your systems, your culture, and your customers. You've effectively run a "try before you hire" assessment and seen exactly how they work. Should a permanent role open up, [a former seasonal employee can step into it](https://www.theperillogroup.com/2025/12/03/turning-holiday-hires-into-long-term-talent/) with far less ramp-up time than an external hire, and people who grow into a role this way tend to stay longer because they already know they enjoy the work \[13\]. [Promoting from your seasonal pool](https://dpistaffing.com/2025/12/26/retaining-seasonal-employees-after-the-holidays/) also cuts sourcing and onboarding costs significantly \[14\].

Even where there's no permanent vacancy, your seasonal pool is a ready-made talent pipeline for next year. A returning worker needs only light re-induction rather than full onboarding, which compresses your time-to-productivity and cuts recruitment costs at a stroke. [Some businesses have reported substantial increases in seasonal return rates](https://workbright.com/blog/5-reasons-to-use-temporary-worker-onboarding-software-for-seasonal-staff/) simply by keeping in touch and following up \[11\].

## Looking ahead

Seasonal demand is one of the few business pressures you can genuinely see coming. The peak arrives at roughly the same time every year, in roughly the same shape, and the data to plan for it sits in your own records. The difference between a chaotic season and a smooth one rarely comes down to luck or budget - it comes down to whether the work was treated as predictable and planned for accordingly.

Forecast early, recruit ahead of the rush, invest in onboarding even for short contracts, manage seasonal staff as the genuine team members they are, and protect the relationships with those who perform well. Do this consistently and the annual scramble gives way to something far more valuable: a dependable, repeatable way to meet your busiest periods with confidence.

_This article is intended for informational purposes only and does not constitute legal advice. The information is accurate at the time of writing but may be subject to change. For advice specific to your situation, please consult a qualified professional._

\[1\] Network Revolution, _Christmas Brings a Hiring Wave - Tesco seeks 28,500 staff_, November 2025.

\[2\] Retail Gazette, _John Lewis Partnership launches 'biggest ever' seasonal recruitment drive for Christmas_, September 2025.

\[3\] Employment Hero, _Consequences of the UK retail & hospitality hiring slump_, January 2026.

\[4\] WorkBright, _How Seasonal Worker Onboarding Streamlines Your Hiring Process_, May 2025.

\[5\] Success Knocks, _Summer Hiring Strategies for Retail and Hospitality: Beat the Rush in 2026_, May 2026.

\[6\] Indeed Hiring Lab UK, _May 2026 UK Labour Market Update: Slow Summer Hiring_, June 2026.

\[7\] OrgShakers, _Seasonal Hiring and Onboarding: How to Make Temporary Teams Feel Permanent_, December 2025.

\[8\] Personnel Today, _Seasonal Hiring Trends in the UK: What to Expect_, 2025.

\[9\] ixceed Solutions, _UK Hiring Trends August 2025: Contract Recruitment Rises Despite Permanent Hiring Slowdown_, September 2025.

\[10\] WorkBright, _How Seasonal Worker Onboarding Streamlines Your Hiring Process_, May 2025.

\[11\] WorkBright, _Temporary Worker Onboarding Software for Seasonal Staff_, 2025.

\[12\] OrgShakers, _Seasonal Hiring and Onboarding_, December 2025.

\[13\] The Perillo Group, _Turning Holiday Hires Into Long-Term Talent_, December 2025.

\[14\] DPI Staffing, _Retaining Seasonal Employees After the Holidays_, December 2025.

\[15\] Sage Advice UK, _Employee Onboarding Process_, 2025.

iStock-501070858 (2).jpg

Managing seasonal workers: How to build a high-performing temporary team

Following the [first wave of reforms introduced in April 2026](https://www.natwestmentor.co.uk/news/employment-law-changes-in-april-2026-what-you-need-to-know), employers now face a further set of changes expected to take effect from October 2026. This second wave places greater emphasis on employer responsibilities - particularly around harassment prevention, trade union rights and workplace protections. 

With October fast approaching and several of the changes still subject to finalised regulations and codes of practice, businesses should begin reviewing their policies, procedures and management practices now rather than waiting for every detail to be confirmed. 

## Summary

- From October 2026, the Employment Rights Act 2025 introduces a second wave of reforms focused on harassment prevention, trade union rights and workplace protections. 
- The duty to prevent sexual harassment rises from "reasonable steps" to "all reasonable steps," and a new duty covers harassment by third parties. 
- Employers must give workers a standalone written statement on the right to join a trade union, and unions gain new workplace access rights (firms with fewer than 21 employees are exempt). 
- Tribunal time limits for most claims are set to rise from three to six months, "no earlier than" October 2026. 

## October 2026 changes

### Sexual harassment

The current duty on employers to take reasonable steps to prevent sexual harassment in the course of employment is being strengthened. From October, this becomes a duty to take all reasonable steps - a higher and more proactive standard that will require employers to go further than simply having a policy in place. 

The government has the power to make regulations clarifying what "all reasonable steps" means in practice, but these are not expected until 2027 or 2028. In the meantime, the [EHRC's technical guidance on sexual harassment and harassment at work](https://www.equalityhumanrights.com/guidance/sexual-harassment-and-harassment-work-technical-guidance) provides the most useful practical benchmark for employers assessing whether their current measures are sufficient. 

### Third-party harassment

A new duty will require employers to take all reasonable steps to prevent harassment of their employees by third parties - meaning anyone other than the employer or a fellow employee, such as contractors, suppliers, clients, customers, service users, passengers, patients, members of the public and residents. This covers harassment related to all relevant protected characteristics: age, disability, gender reassignment, race, religion or belief, sex and sexual orientation.  

Third-party harassment protections were removed from statute in 2013, so this represents a significant restoration of workplace rights. The "all reasonable steps" standard mirrors the strengthened duty introduced for sexual harassment (see above), and employers should consider both duties together when reviewing their harassment prevention measures. 

### Duty to inform workers of right to join a trade union

Employers will be required to inform their workers of their right to join a trade union. This must be provided as a standalone written statement - it cannot be incorporated into the written statement of particulars of employment (the Section 1 statement) or other standard onboarding documents. 

The statement must include: the functions of trade unions, a summary of workers' rights in relation to union membership, a list of any trade unions recognised by the employer, and a signpost to the relevant government website for further information. 

Regulations will set out the precise content of the statement, how it must be issued to both new and existing workers, and how frequently it must be reissued. The obligation to inform existing workers - not just new starters - means employers should not treat this as a one-off onboarding task. 

### Trade union right of access

Trade unions will have new rights to access workplaces - both physically and digitally (including, for example, the ability to communicate with workers via email or virtual meetings). 

To start this process, a union must make a written request to an employer seeking access. The employer then has 15 working days to issue a written response, followed by a negotiation period of 25 working days to allow for the parties to agree the terms of access. If no agreement is reached, the union has 55 working days from the date of the initial request to refer the matter to the Central Arbitration Committee (CAC), which has the power to impose access terms. 

**Please note** - employers with fewer than 21 employees are exempt from this regime. 

### Facilities and time off for trade union officials

Currently, employers who recognise a trade union must allow officials of that union to take paid time off during working hours to carry out trade union duties and undertake relevant training.  

The ERA strengthens this by introducing a new duty on employers to provide reasonable accommodation and facilities - such as meeting rooms or access to communication tools - where the representative requests this to carry out their duties. 

This new facilities duty applies to trade union officials, trade union learning representatives, and the newly created category of trade union equality representatives. 

### Enhanced protection from detriment

Workers who take part in protected industrial action will gain a new right not to be subjected to a detriment by their employer, where the sole or main purpose of that treatment is to prevent, deter or penalise them for doing so. This could include, for example, disciplinary action, financial penalties, or denial of career development opportunities - though the protection is not limited to these examples. 

### Employment tribunal time limits

No earlier than October 2026, the time limit for bringing most employment tribunal claims will increase from three months to six months. Note that breach of contract claims arising on termination of employment are excluded and will remain subject to a three-month limit. 

The "no earlier than" caveat means this change could slip beyond October 2026 - potentially into 2027 - so employers should monitor the confirmed implementation date. 

In practical terms, employers should review their record-keeping practices in light of this change. Documents and records relating to disciplinary processes, grievances and dismissals that were previously safe to dispose of will need to be retained for longer. 

### Tips and gratuities

Key changes to tipping legislation were scheduled to come into effect in October, but the indications are that this will be later in the year. These will require employers to consult with worker or trade union representatives before producing their first written tipping policy. Employers will also have to review the policy every three years and consult with the representatives when doing so. Finally, the employer will also need to provide workers with an anonymised summary of the views expressed during consultation.  

### Public sector outsourcing

Where a company takes on a public sector outsourcing contract, new measures under the ERA are intended to prevent the creation of a two-tier workforce. Workers employed directly by the contractor to deliver the outsourced service should not be treated less favourably in their terms and conditions than employees who transferred from the public authority under TUPE. The aim is to promote consistency in pay and employment terms across the workforce. 

## What should employers do now?

Although some of the changes will require further regulations and government guidance before they are fully implemented, employers should begin preparing now. Reviewing workplace policies, updating harassment procedures, assessing trade union processes and ensuring managers understand the new obligations will help organisations reduce legal risk and maintain compliance. 

