15 Days to "All Reasonable Steps": Could You Prove Your Harassment Prevention Works?
15 October 2026 · By Oliver Tasker
On 30 October 2026, the legal standard on workplace harassment rises sharply. Employers will have to take "all reasonable steps" to prevent harassment and that duty now reaches harassment of staff by customers, clients, suppliers and other third parties. A policy in the handbook and an old training slide during an induction will not be enough.
What Is Changing
A higher standard. The existing duty to take "reasonable steps" to prevent sexual harassment becomes a duty to take "all reasonable steps". Employees cannot bring a standalone claim for breach of the duty, but if a harassment claim succeeds and a breach is found, compensation can increase by up to 25%. The Equality and Human Rights Commission (EHRC) can also enforce the duty.
Third-party harassment. Employers will be responsible for taking all reasonable steps to prevent harassment of their staff by people who are not employees, including customers, clients, contractors, visitors and members of the public. This covers harassment related to protected characteristics such as race, disability, age and sex, not only sexual harassment. It also covers online conduct, such as abuse on a client video call or in a customer chat queue.
There is no set definition of "all reasonable steps" and employers must apply the higher standard now, judged against their own size, sector and working environment.
Evidence Is the Real Test
The question at tribunal will not be whether you have a policy. It will be whether you identified the risks in your workplace, acted on them and kept the measures under review. Tribunals and the EHRC are likely to scrutinise how risks were identified and what was done about them, so employers should record their decisions and reasoning, including steps they considered and rejected as unreasonable.
Why Generic Does Not Work
A risk assessment bought off the shelf will describe a workplace that does not exist. A bar manager, a care worker, a field engineer and a receptionist face completely different risks, from different people, in different settings. Tailoring is what makes steps "reasonable" in the eyes of a tribunal.
Bespoke Risk Assessments
An effective assessment is built around how your business actually operates. It should:
Map every role and site by the amount and type of third-party contact, including digital interactions
Identify higher-risk situations such as lone working, alcohol, client entertainment, late shifts and social events
Draw on real intelligence: past complaints, grievances, exit interviews and staff feedback
Cover sexual harassment and third-party harassment, with practical controls for each risk identified
Be reviewed regularly and after any complaint, not filed away
Bespoke Training
Training that does not reflect your workplace will not change behaviour or satisfy a tribunal. The right approach is:
Scenario-based, using situations your staff will recognise from their own roles
Role-specific, with separate sessions for frontline staff, managers and senior leaders
Practical for managers, covering how to spot problems, respond to a report, protect the person affected and escalate
Recorded, with attendance and content documented
Repeated, because a one-off session years ago will not meet a duty that is ongoing
Where to Focus Next
Add third-party harassment to your risk assessment and policy, including a clear way to report it
Put conduct expectations into customer, client and supplier contracts where you can
Agree how you will investigate when the person involved is not your employee
Keep a central log of reports, including informal ones
Give leaders ownership of prevention and regular reporting
Impact
Impact Employment Law can help you meet the new standard in a way that fits your business. We deliver tailored, scenario-based training for staff and managers that reflects your sectors and roles and look at a bespoke sexual harassment and third-party harassment risk assessment, review and update your policies. We also help you build the paper trail that shows what you did and why, which is what a tribunal or the EHRC will ask to see. With the duty arriving on 30 October, now is the time to act.
For a quote for your organisation on bespoke training then contact Oliver Tasker:
📞 Call: 01522 776270 ✉️ Email: oliver@impactemploymentlaw.co.uk
Advice. Protection. Impact.