If you’re an HR manager, you’ve probably had at least one conversation about Worker Protection Act training in the last year. It’s been in force since October 2024, and the legal duty it created isn’t going away. If anything, it’s about to get stronger.
If you’re unsure whether your current policies meet the new standard, this article’s for you. We break down what the Worker Protection Act requires you to do and what ‘reasonable steps’ actually looks like day-to-day. And we explain how you can help your team understand what sexual harassment is, and how it can be reported.
What the Worker Protection Act requires
The Worker Protection (Amendment of Equality Act 2010) Act 2023 introduced a new duty: employers must take reasonable steps to prevent sexual harassment of their staff. This covers harassment from colleagues, managers and third parties, such as customers or clients.
It’s a shift in emphasis. In the past, employers were largely judged on how they responded after harassment had taken place. Now, they’re expected to anticipate the risk and act before anything goes wrong.
A few key points to know:
- It applies to every employer, regardless of size or sector.
- Compensation for successful Equality Act harassment claims is uncapped, and not taking action can make that worse.
- The Equality and Human Rights Commission (EHRC) can investigate and enforce independently, even without a tribunal claim or an individual complaint.
This last point matters more than most employers realise. The EHRC’s enforcement powers don’t depend on an individual bringing a claim. The commission can investigate organisations on its own initiative, including from intelligence received via workers, trade unions or media reports.
Why this isn’t a box-ticking exercise
It’s tempting to treat this as paperwork: write a policy, file it away, move on. But that approach won’t hold up.
The EHRC’s technical guidance doesn’t create new legal obligations beyond the Act itself – but it’s the benchmark tribunals routinely refer to when deciding whether an employer took reasonable steps. In other words, what you can evidence matters as much as what you’ve written down.
And the financial risk is real. If an employee proves their employer didn’t take reasonable steps to prevent the harassment they experienced, a tribunal can increase compensation owing by up to 25%. Given that compensation for sexual harassment claims is uncapped, this could represent a significant additional cost.
The numbers suggest awareness still has a way to go. A freedom of information request to Acas found that enquiries about workplace harassment rose by 39% in the first half of 2025. That’s 5,583 calls, an increase of over 1,500 on the year before. Separate research has also found that a significant proportion of organisations have no formal reporting pathway in place at all.
What ‘reasonable steps’ looks like in practice
The Act itself doesn’t hand you a checklist. The EHRC’s updated technical guidance says reasonable steps are assessed in context. This means looking at your organisation’s size, sector, workforce and the extent of third-party contact your staff have. A risk assessment approach is expected, not a generic, one-size-fits-all policy.
In practice, most employers need to show a combination of the following:
- A clear, accessible anti-harassment policy that’s communicated to staff, not just stored on a shared drive
- Regular risk assessments specific to your workplace, your sector and the roles most likely to involve third-party contact
- Structured training for all employees, with separate, deeper coverage for managers who’ll need to handle a report or concern
- A safe, confidential way to report concerns, with a clear process for what happens next
- Documented evidence that complaints are handled promptly and taken seriously
The common thread across all of this is evidence. A good online sexual harassment awareness course is a solid foundation for the staff-wide training piece – and gives you a documented record to point to if you’re ever asked to show what you’ve done.
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Making sure your whole team understands what counts as sexual harassment
A lot of staff genuinely don’t know what constitutes sexual harassment. It’s not always obvious, overt behaviour. It can include comments, jokes or unwanted attention. Even small things can build into a hostile or uncomfortable atmosphere over time.
This is where sexual harassment training for employees can fall short.
Effective training shouldn’t just explain legislation; it should also cover things like:
- What sexual harassment is – including less obvious forms like comments or behaviour that build up over time – and how to recognise it when you see it.
- What employees and managers are each responsible for in preventing and addressing harassment.
- Strategies you can use to help prevent harassment in the workplace.
When everyone in your organisation understands these basics – not just HR and senior leadership – you’re in a far stronger position. You can prevent incidents and demonstrate reasonable steps if you’re ever challenged.
What’s changing next – and why you shouldn’t wait
The Worker Protection Act isn’t the final word on this topic. The Employment Rights Act 2025 became law in December 2025. From October 2026, it’s expected to raise the bar further by changing the standard from ‘reasonable steps’ to ‘all reasonable steps’. Specific regulations defining what ‘all reasonable steps’ means in practice are expected to follow in 2027.
Practically, that means employers who build solid, evidenced processes today are in a much better position when the standard rises. It’s far easier to get this right from the start than to fix it under pressure later.
A practical next step
You don’t need a perfect system overnight. Start by asking yourself a simple question: if the EHRC asked you tomorrow to evidence the reasonable steps you’ve taken, what could you actually show them?
If the honest answer is ‘not much’, that’s your starting point. A documented policy, a recent risk assessment and structured training for your whole workforce will take you a long way towards a credible answer.
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