### Further reading

For more information on the upcoming employment law changes, you may find the following articles helpful: 

- [Statutory Sick Pay (SSP) changes from April 2026](https://www.natwestmentor.co.uk/news/statutory-sick-pay-ssp-changes) 
- [Unfair dismissal changes 2027: The six-month qualifying period explained](https://www.natwestmentor.co.uk/news/unfair-dismissal-changes-2027)  
- [The Fair Work Agency: What this new enforcement body means for employers](https://www.natwestmentor.co.uk/news/the-fair-work-agency) 
- [Employment law changes in April 2026: What you need to know ](https://www.natwestmentor.co.uk/news/employment-law-changes-in-april-2026-what-you-need-to-know)

For the latest HR news and updates, visit our [News blog](https://www.natwestmentor.co.uk/news/page/1/). 

**Not sure what to prioritise before October?** Our free webinar on 16 September walks through the October and January changes, the practical steps to take now, and the risks of leaving policy reviews too late. [Register here](https://rbs.zoom.us/webinar/register/3317815412217/WN_19H9XUlMRfKnmcDbKdFYTQ).

_This article is intended for informational purposes only and does not constitute legal advice. The information is accurate at the time of writing but may be subject to change. For advice specific to your situation, please consult a qualified professional._

Colleagues at a work meeting reading and discussing written legal changes 

news image (2).jpg

Employment Rights Act: October 2026 changes

Closing the disability employment gap alone could add an estimated [£17 billion a year](https://www.gov.uk/government/news/government-commits-to-introducing-mandatory-ethnicity-and-disability-pay-gap-reporting-for-large-employers) to the UK economy \[1\]. That figure points to a wider truth: many organisations are not reaching, retaining, or making the most of the talent already available to them, often because of how their policies are designed rather than any lack of good intent.

Most employers want to treat their people fairly. Fair intentions do not always produce fair outcomes, though, because policy design can create barriers that have little to do with someone's ability to do the job. A recruitment process can assess confidence rather than capability. A working pattern can suit some employees better than others. A promotion route can be clear to some staff and unclear to others.

Inclusive workplace policies address these issues by designing systems that work for the widest possible range of people. The aim is not to lower standards, but to remove obstacles, so that recruitment, progression, and day-to-day working reflect what people can contribute. Done well, this is not only fairer but commercially stronger.

## Summary

*   Inclusion and diversity are related but different: diversity describes the make up of the workforce, while inclusion relates to whether everyone can be themselves, contribute, are valued and able to progress. Effective policies consider both \[9\].
*   Closing the disability employment gap could add an estimated £17 billion a year to the UK economy \[1\].
*   Employment gaps remain wide: in Q2 2025, 52.8% of working-age disabled people were in employment, compared with 82.5% of non-disabled people \[2\].
*   The legal foundation is the Equality Act 2010, which prohibits discrimination and requires reasonable adjustments for disabled employees \[3\].
*   New harassment duties arrive from 2026. Employers will need to take "all reasonable steps" to prevent harassment, including by third parties, from October 2026 \[4\]\[11\].
*   Pay gap reporting is expanding: voluntary gender pay and menopause action plans from April 2026, mandatory action plans for large employers expected from 2027, with ethnicity and disability pay gap reporting confirmed to follow \[5\]\[6\].
*   Inclusive recruitment focuses on essential skills, structured interviews, and accessible processes that assess genuine capability.
*   Many of the most effective adjustments cost little or nothing, such as clearer communication, flexible hours, and a quieter workspace / remote working.
*   Inclusion works best when it is shared across the organisation and the tone set by leadership, rather than treated as a task for the HR team alone \[8\].

## Inclusion vs diversity: What is the difference?

The two ideas are often used interchangeably, but they are not the same. Diversity describes the mix of people in an organisation, including differences in:

*   age
*   sex
*   race (including colour, ethnicity, nationality)
*   disability
*   pregnancy and maternity
*   religion
*   marriage and civil partnership
*   sexual orientation
*   gender reassignment.

Inclusion describes whether those people can take part fully, feel they belong, and have a genuine equality of opportunity. As the [CIPD notes](https://www.cipd.org/uk/knowledge/reports/inclusion-work/), hiring a diverse workforce does not guarantee that every employee has the same experience or opportunities \[9\].

An [inclusive policy](https://www.natwestmentor.co.uk/news/building-a-diverse-equal-and-inclusive-workplace) is one designed so that a wide range of people can succeed within it. This applies across the employee lifecycle, including how organisations advertise roles, communicate, manage performance, collaborate, decide pay and promotion, and handle complaints. A policy may be well-intentioned and still produce uneven outcomes if it is not designed with different needs or experiences in mind.

Inclusion does not mean lowering expectations or creating exceptions. It means reducing barriers that are unrelated to someone's ability to do the job and recognising and valuing people’s different contributions and perspectives, so that selection and progression can reflect merit and enrich workplaces.

## Why inclusive policies make commercial sense

The commercial argument now extends well beyond reputation. UK employers increasingly treat equality, diversity and inclusion as part of their wider strategy, with [57% of UK organisations](https://stribehq.com/resources/workplace-diversity-and-inclusion-statistics/) regarding it as a priority when recruiting \[7\]. This can affect talent attraction, as many candidates take it into account when considering an employer. Around [66% of British workers](https://stribehq.com/resources/workplace-diversity-and-inclusion-statistics/) say the acceptance and inclusion of employees from all backgrounds is important when they weigh up job opportunities \[7\].

The advantage of varied perspectives shows up in two places. Internally, it improves the quality of decisions and ideas: BCG's study of more than 1,700 companies found that those with above-average management diversity generated 19% more revenue from innovation than less diverse businesses \[12\], because people with different backgrounds approach a problem from angles a homogeneous team would miss. Externally, those same perspectives help an organisation understand the people it serves. Customers are not a single, uniform group, and a workforce that reflects that range is better placed to anticipate how products and services will land and to spot opportunities a narrower team would overlook - insight difficult to replicate through research alone.

Inclusion also shapes how an organisation is seen by the people it depends on. Investors, clients, partners, and prospective recruits increasingly weigh an employer's approach to equality and inclusion when they decide who to work with, which makes a credible commitment an asset across the full range of stakeholder relationships rather than a matter for recruitment alone.

There are links to retention and performance as well. The CIPD's research connects inclusive cultures with stronger engagement and retention, and notes that a diverse workforce may not stay with an organisation [where people do not feel valued](https://www.cipd.org/globalassets/media/knowledge/knowledge-hub/reports/building-inclusive-workplaces-report-sept-2019_tcm18-64154.pdf), included and respected \[8\]. Retention also has a clear cost dimension. When [employee replacement costs](https://www.natwestmentor.co.uk/news/how-much-does-it-cost-to-employ-someone) range from 50% to 200% of annual salary, improvements in retention can produce meaningful savings.

There is also a wider talent pool to consider. In Q2 2025, [52.8% of working-age disabled people](https://publications.parliament.uk/pa/cm5901/cmselect/cmworpen/1227/report.html) were in employment, compared with 82.5% of non-disabled people \[2\]. The disability pay gap stands at [15.5%](https://www.tuc.org.uk/news/tuc-disability-pay-gap-means-disabled-workers-effectively-stop-earning-today), which equates to around £4,000 a year for the average disabled employee working full time, and is wider still for disabled women \[10\]. These figures suggest that skills and experience may be going unused where recruitment and working practices are not accessible.

## The legal context

Inclusive policies rest on a clear legal base. The [Equality Act 2010](https://www.legislation.gov.uk/ukpga/2010/15/contents) is the foundation, prohibiting discrimination, harassment, and victimisation across nine protected characteristics, and requiring employers to make [reasonable adjustments](https://www.natwestmentor.co.uk/news/reasonable-adjustments-in-the-workplace) for disabled employees \[3\]. That duty is anticipatory, so employers are expected to consider barriers in advance rather than waiting for a problem to arise. Many adjustments cost little or nothing, such as flexible hours, written instructions, or a quieter workspace.

These obligations are tightening. From October 2026, the [Employment Rights Act 2025](https://www.natwestmentor.co.uk/news/employment-rights-bill-roadmap-for-2025-2027) raises the duty to take "all reasonable steps" to prevent harassment [](https://www.natwestmentor.co.uk/news/sexual-harassment-legislation-a-roadmap-for-employers)and introduces employer liability for harassment by third parties such as customers, clients, and contractors. The third-party liability applies to all types of harassment, not only sexual harassment, where an employer cannot show it took all reasonable steps to prevent it \[4\]. Pay gap transparency is also expanding: voluntary action plans on gender pay and menopause support arrive in April 2026, with mandatory action plans expected for employers of 250 or more from 2027, and ethnicity and disability pay gap reporting confirmed to follow \[5\]\[6\]\[11\]. Smaller employers fall outside the mandatory thresholds for now, but the requirements are widening, and good data habits make any future obligations easier to meet.

The practical point for policy is that inclusion is moving from good practice towards legal expectation. Designing fair systems now is more straightforward than retrofitting them under a tighter regime later.

