--- title: "Third-Party Harassment Explained: New Employer Responsibilities in 2026" description: Learn how new third-party harassment rules could affect UK employers and what businesses should do to prepare for 2026 changes. image: https://circleukgroup.co.uk/hubfs/Canva%20images/Blog%20Feature%20Image-Jun-23-2026-12-09-18-1646-PM.png --- [Skip to the main content.](https://circleukgroup.co.uk/safe-circle/third-party-harassment-employer-responsibilities-2026#main-content) **CIRCLE UK GROUP** | SECURITY, SAFETY AND COMPLIANCE IN ONE SOLUTION [Download Circle Overwatch](https://circleukgroup.co.uk/circle-overwatch)  |  24/7 Helpline: **[020 3988 2444](tel:02039882444)** [![Circle UK Group](https://circleukgroup.co.uk/hs-fs/hubfs/New%20Logo%20CUKG/CUKG_Logo_color-1.png?width=800&height=356&name=CUKG_Logo_color-1.png "Circle UK Group")](https://circleukgroup.co.uk) [![Circle\_UK\_Group\_Logo](https://circleukgroup.co.uk/hs-fs/hubfs/New%20Logo%20CUKG/CUKG_Logo_color-1.png?width=1037&height=462&name=CUKG_Logo_color-1.png "Circle_UK_Group_Logo")](https://circleukgroup.co.uk) - [Industries We Protect](https://circleukgroup.co.uk/protecting-businesses-across-sectors) - [Integrated Solutions](https://circleukgroup.co.uk/complete-security-solutions) - [Meet The Team](https://circleukgroup.co.uk/meet-the-team) - [Insights](https://circleukgroup.co.uk/safe-circle) - [Case Studies](https://circleukgroup.co.uk/case-studies) - [News](https://circleukgroup.co.uk/safe-circle) - [Training & Courses](https://circleukgroup.co.uk/circle-academy) [Contact Us 24/7](https://circleukgroup.co.uk/contact) Toggle Menu Toggle Menu [Contact Us 24/7](https://circleukgroup.co.uk/contact) - [Industries We Protect](https://circleukgroup.co.uk/protecting-businesses-across-sectors) - [Integrated Solutions](https://circleukgroup.co.uk/complete-security-solutions) - [Meet The Team](https://circleukgroup.co.uk/meet-the-team) - [Insights](https://circleukgroup.co.uk/safe-circle) - [Case Studies](https://circleukgroup.co.uk/case-studies) - [News](https://circleukgroup.co.uk/safe-circle) - [Training & Courses](https://circleukgroup.co.uk/circle-academy) - [Request Risk Assessment](https://circleukgroup.co.uk/en/identify-risks-tailored-mitigation-plans-circle-uk-group) - [Security Services](https://circleukgroup.co.uk/security-services-uk) - [Circle Alarm System](https://circleukgroup.co.uk/circle-alarm-systems) - [Compliance & Training](https://circleukgroup.co.uk/circle-academy) - [Stay informed - Sign Up](https://circleukgroup.co.uk/newsletter) - [Download the Overwatch app](https://circleukgroup.co.uk/circle-overwatch) [Facebook](https://www.facebook.com/circleukgroup) [Linkedin](https://www.linkedin.com/company/circleukgroup/) [YouTube](https://www.youtube.com/channel/UC8ckYEBLGRFEXxCfSvfOimA) 4 min read # New Employer Duties: Understanding Third-Party Harassment in 2026 [![Picture of Circle Editor](https://circleukgroup.co.uk/hubfs/Circle%20Overwatch%20app-2.png) Circle Editor](https://circleukgroup.co.uk/safe-circle/author/circle-editor) : Updated on June 24, 2026 [Risk Management](https://circleukgroup.co.uk/safe-circle/tag/risk-management) [Health & Safety](https://circleukgroup.co.uk/safe-circle/tag/health-safety) [HR Compliance](https://circleukgroup.co.uk/safe-circle/tag/hr-compliance) [Workplace Compliance](https://circleukgroup.co.uk/safe-circle/tag/workplace-compliance) ![New Employer Duties: Understanding Third-Party Harassment in 2026](https://circleukgroup.co.uk/hubfs/Canva%20images/Blog%20Feature%20Image-Jun-23-2026-12-09-18-1646-PM.png) Third-Party Harassment Explained: New Employer Responsibilities in 2026 6:30 ## What UK Employers Need to Know About the Employment Rights Act 2025 Changes Most employers understand their responsibility to prevent harassment between employees. What many businesses do not realise is that under the Employment Rights Act 2025, they may also face increased responsibilities for harassment carried out by third parties, including customers, clients, contractors, suppliers and visitors. For sectors where employees regularly interact with the public, this represents one of the most significant workplace compliance changes in years. Security officers dealing with members of the public, retail staff facing abusive customers, construction workers interacting