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Status at 31 October 2026: in force since 30 October 2026
Since 30 October 2026 an employer in England, Scotland and Wales must take all reasonable steps to prevent sexual harassment of its employees, and must not permit a third party such as a customer to harass them if it failed to take all reasonable steps to prevent it (Employment Rights Act 2025 sections 20 and 21, brought into force by S.I. 2026/1065). We checked legislation.gov.uk and Acas on 31 October 2026. We found no regulations made under the new power to list steps (section 40B of the Equality Act 2010), so there is no official list or template.
The short version
- A policy is a step, not the duty. The law asks whether you took all reasonable steps. Acas says: “One reasonable step might be to create a policy on sexual harassment.”
- It can sit inside another policy. Acas says you could instead include sexual harassment in a policy on bullying or discrimination.
- Acas lists eight things to include. They are in the table below.
- Third parties belong in it. Customers, clients and other third parties are now part of the duty, so the policy should say how staff report harassment from them and what you will do.
- Consult if you write a specific one. Acas says to consult any recognised trade union or, if there is none, other worker representatives.
- It has to be used. Acas gives an example of an employer whose policy had not been reviewed or used for years, and says it is very unlikely to have taken all reasonable steps.
This guide is general information, not legal advice. It covers Great Britain, not Northern Ireland.
What Acas says a policy should include
| Point | What it can look like in a small business |
|---|---|
| An explanation of what sexual harassment is | Plain examples: comments, touching, messages, jokes, images, including online |
| A statement that you will not tolerate it | One clear sentence, applying to everyone whatever their role or status, and that complaints will be taken seriously and not ignored |
| What to do if you experience or witness it | A range of people to tell (Acas suggests, for example, their manager, a more senior manager, someone trained to deal with complaints, or their trade union representative), and a note that people can usually choose informal or formal, though some things are too serious for informal |
| How managers deal with complaints | Point to your grievance procedure or a separate procedure, and say what happens if a complaint is upheld |
| How you deal with third-party harassment | How staff report it from customers or clients, and what you could do to stop it happening again |
| Support available | For people affected or who witnessed it, managers handling complaints and anyone accused: your employee assistance programme if you have one, and outside sources of support |
| Time off because of sexual harassment | Say how you handle sick leave and appointments for specialist support. Acas says this should usually be paid and should not count against an absence trigger point |
| How you assess and manage the risks | Either in the policy or in separate guidance for managers (see our risk assessment guide) |
One detail Acas stresses for third parties: you cannot use your usual disciplinary procedure if the person accused does not work for you, so the policy should say what you will do instead.
A short template you can adapt
This is our own plain-English wording, written from the Acas points above. Replace the text in square brackets and cut anything that does not fit your business. It is a starting point, not a document that makes you compliant.
> [Business name] sexual harassment policy > > What this is. Sexual harassment is unwanted behaviour of a sexual nature that violates someone’s dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment for them. Examples include comments about someone’s body, sexual jokes, unwanted touching, and sexual messages or images. It can happen once, in person or online. Intention does not decide it: what matters is the effect on the person. > > Our position. We do not tolerate sexual harassment of anyone who works for us, by anyone: colleagues, managers, owners, customers, clients, suppliers or visitors. Complaints will be taken seriously and will not be ignored or covered up. Nobody will be treated badly for making a complaint in good faith. > > If it happens to you or you see it. Tell [name], [name] or [name] as soon as you are able, or later if you need time. You can also tell [outside option, for example a trade union representative]. You can ask us to deal with it informally or make a formal complaint under our [grievance procedure]. Some situations are too serious to deal with informally. You can also tell us about a situation that felt unsafe even if nothing happened. > > Customers and other outsiders. If a customer, client, supplier or visitor harasses you, step away if you can and tell [name] straight away. We will decide what to do, which may include a warning, refusing service or ending a contract, and where there is a crime, telling the police. We will tell you what we did and look at what would stop it happening again. > > How managers deal with it. A manager who is told about harassment must take it seriously, write down what they were told, keep an open mind, and pass it to [name] the same day. [Describe the procedure, and what happens if a complaint is upheld.] > > Support. [Employee assistance programme, if any, and outside sources of support] is available to anyone affected, anyone who witnessed it, managers dealing with a complaint and anyone accused. > > Time off. Time off because of sexual harassment, including sick leave and appointments for specialist support, will be [paid] and will not count towards any absence trigger. > > Risks and review. [Name] assesses the risks of sexual harassment in our work and decides what steps to take. We will review this policy [after any report, when our work changes, and at least once a year].