## Inclusive recruitment: Reaching and assessing talent fairly

Recruitment is often where inclusion is most easily supported or undermined, because barriers at this stage can filter out candidates before they have a chance to show what they can do.

When writing job descriptions, include only what is genuinely essential, as each additional requirement narrows the applicant pool. Phrases such as "excellent communicator" or "energetic self-starter" describe a personality type rather than a role requirement, and may indirectly disadvantage some candidates. Describe the actual task instead, for example "able to explain technical information clearly to non-specialist clients." Avoid language that signals a narrow group, as "recent graduate" can amount to age discrimination.

Inclusive selection focuses on capability rather than performance under unfamiliar pressure. Practical steps include:

*   providing interview questions in advance, so candidates are assessed on their reasoning rather than how quickly they think on the spot
*   offering work samples or task-based assessments alongside conversation
*   allowing candidates to request adjustments without disadvantage, and asking proactively whether any are needed
*   using structured interviews, where each candidate is asked the same core questions against agreed criteria
*   involving more than one person in shortlisting to reduce individual bias.

Structured approaches reduce the influence of unconscious bias and predict job performance more reliably than unstructured conversation.

It is also worth considering where roles are advertised and who they reach. Anonymising applications at the shortlisting stage and partnering with organisations that support under-represented groups both help widen the pool. Schemes such as [Disability Confident](https://www.gov.uk/government/collections/disability-confident-campaign) offer a structured framework for employers who want to improve how they recruit and retain disabled people.

## Building inclusion into everyday working

Recruitment brings people in. Day-to-day practices influence whether they stay and progress.

Flexibility is one of the most practical ways to support inclusion, and benefits disabled and [neurodivergent employees](https://www.natwestmentor.co.uk/news/neurodiversity-in-the-workplace), carers, parents, older workers, and those managing health conditions. The Employment Rights Act 2025 will strengthen [flexible working rights](https://www.natwestmentor.co.uk/news/flexible-working-how-the-law-is-changing) in 2027 by requiring employers to show that any refusal of a request is reasonable, in addition to relying on statutory grounds \[11\]. Review return-to-office arrangements with care, as fixed attendance requirements can disadvantage some disabled workers who benefit from remote or hybrid working.

Clear communication matters just as much. Specific instructions reduce ambiguity for everyone, and they are essential for employees who interpret language literally. Compare these two approaches:

**Unclear**: "Can you look at the report when you get a chance and let me know your thoughts?"

**Clear**: "Please review the draft report and send any changes by Tuesday at 2 PM, ahead of the client meeting on Wednesday."

Written confirmation after verbal discussions, agendas circulated in advance, and the option to contribute in writing as well as aloud all widen participation.

Pay, performance, and progression decisions should rest on clear, consistent criteria - but consistency alone does not guarantee fairness. A measure applied evenly to everyone can still disadvantage people whose circumstances it fails to account for. Disabled employees are the clearest example: a metric affected by the effects of a disability rather than performance needs to be examined and adjusted where it creates that disadvantage.

The CIPD suggests comparing [promotion rates](https://www.cipd.org/uk/knowledge/evidence-reviews/building-inclusive-workplaces/) between demographic groups to identify patterns that may need attention \[9\].

Employee networks, regular surveys, and feedback channels give people a route to raise issues and help shape policy. Encouraging feedback is widely seen as an effective way to support inclusion, with [63% of British workers](https://stribehq.com/resources/workplace-diversity-and-inclusion-statistics/) identifying it as the best approach \[7\]. The value comes from acting on what these channels reveal, rather than gathering the feedback alone.

## Where to start

A phased approach works well for employers wondering where to begin.

Start by reviewing existing systems. Examine recruitment, communication, performance, and pay processes for hidden barriers, using engagement surveys, focus groups, and workforce data to show where outcomes differ between groups.

Next, introduce low-cost changes and trial them. Clearer job adverts, structured interviews, advance agendas, accessible meeting practices, and consistent flexible working policies are inexpensive and make a noticeable difference. Run them with willing teams first, gather feedback, and refine.

Once changes prove effective, formalise them in policy, support them with manager training, and build them into leadership and performance frameworks so they no longer depend on individual champions. Prepare for the reporting duties ahead by capturing relevant data before it becomes mandatory.

Throughout, leadership behaviour matters alongside written policy. When senior people support inclusion visibly, treat adjustments as routine, and ask what works best for each person, the culture tends to follow. Inclusion is less a single project than a consistent way of working, and the organisations that treat it that way tend to recruit from a wider pool, keep people for longer, and meet their legal duties with less last-minute scramble.

_This article is intended for informational purposes only and does not constitute legal advice. The information is accurate at the time of writing but may be subject to change. For advice specific to your situation, please consult a qualified professional._

\[1\] GOV.UK, Government commits to introducing mandatory ethnicity and disability pay gap reporting for large employers, March 2026.

\[2\] House of Commons Work and Pensions Committee, Employment support for disabled people: Disability at Work (ONS figures, Q2 2025), 2026.

\[3\] DavidsonMorris, Equality, Diversity and Inclusion: 2026 Employer Guide, February 2026.

\[4\] Penningtons Manches Cooper, Harassment and the Employment Rights Act 2025: what employers need to know, February 2026.

\[5\] Lewis Silkin, What's in the Employment Rights Act?, February 2026.

\[6\] Pinsent Masons, UK government to progress mandatory ethnicity and disability pay gap reporting, March 2026.

\[7\] Stribe, Diversity and inclusion statistics every workplace leader should know in 2026 (citing YouGov and Nigel Wright Group), November 2025.

\[8\] CIPD, Building inclusive workplaces: Assessing the evidence, 2019.

\[9\] CIPD, Inclusion at Work: executive summary, 2022.

\[10\] TUC, Disability pay gap means disabled workers effectively stop earning from today (15.5% gap, analysis of ONS figures), November 2025.

\[11\] ACAS, Employment Rights Act 2025.

Inclusive policies help organisations attract talent, retain staff, and meet their legal duties. With new harassment rules and pay gap reporting arriving across 2026 and 2027, this guide explains what inclusion involves and how to build it into everyday practice.

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Inclusive workplace policies: A practical guide for UK employers

The 2026 World Cup could cost employers around [$17 billion in lost productivity](https://www.businesswire.com/news/home/20260602114727/en/World-Cup-Could-Cost-Employers-$17-Billion-in-Lost-Productivity-UKG-Says) worldwide, according to research published by workforce software firm UKG. The same study found that 37% of employees plan to adjust their work schedule around the tournament, and more than a quarter expect to miss work by arriving late, leaving early, or skipping a day entirely. \[1\]

For UK employers, the timing makes this particularly relevant. The tournament runs from 11 June to 19 July 2026, hosted across the United States, Canada, and Mexico, which means most matches fall in the UK evening or later. England open against Croatia on Wednesday 17 June at 9pm BST, play Ghana on Tuesday 23 June at 9pm, and finish the group stage against Panama on Saturday 27 June at 10pm \[2\]. If either England or Scotland progress, the knockout fixtures run later still, with some kick-offs scheduled for 1am, 2am, or beyond in UK time.

Late nights, and the temptation of a drink while watching, create a predictable pattern: lateness, tiredness, reduced productivity, and short-notice absence the morning after a big game \[3\]. This article sets out the main risks and the practical steps employers can take to manage them while keeping morale high.

## Summary

*   Most matches kick off late in UK time, so the main risk is next-day disruption: lateness, tiredness, and short-notice absence, rather than time off during the working day.
*   The disruption grows if the teams your staff follow progress, as knockout fixtures run into the early hours of UK mornings.
*   Plan staffing now. Review cover for popular fixtures, knockout games, and the days immediately after, particularly for client-facing and business-critical work.
*   Decide your annual leave approach early and communicate it, applying any limits on numbers off at once consistently and fairly.
*   Remind staff of your sickness absence and reporting policies before the tournament. Note that Statutory Sick Pay is now payable from day one of absence, which raises the cost of unplanned sickness.
*   Flexibility, used consistently, often works better than rigid enforcement. Adjusted start times or remote working after late games can reduce both absence and resentment.
*   Screening the highlights of matches or running sweepstakes can boost morale, provided participation is genuinely optional and non-followers are not excluded.
*   Apply conduct, dignity at work, and equal opportunities policies as normal. Football is not an excuse for harassment, discrimination, or exclusion.

## Why this tournament is different

Major sporting events usually raise the same questions for employers: how to handle holiday requests, manage productivity, and deal with absence. The 2026 World Cup carries an unusual twist because of where it is being held.

Because the tournament is hosted in North America, most fixtures take place outside normal UK working hours. On one hand, this reduces the pressure for time off during the working day, since fewer matches clash with it. On the other hand, late-evening and overnight kick-offs create a different problem: employees staying up to watch, then struggling the next morning. With both England and Scotland qualified, interest across UK workforces is likely to be high. The home nations won't be the only draw, either. This is the first 48-team World Cup, and many workplaces will include staff following Sweden, Czechia, Brazil, or other qualified sides, whose key fixtures may fall at different times again \[5\].