with contractors and delivery personnel, and hospitality teams serving guests may all be affected. The proposed changes aim to strengthen workplace protections and place greater emphasis on proactive employer action. In this guide, we explain what third-party harassment is, what is changing in 2026 and how employers can prepare. > This article forms part of our Employment Rights Act 2025 Employer Guide, covering the key workplace reforms affecting UK businesses between 2025 and 2027. [**Read the Complete Guide →**](https://circleukgroup.co.uk/employment-rights-act-2025-employer-guide) ## What Is Third-Party Harassment? Third-party harassment occurs when an employee experiences unwanted, inappropriate or offensive conduct from someone who is not employed by their organisation, but who they encounter in the course of their work. This could arise during routine duties, at a client site, in a public-facing role or in any situation where the employee is required to interact with individuals outside their direct employer, and the behaviour has the effect of violating their dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment. This may include: - Customers - Clients - Contractors - Agency workers - Suppliers - Members of the public - Visitors The behaviour may involve verbal abuse, discriminatory comments, sexual harassment, intimidation, offensive language or other conduct that creates a hostile, degrading or offensive working environment. Unlike traditional workplace harassment, the individual responsible is external to the organisation. ## What Is Changing Under the Employment Rights Act 2025? The Government plans to strengthen protections against third-party harassment as part of wider workplace reforms expected to take effect during 2026. Employers may be required to take reasonable steps to prevent employees from being subjected to harassment by third parties in the course of their work. This means organisations may need to demonstrate that they have considered the risks, implemented appropriate controls and responded effectively when concerns are raised. The changes sit alongside the strengthened duty on employers to take "all reasonable steps" to prevent workplace sexual harassment. ## Why Does This Matter for Employers? Many businesses already have anti-harassment policies in place, but these often focus primarily on employee behaviour. The new expectations extend beyond internal conduct and require employers to consider risks posed by external individuals. Failure to address known risks or respond appropriately to incidents could increase the likelihood of employment tribunal claims and reputational damage. For businesses with customer-facing teams, this change should not be viewed as a future issue. Preparation should begin now. ## Which Sectors Could Be Most Affected? ### Security Services Security officers frequently deal with members of the public, trespassers, customers and visitors in potentially challenging situations. Verbal abuse, aggressive behaviour and discriminatory language can be common risks in certain environments. Employers should ensure officers receive appropriate training and understand reporting procedures. ### Retail Retail workers regularly encounter customers and may experience abusive or inappropriate behaviour, particularly during disputes, refusals of service or busy trading periods. Clear reporting mechanisms and management support will become increasingly important. ### Construction Construction sites often involve multiple contractors, subcontractors, suppliers and visitors. Employers should assess how third-party interactions are managed and ensure workplace standards apply to everyone operating on site. ### Warehousing and Logistics Warehouse staff, drivers and logistics teams often interact with contractors, agency workers and delivery personnel. Employers should review workplace conduct expectations across the entire supply chain. ### Hospitality Hotels, restaurants, bars and leisure venues can expose employees to inappropriate behaviour from guests and customers. Managers should be trained to recognise concerns and intervene where necessary. [![Book Your Workforce Compliance Review](https://no-cache.hubspot.com/cta/default/20415666/be923fe8-b3b4-4e9e-9911-d386938494c3.png)](https://cta-redirect.hubspot.com/cta/redirect/20415666/be923fe8-b3b4-4e9e-9911-d386938494c3) ## What