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The All Reasonable Steps Duty to Prevent Sexual Harassment
Since October 2024 employers have had a duty to take reasonable steps to prevent sexual harassment of their workers. From October 2026 that duty rises to taking all reasonable steps, a higher bar.
One word changes the standard. It moves the duty from doing something reasonable to showing you have done everything reasonable.
This guide explains how the upgraded duty differs from the original, what it is likely to require, and the evidence pack that supports it.
From Reasonable to All Reasonable Steps
The original preventative duty came from the Worker Protection Act and required reasonable steps. The Employment Rights Act 2025 raises it to all reasonable steps from October 2026.
The practical effect is that doing some preventative work is no longer enough. A tribunal can ask what other reasonable steps you could have taken and did not.
What All Reasonable Steps Looks Like
Regulations are expected to specify what counts as all reasonable steps, so the detail may firm up before the duty starts. Verify the position when you act on it.
The direction is clear even now. It points to a risk-based approach, where you identify where sexual harassment could occur, including from third parties, and act on each risk you find.
The Evidence Pack You Need
- A sexual harassment risk assessment that looks at your roles, settings and third-party contact.
- A clear anti-harassment policy that names sexual harassment and the reporting route.
- Training records showing staff and managers understand the policy.
- A reporting and complaints process that staff can actually use.
- A record of incidents and the action taken in response.
This duty overlaps with the new third-party liability, which we cover in our third-party harassment policy guide. For the wider employer view, see our sexual harassment October 2026 employer guide.
The Upgraded Duty at a Glance
| Point | Detail |
|---|---|
| Old standard | Reasonable steps, in force since October 2024 |
| New standard | All reasonable steps, from October 2026 |
| Detail | Regulations expected to specify what counts |
| Evidence | Risk assessment, policy, training and incident records |
How Policy Pros Can Help
We build the evidence pack the upgraded duty needs: the risk assessment, the policy and the training records that show you took all reasonable steps. Our harassment and bullying at work policies service covers the documentation.
See the October 2026 checklist for the wider wave, and our HR policies and procedures service for the supporting documents. The official position is in the GOV.UK timeline and the Acas Employment Rights Act 2025 hub.
Frequently Asked Questions
How does the all reasonable steps duty differ from the old one?
The duty in force since October 2024 required reasonable steps to prevent sexual harassment. From October 2026 it rises to all reasonable steps, which means doing some preventative work is no longer enough if there were other reasonable steps you could have taken.
When does the all reasonable steps duty start?
It is due to take effect in October 2026 under the Employment Rights Act 2025. Regulations are expected to specify what counts as all reasonable steps, so check the detail when you act on it.
What evidence shows we took all reasonable steps?
A sexual harassment risk assessment, a clear anti-harassment policy, training records, a usable reporting process, and a record of incidents and the action taken. Together these form the evidence pack behind the duty.
Does the duty cover harassment by customers and clients?
It sits alongside the new third-party harassment liability that also starts in October 2026, so your risk assessment and policy should consider sexual harassment by third parties as well as by colleagues.
Do small businesses have to meet the all reasonable steps duty?
Yes. The duty applies regardless of size. What counts as all reasonable steps is proportionate to your situation, but a small employer still needs the risk assessment, policy and training records to show it acted.