Hybrid and remote working adds another dimension. It can make it easier for someone to stay up through the night and attempt to work the following day, with predictable effects on focus and output. It also gives employers less direct visibility of how working hours are actually spent. None of this is a reason to clamp down, but it is a reason to set clear expectations in advance.

## Planning staffing and cover

The single most useful step is to look ahead at the fixture calendar and map it against your own busy periods and business-critical work. Identify the dates most likely to affect attendance: the group games your staff are most likely to follow, any knockout fixtures, and the working days immediately afterwards.

Review whether you have enough cover for client-facing work, phone lines, deadlines, shifts, site work, and any service that cannot simply pause. Where gaps appear, address them early through planned leave, temporary cover, or adjusted deadlines, rather than discovering the problem on the morning itself. Shift workers and rota-based teams need particular attention, as their hours may overlap directly with popular fixtures even when office-based staff are unaffected.

## Annual leave requests

Expect a rise in annual leave requests around key matches and the days after them. Decide your approach before the requests arrive, and make it clear to staff.

A first-come, first-served system is common and easy to explain, but apply it consistently. If you need to limit the number of people off at any one time to maintain cover, set that limit in advance and apply it to everyone on the same basis. Inconsistent decisions, where one team is granted leave freely and another refused, are a frequent source of resentment and, at worst, grievances.

It is also worth reminding employees that leave needs to be requested and approved in the normal way, and that approval depends on business needs. Communicating this early, ideally before the tournament begins, manages expectations and reduces friction when popular dates fill up.

## Sickness absence and "sickies"

The most commonly raised concern is the "sickie": an employee calling in sick the morning after a late game, whether through genuine tiredness, a hangover, or simply to watch the highlights. This is where a clear, well-communicated sickness absence policy earns its place.

Remind staff before the tournament of your sickness reporting procedures, the standards expected, and the consequences of unauthorised absence. Monitoring absence levels during the tournament, and noting any patterns that suggest a fixture-related spike, allows you to address issues fairly and on evidence rather than assumption.

A word of caution on judging which absences are "genuine". A hangover may be self-inflicted, but employers should avoid making assumptions about which illnesses count and which do not, as this can create inconsistency and unfairness. The better approach is to apply your policy evenly, distinguish carefully between someone who is genuinely unfit for work and someone whose absence appears not to be, and take proportionate action where there is a real concern. With [unfair dismissal](https://www.natwestmentor.co.uk/news/unfair-dismissal-changes-2027) protections changing, fair and documented process is worth getting right.

One change makes this more pressing in 2026. Recent [Statutory Sick Pay](https://www.natwestmentor.co.uk/news/statutory-sick-pay-ssp-changes) reforms mean that even a short absence can now trigger SSP from day one, so short-notice sickness after a late game costs employers more than it used to \[4\]. That raises the value of clear policies, accurate records, and consistent handling.

## Flexibility as an alternative to enforcement

Rigid enforcement is not the only option, and it is often not the most effective one. Where the nature of the work allows, a degree of planned flexibility can reduce both absence and ill-feeling.

Options worth considering include adjusted start times the morning after a late fixture, allowing affected staff to begin later and finish later, or to work from home where the role permits. Scheduling fewer early-morning meetings on the days after major games is a small change that takes pressure off. Some employers allow staff to use flexible or [flexible working](https://www.natwestmentor.co.uk/news/flexible-working-how-the-law-is-changing) arrangements during the tournament, provided output and cover are maintained.

The key, as with leave, is consistency. Flexibility offered to one group and withheld from another, without a clear operational reason, undermines trust. It also helps to be clear that flexibility is a two-way arrangement: it depends on staff maintaining their standards and not abusing the goodwill, which protects colleagues who have no interest in the football from carrying an unfair share of the load.

## Turning the tournament into a positive

Handled well, the World Cup can lift morale rather than drain productivity. Many employers choose to embrace it.

Screening selected matches or highlights in the workplace, or allowing staff to watch during breaks, can build a sense of occasion, particularly for fixtures that fall within or close to working hours. Sweepstakes, predictions leagues, themed lunches, or charity initiatives tied to the tournament can engage people across the organisation. Where employees watch a match during working time, you can reasonably ask them to make up the time, provided this is agreed in advance.

The important caveat is inclusion. Not everyone follows football, and any activity should be genuinely optional. Plan so that those who opt out are not left to cover a disproportionate share of the work, and that the workplace does not tip into pressure to take part. Done thoughtfully, these initiatives bring people together; done carelessly, they can alienate part of the workforce.

## Conduct, inclusion, and discrimination risks

Heightened emotion around international football can spill into behaviour that crosses a line. Before the tournament begins, remind staff that your usual standards still apply, including policies on dignity at work, bullying and harassment, equal opportunities, social media, and conduct.

The risks are real. Banter about national teams can shade into comments about nationality or ethnicity, which may amount to harassment or discrimination. Rivalry between supporters of different teams should not become a route to exclusion or intimidation. These are not reasons to suppress everyone's enthusiasm, but they are reasons to be clear that football provides no licence for offensive remarks or behaviour that makes colleagues uncomfortable.

This matters more than usual in 2026, as employer duties around harassment are tightening. Handling World Cup conduct well now also puts a workplace in a stronger position for those changes. For a fuller picture, see our guidance on [building an inclusive workplace](https://www.natwestmentor.co.uk/news/building-a-diverse-equal-and-inclusive-workplace).

## Preparing now

A short checklist for the coming weeks:

*   map the key fixtures against your busy periods, based on your knowledge of what national football teams your employees support, and identify where cover is at risk
*   decide and communicate your annual leave approach, including any limits on numbers off at once
*   remind staff of sickness reporting procedures and conduct standards before the first game
*   review your sickness absence policy in light of the day-one SSP change, and make sure records and handling are consistent
*   decide whether you will offer flexibility, screen matches, or run activities, and set the ground rules clearly
*   brief managers so that leave, flexibility, and absence are handled the same way across teams.

A clear, fair, and well-communicated approach lets employees enjoy the tournament while the business keeps running. Setting expectations now, rather than improvising on the morning after England's opening game, is the difference between a month of goodwill and a month of friction.

_This article is intended for informational purposes only and does not constitute legal advice. The information is accurate at the time of writing but may be subject to change. For advice specific to your situation, please consult a qualified professional._

\[1\] UKG, World Cup Could Cost Employers $17 Billion in Lost Productivity, June 2026.

\[2\] FIFA / England Football, England FIFA World Cup 2026 match schedule, May 2026.

\[3\] Personnel Today, Employers urged to prepare for 'sickies' during World Cup, 2026.

\[4\] VWV, New statutory sick pay rules effective from 6 April 2026, April 2026.

\[5\] Brightmine, World Cup 2026: Employers' guide to workplace implications, April 2026.

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World Cup 2026: How employers can manage absence and disruption

Men's Health Week, organised by the [Men's Health Forum](https://www.menshealthforum.org.uk/mhw), runs from 15 to 21 June 2026 \[1\]. For employers, it offers a useful focal point to review how well existing wellbeing provision reaches the men on their teams, and to identify changes that could improve engagement and outcomes year-round.

The data suggests this matters. Men experience mental and physical health conditions at broadly similar rates to women but tend to seek help less often. Around [75% of suicides registered in England and Wales in 2023 were male](https://www.matesinmind.org/training-and-resources/men-s-health-week-uk-15-21-june-2026), and suicide remains the leading cause of death for men under 50 in the UK \[2\]. Yet only around [36% of referrals to NHS Talking Therapies are men](https://vitahealthgroup.co.uk/health-hub/articles/mens-mental-health-month-2025/) \[3\], and just over half of men say they would consider seeing a GP about a mental health concern.

The workplace pattern follows a similar shape. In November 2025, the UK government announced the [first Men's Health Strategy for England](https://hansard.parliament.uk/commons/2025-11-19/debates/25111932000017/Men%E2%80%99SHealthStrategyForEngland), citing the impact of men's health on "families, workplaces and communities" \[4\]. Employers sit at a useful point of influence: a place where men spend a significant share of their adult life, where preventative information can reach them at scale, and where small adjustments to communication, manager training, and flexibility can support better engagement with health services.

This article sets out what recent UK research shows about men's health at work, where common gaps appear, and the practical steps employers can take.

## Summary

*   Men's Health Week 2026 runs from 15 to 21 June, providing employers with a focused window to review wellbeing provision and engagement among male staff \[1\].
*   Around 75% of suicide deaths in England and Wales are male, and suicide is the leading cause of death for men under 50 \[2\].
*   Men are less likely to access psychological therapies - only 36% of NHS Talking Therapies referrals are men \[3\].
*   UK Employee Assistance Programme data shows 56% of calls are made by women and just 29.5% by men, pointing to gendered patterns in engagement with workplace mental health support \[5\].
*   [Only 37% of eligible men have ever been invited for an NHS Health Check](https://www.healthwatch.co.uk/report/2025-11-05/mens-health-how-improve-health-outcomes-knowledge-and-behaviours); workplace information was a notable factor in encouraging younger and ethnic minority men to attend \[6\].
*   Presenteeism reached a post-pandemic high in 2025, reported by 38% of UK businesses, with poor mental wellbeing estimated to cost UK employers £42-£45 billion annually \[7\].
*   Sector matters: construction, agriculture, and the armed forces have elevated suicide rates among men, suggesting targeted support is more effective than generic provision \[8\].
*   Low-cost actions for employers include reviewing how visibly wellbeing support is communicated, signposting NHS Health Checks, offering paid time off for medical appointments, and training line managers to recognise early signs of distress.