Are "Reasonable Steps"? Although guidance will continue to evolve, reasonable steps may include: - Conducting workplace risk assessments - Maintaining anti-harassment policies - Providing staff training - Implementing reporting procedures - Investigating complaints promptly - Taking action following incidents - Monitoring workplace culture - Recording incidents and outcomes The key principle is that employers should be able to demonstrate proactive efforts to prevent harassment before incidents occur. ![Circle UK 2026 Large-027](https://circleukgroup.co.uk/hs-fs/hubfs/Photo%20Session%202026/Circle%20UK%202026%20Large-027.jpeg?width=2064&height=1376&name=Circle%20UK%202026%20Large-027.jpeg) ## How Should Employers Prepare? Preparation should begin with a review of existing workplace policies and [risk management procedures](https://circleukgroup.co.uk/safe-circle/what-is-risk-management). Employers should consider where employees interact with third parties and assess the potential risks associated with those interactions. Management teams should understand their responsibilities and be confident responding to complaints. Training will play a critical role in helping supervisors and managers recognise risks, handle reports appropriately and support affected employees. [![Request Free Risk Exposure Audit  ️](https://no-cache.hubspot.com/cta/default/20415666/5f4754e2-747f-433e-9f47-5445b475397c.png)](https://cta-redirect.hubspot.com/cta/redirect/20415666/5f4754e2-747f-433e-9f47-5445b475397c) ## How Circle Academy Can Help Preparing for third-party harassment obligations requires more than a policy update. Managers, supervisors and employees need practical training to recognise inappropriate behaviour, respond effectively and create safer workplaces. Circle Academy supports employers through: - Sexual Harassment Awareness Training - Equality, Diversity and Inclusion Training - Employment Law Fundamentals - Leadership and Management Courses - Workplace Compliance Training - HR and Manager Development Programmes With more than 180 accredited courses available online and in person, we help organisations build compliant, confident and respectful workplace cultures. [![Get your team trained, certified and compliant - browse accredited courses online  ️](https://no-cache.hubspot.com/cta/default/20415666/68d5d6d5-071f-454b-9d6b-3de44a06cd28.png)](https://cta-redirect.hubspot.com/cta/redirect/20415666/68d5d6d5-071f-454b-9d6b-3de44a06cd28) ## Frequently Asked Questions Have Question? We are here to help ###### What is third-party harassment? Third-party harassment occurs when an employee experiences harassment from someone outside their organisation, such as a customer, contractor, supplier or visitor. ###### When do the new rules take effect? The Government expects the reforms relating to third-party harassment to be introduced during 2026 as part of the Employment Rights Act implementation programme. ###### Does this affect all employers? Yes. Any organisation whose employees interact with third parties should consider the potential risks and prepare accordingly. ###### Can employers be responsible for customer behaviour? The proposed changes increase expectations on employers to take reasonable steps to prevent and address harassment by third parties. ###### What should employers do now? Review policies, conduct risk assessments, train managers and ensure employees understand how to report concerns.   ## Frequently Asked Questions Have Question? We are here to help ###### What is third-party harassment? Third-party harassment occurs when an employee experiences harassment from someone outside their organisation, such as a customer, contractor, supplier or visitor. ###### When do the new rules take effect? The Government expects the reforms relating to third-party harassment to be introduced during 2026 as part of the Employment Rights Act implementation programme. ###### Does this affect all employers? Yes. Any organisation whose employees interact with third parties should consider the potential risks and prepare accordingly. ###### Can employers be responsible for customer behaviour? The proposed changes increase expectations on employers to take reasonable steps to prevent and address harassment by