Before you adopt it
- Make the other policies agree. Acas says to check discipline, social media and dress code policies, for example that online harassment is not tolerated, including on personal devices.
- Consult. If it is a specific sexual harassment policy, Acas says you should do this in consultation with any recognised trade union or, where there is none, other worker representatives.
- Tell everyone. Acas lists telling everyone that sexual harassment is not acceptable, for example as part of induction, and training everyone, managers and senior leaders in what they need. Give the policy to current staff, add it to induction, and keep a dated record that people were told.
- Review it. Acas says to regularly check whether your policies are working and how effective your training is, and to review your policies if harassment happens.
Common mistakes
- Downloading a template and filing it. A policy nobody has been told about does not help you.
- Copying wording written for another country. Many online templates are American or Australian. This duty is in the Equality Act 2010 and applies in England, Scotland and Wales.
- Forgetting third parties. A policy that only deals with colleagues leaves out the customer rule that started on 30 October 2026.
- Making promises you will not keep. If the policy says you will ban any customer who is rude, you have to do it. “May” is safer.
- No way to report except to the manager. Acas says to give a range of options and says workers should be able to report to someone other than their manager.
Free checklist and the full kit
The free 30-Day Action Checklist (two pages from our kit, unaltered) puts the policy in context: who is responsible, the risk assessment, the policy, briefing, records and the first review. The Sexual Harassment Prevention Kit (£14) has a longer fill-in policy, a third-party harassment procedure with wording for a sign, a booking email and a contract, a manager’s guide for taking a report, a staff briefing sheet with sign-in, and three logs. It does not make you compliant. The law does not list the steps, so the kit helps you decide, take and record yours.
Frequently asked questions
Is a sexual harassment policy a legal requirement?
No law says in terms that every employer must have one. The duty is to take all reasonable steps to prevent sexual harassment. Acas says one reasonable step might be to create a policy, and what is reasonable depends on your organisation. For most employers a policy is an obvious step.
Can we put it in our bullying or equality policy?
Acas says you could include sexual harassment in a policy on bullying or discrimination as an alternative. If you do, make sure it still covers the points in the table above, including third parties.
Does a small business need a policy?
The duty applies to employers of any size. Acas lists the size of your organisation as one of the things that decides which steps are reasonable, so a small business may need a shorter, simpler policy than a large one, but it still needs to think about the risks and the steps.
Is training compulsory?
The law does not list training as a required step, and we found no regulations that do. Acas lists informing and training workers among the steps you could take, including training for managers and for someone who can advise people thinking of making a complaint. A short briefing for the whole team, with a record of who attended, is a common small-business approach.
What should the policy say about customers?
How staff report harassment from customers and other third parties, and what you will do about it. Acas says to explain how you will deal with problems, including steps to prevent it happening again. See our guide on customers harassing staff.
Sources
Last checked 31 October 2026.
- Creating a sexual harassment policy, Acas (updated 30 October 2026)
- Steps for employers to prevent sexual harassment, Acas (updated 30 October 2026)
- Employment Rights Act 2025, section 20 and section 21, legislation.gov.uk (in force 30 October 2026, S.I. 2026/1065 regulation 3)
- Equality Act 2010, section 40B, legislation.gov.uk (power to specify reasonable steps; no regulations found)
- Equality Act 2010, section 26, legislation.gov.uk (definition of harassment)
Changes to this guide
- 2 November 2026: Reviewed by Liam Humphreys; no changes to the guidance.
- 31 October 2026: Published, with the byline By Plainfiles until a named review.
This guide is general information written from the official sources listed above and checked on 2 November 2026. It is not legal, tax or financial advice, and Plainfiles is not endorsed by any government body. Rules change, so check the linked official pages for your own situation. Written and designed by Plainfiles with the help of artificial intelligence (AI) tools, then checked against the official legislation and guidance listed in the sources. How we write and check our guides.