## Why men's health at work tends to need separate consideration

Workplace wellbeing initiatives often perform unevenly across gender. Research from the UK Employee Assistance Professionals Association reports that [56% of calls to an Employee Assistance Programme (EAP) are made by women and only 29.5% by men](https://www.eapa.org.uk/why-dont-more-men-use-the-eap/), with the remainder unspecified \[5\]. The same pattern appears across NHS Talking Therapies and routine GP attendance. Mental Health UK reports that men are [significantly less likely to access psychological therapies](https://mentalhealth-uk.org/mens-mental-health/), and [50% of men have struggled with mental health difficulties at some point - yet fewer than half have sought medical advice](https://www.matesinmind.org/training-and-resources/men-s-health-week-uk-15-21-june-2026), with 37% saying they have actively hidden symptoms from those around them \[2\].

The reasons are well documented in research, including stigma, concern about career impact, and cultural expectations around self-reliance. For employers, the practical implication is that simply providing a wellbeing service does not guarantee it will be used equally across the workforce. Reviewing how services are communicated, who they reach, and whether engagement is monitored by gender can help identify where adjustments may be useful.

### The physical health picture

Mental health often dominates the conversation around men's wellbeing, but physical health follows a similar pattern. Men in the UK have a life expectancy around four years shorter than women, with much of the gap attributed to preventable conditions. Men tend to attend GP appointments less frequently than women and engage less consistently with preventative screening.

Healthwatch England's [June 2025 nationally representative poll of 3,575 men](https://www.healthwatch.co.uk/report/2025-11-05/mens-health-how-improve-health-outcomes-knowledge-and-behaviours) found that only 37% of eligible men had ever been invited for an NHS Health Check, although 92% of those who attended would go again, and 79% said they would attend screening if it were introduced routinely by the NHS \[6\]. The same research found that younger and ethnic minority men were particularly likely to be encouraged to attend through information shared at their workplace, suggesting employers can play a useful role in raising awareness of NHS preventative services.

## What current UK workplace data shows

The 2025 wellbeing picture for UK workers is mixed. The [Mental Health UK Burnout Report 2025](https://mhfaengland.org/mhfa-centre/blog/how-do-we-tackle-presenteeism-in-the-workplace/) found that around 9 in 10 UK workers reported high or extreme levels of stress in the past year \[7\]. Presenteeism - working when unwell or beyond contracted hours - was reported by 38% of UK businesses in 2025, the highest level recorded since that survey began.

Poor mental wellbeing is estimated to cost UK employers between [£42 billion and £45 billion annually](https://www.natwestmentor.co.uk/news/developing-employee-wellbeing-initiatives-in-the-workplace), primarily through presenteeism, sickness absence, and turnover \[9\]. The CIPD's [2025 Health and Wellbeing at Work report](https://www.cipd.org/uk/knowledge/reports/health-well-being-work/) found that just over half of employees feel their organisation is supportive of mental health, with many feeling underserved, and over two-thirds saying their line manager is open and approachable on mental health issues - a useful indicator of where workplace support tends to begin in practice \[10\].

### Sector-specific considerations

Certain sectors carry elevated risk for the men who work in them. Research summarised by [Mental Health First Aid Course](https://www.mentalhealthfirstaidcourse.co.uk/blog/mens-mental-health-statistics) suggests construction workers face suicide rates approximately 3.7 times higher than the general population, with agriculture, farming, and the armed forces also showing raised rates \[8\]. Contributing factors commonly cited include long hours, physical isolation, occupational cultures emphasising self-reliance, and reduced access to support in rural or operational settings.

For employers in these sectors, generic wellbeing communications may be less effective than targeted approaches. Industry-specific charities and partnerships can provide sector-relevant support.

*   **Construction**: [Lighthouse Construction Industry Charity](https://www.lighthouseclub.org/) operates a 24/7 helpline and on-site wellbeing services.
*   **Construction and trades**: [Mates in Mind](https://www.matesinmind.org/) provides workplace mental health programmes designed around construction sector culture and shift patterns.
*   **Agriculture**: The Royal Agricultural Benevolent Institution (RABI) and the Farm Safety Foundation (Yellow Wellies) offer support specifically for farming communities.
*   **Armed forces and veterans**: Combat Stress and SSAFA provide specialist mental health support.

## Practical actions for employers

The actions below are intended as options to consider rather than a prescriptive list. The most appropriate combination will depend on workforce size, sector, existing provision, and the gaps identified through internal review.

### Review how visibly support is communicated

Wellbeing services tend to perform better when they are easy to find. A useful starting point is to audit how a new starter or existing employee would access mental health support today: how many clicks from the intranet homepage, whether information appears in routine communications such as payslips or team channels, and whether the language used in promotional material is likely to resonate with employees who don't currently engage.

Crisis lines, [Employee Assistance Programme](https://www.natwestmentor.co.uk/news/unlock-your-employees-potential-with-mentors-new-employee-assistance-programme) details, and signposting to NHS Talking Therapies can usefully appear in multiple locations rather than only within wellbeing-specific resources. Communications that reference health in routine business contexts - induction, monthly team meetings, manager one-to-ones - can help reduce the sense that raising a concern requires waiting for an awareness week.

### Signpost the NHS Health Check

NHS Health Checks are free for adults aged 40-74 in England and screen for early signs of heart disease, diabetes, kidney disease, and stroke. Healthwatch's research suggests workplace information is one of the more effective ways to encourage younger and ethnic minority men to attend \[6\].

Practical options include:

*   including NHS Health Check information in induction packs, internal newsletters, and Men's Health Week communications
*    offering paid time off for the appointment, which Healthwatch identified as a common barrier
*   working with occupational health providers to run on-site health screening days, where workforce size makes this viable
*   promoting other preventative information, including testicular cancer self-checks for younger men and prostate cancer awareness for men over 50.

### Train line managers to recognise early signs

Mental health concerns are often disclosed first to line managers. CIPD research indicates that over two-thirds of employees see their line manager as open and approachable on mental health issues, but training varies considerably across organisations \[10\]. Manager training that includes how distress may present differently - for example, irritability, withdrawal, working excessive hours, or increased alcohol use - can support earlier intervention.

Accredited training options in the UK include:

*   **[MHFA England's Mental Health First Aid (MHFAider) course](https://mhfaengland.org/individuals/adult/mhfa/)**: two-day course covering recognition, conversation, and signposting skills
*   **[MHFA England's Mental Health Skills for Managers course](https://mhfaengland.org/individuals/adult/mental-health-skills-for-managers/)**: shorter format focused specifically on line manager responsibilities
*   **[Mates in Mind training programmes](https://www.matesinmind.org/training-and-resources/mental-health-and-wellbeing-training)**: workplace-focused programmes, particularly suited to construction and trades
*   **free awareness resources**: many providers, including the [Men's Health Forum](https://www.menshealthforum.org.uk/), [Mind](https://www.mind.org.uk/), and [Samaritans](https://www.samaritans.org/), offer free posters, conversation guides, and toolkits employers can use to supplement formal training.

### Review flexibility around appointments

Healthwatch's 2025 research suggests inflexibility around appointment times is a common reason men give for not attending GP visits or Health Checks \[6\]. Routine appointments tend to fall during working hours, which can be a barrier for staff in shift-based, customer-facing, or site-based roles.

Reviewing whether existing policies clearly allow paid time off for medical appointments - including mental health appointments - can help reduce this barrier. The same principle applies to bereavement leave, paternity leave, and care-related leave, where take-up among eligible male employees can be lower than entitlement suggests.

## Support beyond Men's Health Week

Men's Health Week 2026 provides a focused window for awareness activity, but the underlying work tends to be year-round. Single-week campaigns can usefully launch sustained activity - manager training, policy reviews, communication audits - rather than acting as a standalone intervention.

The most effective combination will depend on the organisation, but the principle is consistent: provision that is visible, accessible, and supported by trained managers tends to perform better than provision that exists on paper but is rarely used. For employers reviewing their wellbeing offer in advance of June 2026, Men's Health Week offers a helpful prompt to consider what's working, what could be improved, and which small changes might make the biggest practical difference.

_This article is intended for informational purposes only and does not constitute legal advice. The information is accurate at the time of writing but may be subject to change. For advice specific to your situation, please consult a qualified professional._

\[1\] Men's Health Forum, _Men's Health Week 2026_, 2026.

\[2\] Mates in Mind, _Men's Health Week UK: 15-21 June 2026 resources_, 2026.

\[3\] Vita Health Group, _Men's Mental Health Month 2025_, November 2025.

\[4\] UK Parliament Hansard, _Men's Health Strategy for England debate_, 19 November 2025.

\[5\] UK Employee Assistance Professionals Association (EAPA UK), _Why don't more men use the EAP?_.

\[6\] Healthwatch England, _Men's Health: How to improve health outcomes, knowledge and behaviours_, November 2025.

\[7\] Mental Health First Aid England, _How do we tackle presenteeism in the workplace?_, June 2025.

\[8\] Mental Health First Aid Course, _Men's Mental Health Statistics UK_, April 2026.

\[9\] NatWest Mentor, _Developing employee wellbeing initiatives in the workplace_, 2025.

\[10\] CIPD, _Health and Wellbeing at Work Report 2025_.