third parties. ###### What should employers do now? Review policies, conduct risk assessments, train managers and ensure employees understand how to report concerns. ## Sources & Further Reading This article is based on guidance and implementation plans published by the UK Government and ACAS. UK Government – Employment Rights Act Implementation Timeline [https://www.gov.uk/government/publications/implementing-the-plan-to-make-work-pay-and-employment-rights-act](https://www.gov.uk/government/publications/implementing-the-plan-to-make-work-pay-and-employment-rights-act) UK Government – Employment Rights Act Factsheets [https://www.gov.uk/government/publications/employment-rights-bill-factsheets](https://www.gov.uk/government/publications/employment-rights-bill-factsheets) ACAS – Sexual Harassment Guidance [https://www.acas.org.uk/sexual-harassment](https://www.acas.org.uk/sexual-harassment) #### Important Notice The information in this article is intended as general guidance for employers and managers. It should not be relied upon as legal advice. Employment law is subject to change, and the application of legislation may vary depending on individual circumstances. If you are unsure how the Employment Rights Act 2025 may affect your organisation, we recommend seeking appropriate legal or professional advice.   - [Tweet](https://twitter.com/share)   ### Explore More [![Understand the changes, assess your risks and prepare your organisation for the Employment Rights Act 2025.](https://no-cache.hubspot.com/cta/default/20415666/00ca0807-6575-4d48-91db-0b8eda3bb99f.png)](https://cta-redirect.hubspot.com/cta/redirect/20415666/00ca0807-6575-4d48-91db-0b8eda3bb99f) ---   ### Stay Ahead of Security, Compliance & Risk Join over **5,000 professionals** receiving practical insights, industry updates and expert guidance on security, compliance, health & safety and business continuity. ### Posts by Tag - [Security (52)](https://circleukgroup.co.uk/safe-circle/tag/security) - [News (31)](https://circleukgroup.co.uk/safe-circle/tag/news) - [Risk Management (20)](https://circleukgroup.co.uk/safe-circle/tag/risk-management) - [Health & Safety (13)](https://circleukgroup.co.uk/safe-circle/tag/health-safety) - [Risk Assessment (12)](https://circleukgroup.co.uk/safe-circle/tag/risk-assessment) - [Workplace Compliance (12)](https://circleukgroup.co.uk/safe-circle/tag/workplace-compliance) - [Circle Academy (11)](https://circleukgroup.co.uk/safe-circle/tag/circle-academy) - [HR Compliance (10)](https://circleukgroup.co.uk/safe-circle/tag/hr-compliance) - [Warehouse Security (7)](https://circleukgroup.co.uk/safe-circle/tag/warehouse-security) - [Security in Construction (6)](https://circleukgroup.co.uk/safe-circle/tag/security-in-construction) - [CCTV (5)](https://circleukgroup.co.uk/safe-circle/tag/cctv) - [Circle Alarms (5)](https://circleukgroup.co.uk/safe-circle/tag/circle-alarms) - [Waking Watch Service (4)](https://circleukgroup.co.uk/safe-circle/tag/waking-watch-service) - [Manned Guarding (3)](https://circleukgroup.co.uk/safe-circle/tag/manned-guarding) - [Circle Overwatch (2)](https://circleukgroup.co.uk/safe-circle/tag/circle-overwatch) - [Fire Safety (2)](https://circleukgroup.co.uk/safe-circle/tag/fire-safety) - [Demolition Site Security (1)](https://circleukgroup.co.uk/safe-circle/tag/demolition-site-security) - [Facility Management (1)](https://circleukgroup.co.uk/safe-circle/tag/facility-management) See All [![New Six-Month Employment Tribunal Deadline: What Employers Must Know](https://circleukgroup.co.uk/hubfs/Canva%20images/Blog%20Feature%20Image-2.jpg)](https://circleukgroup.co.uk/safe-circle/employment-tribunal-time-limits-six-month-deadline) 1 min read #### [New Six-Month Employment Tribunal Deadline: What Employers Must Know](https://circleukgroup.co.uk/safe-circle/employment-tribunal-time-limits-six-month-deadline) [![Picture of Circle Editor](https://circleukgroup.co.uk/hs-fs/hubfs/Circle%20Overwatch%20app-2.png?width=30&name=Circle%20Overwatch%20app-2.png) Circle Editor](https://circleukgroup.co.uk/safe-circle/author/circle-editor) : Jun 23, 2026, 2:12:12 PM What UK Employers Need to Know About the Employment Rights Act 2025 Changes Many employers are familiar with the current employment tribunal time... 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