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Men's Health Week 2026: How employers can support the men on their teams

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Exit interviews: Getting useful insights from departing employees

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Time to hire in the UK: How long recruitment really takes by industry and role type

A senior team member quietly takes a fortnight off citing a "chest infection" and returns looking thinner and more tired than before. A high performer's output dips for the third quarter running, but no one feels able to ask why. A long-serving colleague resigns without notice, citing only "personal reasons" in their exit interview.

These patterns rarely indicate the problems they appear to be. More often, they signal employees navigating poor mental health in environments that haven't given them the tools, language, or permission to ask for help.

Mental Health Awareness Week 2026 takes place from Monday 11 to Sunday 17 May, with the Mental Health Foundation setting the theme as **Action** \[1\]. The framing is deliberate: awareness of mental health is now widespread, but the gap between knowing something matters and doing something about it remains the central workplace challenge.

The numbers behind the campaign make the case sharper. The Health and Safety Executive's most recent figures, published in November 2025, show that [964,000 workers in Great Britain are suffering from work-related stress, depression or anxiety](https://press.hse.gov.uk/2025/11/20/hse-publishes-annual-workplace-health-and-safety-statistics/) - a 24% increase on the previous year and the highest level since records began in 2001 \[2\]. Mental health conditions now account for 52% of all work-related ill health and 62% of working days lost.

## Summary

*   Mental Health Awareness Week 2026 runs from 11 to 17 May, with the Mental Health Foundation's theme set as **Action** - moving beyond conversation into practical workplace change \[1\].
*   Work-related stress, depression and anxiety reached a record 964,000 cases in 2024/25, accounting for 22.1 million lost working days \[2\].
*   Poor mental health costs UK employers an estimated £51 billion annually, with presenteeism (£24bn) the largest component \[3\].
*   The CIPD's 2025 Health and Wellbeing at Work survey reported sickness absence at 9.4 days per employee - the highest level in over 15 years \[4\].
*   Manager capability is decisive: only 45% of UK managers have been trained to hold mental health conversations, yet training reduces employee desire to quit from 35% to 18% \[5\].
*   The most effective employers treat the week as a launch point for year-round practice, not a standalone campaign.

## What the 2026 theme means for employers

The Mental Health Foundation has run Mental Health Awareness Week for twenty-five years, and the 2026 theme reflects a noticeable shift in tone. Previous years have focused on community (2025), movement, loneliness, and kindness - all framing devices that invite reflection. **Action** is more directive, asking individuals, communities, and organisations to identify one specific change and follow through.

For workplaces, the Mental Health Foundation is encouraging employers to focus on conditions that prevent poor mental health rather than only responding once problems arise \[1\]. This matters because the prevailing model in many UK workplaces remains reactive: signposting Employee Assistance Programmes when someone is already struggling, rather than examining whether workload, management practice, or job design are creating the strain in the first place.

## The scale of the workplace challenge

The HSE's November 2025 figures provide the clearest current picture of how work-related mental health conditions are distributed across the UK economy.

*   Stress, depression or anxiety accounted for 52% of all work-related ill health in 2024/25 \[2\].
*   An estimated 22.1 million working days were lost to these conditions - almost a third higher than the previous year \[2\].
*   Rates for women were approximately 25% higher than for men, with pressure peaking for those aged 25-34.
*   Public administration, human health and social work, and education recorded the highest sectoral rates.

The cost picture is similarly stark. Deloitte's most recent UK research estimates poor mental health costs employers around [£51 billion per year](https://www.deloitte.com/uk/en/about/press-room/poor-mental-health-costs-uk-employers-51-billion-a-year-for-employees.html), with presenteeism (£24bn) the largest single component, followed by staff turnover and absenteeism \[3\]. The CIPD's 2025 Health and Wellbeing at Work survey reported [average sickness absence of 9.4 days per employee per year](https://www.cipd.org/uk/about/press-releases/workplace-absence-soars-nearly-two-working-weeks-each-year) - the highest level in more than fifteen years and a sharp rise from 7.8 days in 2023 \[4\].

Where mental health challenges drive extended absence, the management response often determines whether employees return successfully or disengage further - a separate set of considerations covered in our guidance on [supporting employees during long-term sickness](https://www.natwestmentor.co.uk/news/supporting-employees-during-long-term-sickness) and [reasonable adjustments](https://www.natwestmentor.co.uk/news/reasonable-adjustments-in-the-workplace).

## Why managers sit at the centre of the response

Research consistently identifies the line manager relationship as the most influential single factor in workplace mental health. Recent figures suggest [nearly 70% of employees say their manager affects their mental health as much as their partner does](https://mhfaengland.org/mhfa-centre/blog/workplace-mental-health-statistics-2026/) - more than doctors (51%) or therapists (41%) \[5\].

Yet the same data shows the gap between this influence and the support managers themselves receive. Only 38% of UK organisation leaders talk openly about mental health, only 45% of managers have been trained to have mental health conversations, and just 51% of employees believe their manager is equipped to offer support \[5\]. Where training is provided, the impact is measurable: manager confidence in supporting team members rises by 53%, and employee desire to quit falls from 35% to 18%.

For Mental Health Awareness Week 2026, the most useful action many organisations could take is also one of the most overlooked: equipping the people who manage others with practical conversation skills, then giving them permission to use them. A manager who can recognise signs of struggle, listen without rushing to solve, and signpost confidently to internal or external support is doing the work the awareness week is asking for.

## Four practical actions for the week

Mental Health Awareness Week works best when it functions as a launch point rather than a standalone event. The following actions are deliberately scaled to be deliverable by small and medium employers without specialist budgets.

### 1\. Run a workload audit before you run a wellbeing event

Before adding wellbeing initiatives, examine whether workload itself is the issue. The HSE's [Management Standards](https://www.hse.gov.uk/stress/standards/) identify six areas of work design that affect stress: demands, control, support, relationships, role clarity, and change \[6\]. A short anonymous pulse survey or structured one-to-one round can reveal whether deadlines, role ambiguity, or organisational change are the underlying drivers.

### 2\. Audit your Employee Assistance Programme communications

Many employers fund an EAP that staff have either forgotten about or never knew existed. The week is a useful prompt to refresh communications: clarify what the EAP covers, confirm confidentiality, and reduce the friction of access. Some providers offer 24/7 telephone counselling, structured therapy sessions, financial advice, and bereavement support - all underused when the route to access is unclear. For employers without current provision, an [Employee Assistance Programme](https://www.natwestmentor.co.uk/news/unlock-your-employees-potential-with-mentors-new-employee-assistance-programme) is worth exploring as part of a broader wellbeing approach.

### 3\. Train the right group of managers properly

A single group of well-trained managers achieves more than a generic all-staff webinar. [Mental Health First Aid England](https://mhfaengland.org/) offers accredited two-day MHFAider courses, while Mental Health UK and Mind run shorter manager-focused conversation training. Pick a tier that fits your budget and commit to refresher sessions. Training without follow-through fades within months.

### 4\. Embed one routine that outlasts the awareness week

The week's value lies in what continues afterwards. A monthly wellbeing check-in question added to existing one-to-ones. A standing fortnightly "no meetings" afternoon. A reminder in the leaver process to ask about wellbeing factors in resignation. One embedded routine creates more cumulative impact than ten one-off events. For employers building a more structured year-round approach, our guidance on [developing employee wellbeing initiatives in the workplace](https://www.natwestmentor.co.uk/news/developing-employee-wellbeing-initiatives-in-the-workplace) sets out the foundations.

## Recognising the limits of awareness

The Mental Health Foundation's choice of theme reflects a hard-won recognition: awareness without structural change risks frustration. Employees who hear leadership talk about wellbeing whilst experiencing unmanageable workloads, unsupportive line management, or unclear role expectations often feel less safe disclosing concerns, not more.

Recent data illustrates this tension clearly. The Mental Health UK Burnout Report 2025 found that 21% of UK workers had needed time off due to stress-related poor mental health, with the steepest increases among those aged 18-44 \[7\]. Yet [only 13-14% of employees feel comfortable discussing their mental health at work](https://newleafhealth.co.uk/blog/key-workplace-mental-health-statistics/), and 35% report having experienced stigma or discrimination after disclosing \[8\].

Closing this gap is not a campaign-week task. It involves leadership behaviour over time, manager capability, fair workload distribution, and systems that make it easier to ask for help than to mask. Mental Health Awareness Week 2026 is a useful prompt to begin - but the organisations that benefit most are those that treat the week as a checkpoint in a longer programme, not the programme itself.

## A starting point, not a finish line

The shift from awareness to action marks a maturing of the conversation about workplace mental health. The data is unambiguous: pressure on UK workers is rising, the cost to employers is substantial, and the interventions that work are well-evidenced. What the 2026 theme asks for is not more research, more posters, or more talk - it is for employers to identify one thing they can change and to take action to change it.

For some, that will be training a group of managers. For others, it will be auditing workload. For others still, it will be reviewing whether their EAP is genuinely accessible or merely listed in the staff handbook. The action doesn't need to be ambitious to be meaningful - it just needs to be specific, have a clear owner, and be followed through.

_This article is intended for informational purposes only and does not constitute legal advice. The information is accurate at the time of writing but may be subject to change. For advice specific to your situation, please consult a qualified professional._

\[1\] Mental Health Foundation, _Mental Health Awareness Week_, 2026.

\[2\] Health and Safety Executive, _HSE publishes annual workplace health and safety statistics_, November 2025.

\[3\] Deloitte, _Poor mental health costs UK employers £51 billion a year_, 2024.

\[4\] CIPD, _Health and Wellbeing at Work Survey_, 2025.

\[5\] MHFA England, _Key workplace mental health statistics for 2026_, December 2025.

\[6\] Health and Safety Executive, _Tackling work-related stress using the Management Standards approach_, 2025.

\[7\] Mental Health UK, _Burnout Report 2025_, 2025.

\[8\] New Leaf Health, _Key workplace mental health statistics_, 2026.

GettyImages-1160667165 (2).jpg

Mental Health Awareness Week 2026: Turning awareness into action

Every year on 28 April, the International Labour Organization (ILO) marks World Day for Health and Safety at Work, an international awareness campaign encouraging employers to prevent workplace accidents and occupational ill health \[1\]. For businesses, the day provides a practical prompt to review existing health and safety practices and identify areas for improvement.

In Great Britain, the most recent data highlights the scale of the challenge. An estimated 1.9 million workers suffered from work-related ill health in 2024/25, while 680,000 sustained a non-fatal injury \[2\]. Together, these accounted for 40.1 million lost working days, at an estimated cost of £22.9 billion annually \[2\]. Stress, depression and anxiety remain the single largest category of work-related ill health, affecting 964,000 workers \[3\].

World Day offers an opportunity for employers of all sizes to assess risks, act on them, and create conditions where people can work safely and sustainably.

## Summary

*   World Day for Health and Safety at Work takes place on 28 April each year, coordinated by the ILO to promote the prevention of workplace accidents and ill health \[1\].
*   The 2026 theme focuses on healthy psychosocial working environments, highlighting how workload, communication, support, and job design affect both wellbeing and safety outcomes \[4\].
*   In Great Britain, 1.9 million workers reported work-related ill health in 2024/25, with stress, depression and anxiety accounting for 964,000 of those cases \[2\]\[3\].
*   Work-related ill health and injuries cost an estimated £22.9 billion annually \[2\].
*   Employers can use the day to review risk assessments, hold safety conversations with teams, and identify practical improvements that don't require large budgets.
*   The HSE's Working Minds campaign and free stress risk assessment tools provide a structured starting point for businesses of all sizes \[5\].

## What is World Day for Health and Safety at Work?

The ILO began observing World Day for Health and Safety at Work in 2003 as part of its global strategy on occupational safety and health \[1\]. Each year carries a different theme designed to draw attention to emerging or persistent workplace risks. Previous themes have covered topics including digitalisation, climate change, and the role of social dialogue in building safety cultures.

The day serves a dual purpose. Internationally, it raises the political profile of occupational safety and health. At an organisational level, it provides a reason for employers to review their practices, engage staff in safety conversations, and address risks that may have gone unexamined.

It's worth noting that 28 April also coincides with Workers' Memorial Day, which commemorates those who have been injured or suffered illness through their work. For employers, the date carries both a reflective and a forward-looking purpose: acknowledging the human cost of unsafe or unhealthy work, and committing to preventing it.

## The 2026 theme: Healthy psychosocial working environments

This year, the ILO's theme centres on the [psychosocial working environment](https://www.ilo.org/topics-and-sectors/safety-and-health-work/world-day-safety-and-health-work-2026) \[4\]. This refers to the way work is designed, organised, and managed, and how those factors shape day-to-day working conditions.

Psychosocial risks include excessive workload, unrealistic deadlines, lack of autonomy, poor management support, unclear roles, and badly communicated change. When these factors are left unmanaged, they become workplace hazards in much the same way that a trailing cable or a missing guardrail would be. They increase the likelihood of errors, accidents, and long-term ill health.

The [HSE identifies six areas](https://www.hse.gov.uk/stress/risk-assessment.htm) of work design that can affect stress levels:

*   demands
*   control
*   support
*   relationships
*   role
*   change.

**Demands** become a risk when workloads exceed what someone can reasonably deliver within their contracted hours, when deadlines are routinely unrealistic, or when the emotional demands of a role go unacknowledged. **Control** matters because employees who have little say over how they do their work, when they take breaks, or how their day is structured experience measurably higher stress levels. **Support** from managers and colleagues acts as a buffer; without it, even manageable workloads become overwhelming.

**Relationships** at work affect safety directly. Bullying, harassment, and interpersonal conflict don't just cause distress. They create distraction, reduce communication, and erode the trust that safe working depends on. **Role** clarity is equally important: employees who aren't sure what's expected of them, or whose responsibilities conflict, make more errors. And poorly communicated **change**, whether organisational restructures, new systems, or shifts in leadership, creates uncertainty that compounds existing pressures.

The 2026 theme is a recognition that workplace safety has evolved beyond hard hats and hazard signs. The conditions that cause psychological harm need to be assessed and managed with the same rigour as physical risks.

## Where things stand in the UK

The Health and Safety Executive's [annual statistics for 2024/25](https://www.hse.gov.uk/statistics/overview.htm) provide a useful benchmark for employers reviewing their own performance \[2\].

An estimated 1.9 million workers suffered from work-related ill health during the year. Of those, [964,000 reported stress, depression or anxiety](https://www.hse.gov.uk/Statistics/assets/docs/stress.pdf) caused or made worse by work, making it the most common form of occupational ill health by a significant margin \[3\]. The rate of self-reported work-related mental ill health has been climbing since before the pandemic and has accelerated in the years since \[3\]. Female workers report rates around 25% higher than male colleagues \[3\].

Non-fatal injuries affected an estimated 680,000 workers, with slips, trips and falls remaining the most common cause across all sectors \[2\]. The accommodation and food services industry recorded the highest injury rate \[2\].

The combined cost of workplace injuries and new cases of work-related ill health stands at an estimated £22.9 billion annually \[2\]. Poor mental wellbeing alone [costs UK employers between £42 billion and £45 billion](https://www.mentalhealth.org.uk/explore-mental-health/statistics/mental-health-work-statistics) a year through presenteeism, sickness absence, and staff turnover \[6\]. Evidence from Deloitte suggests [employers see a return of approximately £5.30 for every £1 invested](https://www.deloitte.com/uk/en/services/consulting/research/mental-health-and-employers-refreshing-the-case-for-investment.html) in mental health support \[7\].

These figures illustrate why World Day matters as more than a calendar event. The scale of work-related ill health represents a significant operational cost for businesses, and much of it is preventable through better job design, clearer communication, and more consistent management practices.

## How to mark the day in your workplace

World Day for Health and Safety at Work doesn't require a large-scale event. For most businesses, particularly smaller ones, the most valuable thing you can do is use the date as a trigger for practical action.

*   **Review your risk assessments.** Check whether your existing assessments cover psychosocial risks alongside physical ones. If your risk assessment addresses fire exits and manual handling but says nothing about workload, communication, or management support, it's incomplete. The HSE provides [free templates and example assessments](https://www.hse.gov.uk/stress/risk-assessment.htm) for work-related stress \[5\].
*   **Hold a team conversation.** Toolbox talks, team meetings, or structured one-to-ones give employees an opportunity to raise concerns about working conditions. Keep it practical: What's working well? What's causing unnecessary pressure? What one thing could we change?
*   **Check your environment.** Walk through your workplace with fresh eyes. Are workstations set up properly? Is lighting adequate? Are quiet spaces available for focused work? Are emergency procedures clearly displayed and understood? Small environmental improvements often cost very little.
*   **Signpost existing resources.** Many employees don't know what support is already available to them. Use the day to highlight accessibility features in existing software, your [Employee Assistance Programme](https://www.natwestmentor.co.uk/employee-assistance-programme/) if you have one, flexible working options, and any relevant training opportunities.
*   **Recognise good practice.** If teams or individuals have contributed to a safer or healthier working environment, acknowledge it. Recognition reinforces the behaviours you want to see and signals that health and safety is valued, not just required.

## Making it count

World Day for Health and Safety at Work is one day. The conditions that lead to 22.1 million lost working days exist across all the others. The value of 28 April lies not in marking a date but in using it as a catalyst - to have a conversation you've been putting off, to review a process that hasn't been updated since before the pandemic, or to ask your team a question you haven't asked before.

For smaller businesses especially, the gap between awareness and action can feel wide. But the evidence suggests that the most effective interventions are rarely the most expensive. Clearer communication, visible leadership, manageable workloads, and a culture where raising concerns is normal rather than exceptional - these cost very little to implement and can materially improve both [employee wellbeing](https://www.natwestmentor.co.uk/news/developing-employee-wellbeing-initiatives-in-the-workplace) and business performance.

The question isn't whether your business can afford to invest in psychosocial safety. Given the costs of inaction, the more pressing question is whether it can afford not to.

_This article is intended for informational purposes only and does not constitute legal advice. The information is accurate at the time of writing but may be subject to change. For advice specific to your situation, please consult a qualified professional._

\[1\] United Nations, _World Day for Safety and Health at Work_.

\[2\] HSE, _Key figures for Great Britain 2024 to 2025_, November 2025.

\[3\] HSE, _Work-related stress, depression or anxiety statistics in Great Britain, 2025_, November 2025.

\[4\] ILO, _World Day for Safety and Health at Work 2026: Healthy psychosocial working environments_.

\[5\] HSE, _Working Minds campaign and stress risk assessment guidance_.

\[6\] Mental Health Foundation, _Mental health at work: statistics_.

\[7\] Deloitte, _Mental health and employers: refreshing the case for investment_, 2020.

GettyImages-585283345 (1).jpg

World Day for Health and Safety at Work 2026

From 1st January 2027, employees will be entitled to bring an unfair dismissal claim after just six months of continuous service - down from the current two-year threshold. For HR professionals and business owners, this is an important development to plan for now rather than later. Although the change takes effect at the start of 2027, it will apply to existing employees, meaning workforce planning, performance management, and documentation practices will need to adapt well in advance. 
 
## Summary

- From 1 January 2027, the qualifying period for unfair dismissal protection reduces from two years to six months. 
- The change is retrospective - any employee with at least six months' service by 31 December 2026 gains protection automatically on 1 January 2027. 
- Employers can no longer rely on the two-year buffer when managing performance, conduct, or cultural fit in the early stages of employment. 
- A fair reason and fair procedure will be required for any dismissal once an employee hits the six-month mark. 
- Compensatory awards for unfair dismissal will be uncapped. 
- Probationary periods and statutory unfair dismissal rights are legally separate - extending a probationary period does not delay an employee's rights. 
- Employers may wish to adopt a short probationary period with structured check-ins throughout, and a formal review before the probationary period ends. 
- HR policies, contracts, and offer letters that reference the two-year threshold must be updated before 31 December 2026. 
- Line managers need targeted training on the new timelines and fair performance management practices. 
- Organisations that invest in clear expectations, regular feedback, and consistent documentation from day one will be best placed to manage risk under the new rules. 

## The current position

Under the existing rules, employees must complete two years' continuous service before they can bring a standard unfair dismissal claim. This two-year threshold remains in force until 31 December 2026. 

## When does the new unfair dismissal rule come into force?  

On 1 January 2027, the qualifying period for ordinary unfair dismissal protection reduces from two years to six months. This means employees will be entitled to the full protections of unfair dismissal law - including the right to a fair reason for dismissal and a fair procedure - much earlier in their employment. 

## Who gains unfair dismissal rights on 1 January 2027?

The change will apply retrospectively to existing employees. This means that any employee who has already accumulated at least six months’ service by 31 December 2026 will gain unfair dismissal rights automatically on 1 January 2027, without needing to reach the two-year threshold. 

The practical impact is wider than many employers may initially assume. 

- An employee hired on 1 July 2026 will have exactly six months' service by 31 December 2026 and will qualify on 1 January 2027. 
- An employee hired on 1 October 2026 will reach six months' service on 1 April 2027 and will qualify from that date. 
- An employee hired on 1 March 2025 will have over 22 months' service by 1 January 2027 - well beyond the new threshold - and will qualify immediately. 
- An employee hired on 1 March 2026 will have ten months' service by 31 December 2026 and will qualify on 1 January 2027.  

In short: any employee that started employment before 1st July 2026 will have at least six months' service by the 31st December 2026 and will automatically qualify for unfair dismissal protection on 1st January 2027. 

**Quick reference: When do employees qualify?**

<table>
  <thead>
    <tr>
      <th>Start date</th>
      <th>Service by 31 Dec 2026</th>
      <th>Gains rights</th>
    </tr>
  </thead>
  <tbody>
    <tr>
      <td>1 July 2026</td>
      <td>6 months</td>
      <td>1 January 2027</td>
    </tr>
    <tr>
      <td>1 March 2026</td>
      <td>10 months</td>
      <td>1 January 2027</td>
    </tr>
    <tr>
      <td>1 March 2025</td>
      <td>22 months</td>
      <td>1 January 2027</td>
    </tr>
    <tr>
      <td>1 October 2026</td>
      <td>3 months</td>
      <td>1 April 2027</td>
    </tr>
  </tbody>
</table>

## What the new rules mean in practice

The changes place a greater premium on good people management from day one of employment. The current two-year qualifying period effectively meant that dismissal decisions in the first two years carried lower legal risk. That buffer will soon be significantly reduced.  

HR teams and line managers will need to ensure that robust and documented processes are in place before the rule changes take effect. Here are some key actions to consider before the end of 2026. 

- Audit your current workforce. Identify employees who will cross the six-month threshold before or on 1 January 2027. This will help you plan any ongoing performance conversations with appropriate care and documentation. 

- Review and update your probationary period framework. With unfair dismissal rights arising at six months, probationary reviews and documentation take on added significance. Ensure that performance concerns are identified, communicated, and recorded within the probationary period. 

- Update HR policies and employment contracts. Any documents that reference the two-year qualifying period - including offer letters, handbooks, and contracts - will need to be revised. This should be completed before 31 December 2026. 

- Brief your line managers. Many managers are unaware of the current two-year rule, let alone the incoming change. Targeted training on the new timelines and on fair performance management practices is essential. 

## Do the new unfair dismissal qualifying rules apply to employees in their probationary period

A question many employers will face is what happens when an employee is still in their probationary period when the January 2027 rules take effect. The answer is that probationary periods and statutory unfair dismissal rights are legally separate - one does not govern the other. There is no legal requirement to put in place probationary periods, these are useful for employers but not essential. 

From 1 January 2027, an employee will gain unfair dismissal protection at six months’ continuous service regardless of whether they are still within their probationary period. If an employer's standard probationary period runs for 12 months, for example, an employee will have full statutory protection six months before their probationary period ends. Extending a probationary period does not delay the accrual of these rights; the statutory position will always overrule contractual probationary periods. 

If dismissal is being considered during the probationary period and the employee has accrued more than six months’ qualifying service from 1 January 2027, employers should seek legal advice before proceeding. They should also ensure that a documented record of discussions and formal meetings is maintained, as this will be essential in defending any subsequent unfair dismissal claim. 

## Removal of the cap on compensatory awards

The compensatory award for ordinary unfair dismissal will become uncapped from 1 January 2027, removing the current limit of either 52 weeks' gross pay or the statutory maximum - whichever is lower. This is one of the most significant commercial changes for employers, substantially increasing potential financial exposure and likely driving up settlement values and tribunal litigation.  

## Final thoughts 

The reduction in the qualifying period is part of a [broader programme of employment law reform under the Employment Rights Act 2025](https://www.natwestmentor.co.uk/news/employment-law-changes-in-april-2026-what-you-need-to-know). The stated aim is to provide workers with greater security and protection from the early stages of employment, but for employers it represents a fundamental shift in how employment risk is managed. 

In practical terms, the change brings forward the point at which dismissal decisions become legally scrutinised. What was previously a relatively low-risk period for addressing performance or capability will now require a more structured, evidence-based approach within the first six months of employment. The margin for informal decision-making is significantly reduced. 

Employers should therefore view this not simply as a legal update, but as an operational one. Organisations that rely on informal probationary periods, delayed feedback, or lightly documented decision-making will be more exposed under the new regime. Conversely, businesses that implement clear expectations during onboarding, regular performance discussions, and consistent documentation from day one will be better positioned to manage risk and achieve fair dismissal outcomes. 

Although January 2027 may seem distant, the retrospective nature of the change means its impact will be felt immediately. Employers who wait until late 2026 to prepare may find themselves managing a workforce where a significant proportion of employees have already acquired protection. 

The most effective response is early preparation. Reviewing probationary frameworks, upskilling managers, and embedding consistent performance management practices now will ensure that, when the new rules take effect, they do so within a system that is already aligned to the higher standard expected. 

## Further reading

For more information on the upcoming employment law changes, you may find the following articles helpful: 

[Statutory Sick Pay (SSP) changes from April 2026 ](https://www.natwestmentor.co.uk/news/statutory-sick-pay-ssp-changes)

[The Fair Work Agency: What this new enforcement body means for employers. ](https://www.natwestmentor.co.uk/news/the-fair-work-agency)

[Employment law changes in April 2026: What you need to know ](https://www.natwestmentor.co.uk/news/employment-law-changes-in-april-2026-what-you-need-to-know)

For the latest HR news and updates, visit our [News blog](https://www.natwestmentor.co.uk/news/). 

_This article is intended for informational purposes only and does not constitute legal advice. The information is accurate at the time of writing but may be subject to change. For advice specific to your situation, please consult a qualified professional._



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