21.10.2026

Sexual harassment training for UK managers has gone backwards in the run-up to the 30 October deadline

With upcoming changes to the Employment Rights Act, UK employers have gone backwards on manager training in the final months before the sexual harassment duty tightens on 30 October, according to new polling of 540 HR, L&D and compliance professionals by compliance training provider, VinciWorks.

The share of employers running dedicated manager training on sexual harassment has fallen from 30 per cent in July to 22 per cent in October. More than three-quarters (78 per cent) now have none, meaning managers will take the first disclosure of the new regime with no training of their own in how to handle it.

The timing matters because managers control what the law tests. An employee discloses, and within the hour a manager decides whether someone is at immediate risk, what to preserve and who to tell. Those decisions are among the first things an employment tribunal examines.

Nick Henderson-Mayo, Head of Compliance at VinciWorks, said: “Managers who have had no training might mistakenly promise anonymity nobody can deliver, promise action nobody can follow through on, or start working out in that first conversation who is telling the truth. Those are the kind of mistakes that can doom an employer at tribunal, but they are avoidable with strong policies and good training.”

More training, rated no better

The quantity of basic harassment training is not as much of an issue now. The proportion of employers doing no sexual harassment training at all has almost halved since July, from 14 per cent to eight and a half per cent. However, six in 10 (60 per cent) rate their sexual harassment training as no better than “OK, could be better”, against 61 per cent in July.

Small businesses carry the sharpest exposure. One in eight (13 per cent) have no sexual harassment training at all, against four per cent of larger employers. Among businesses with 11 to 50 staff, that rises to almost a quarter (23 per cent).

Ruth Mittelmann Cohen, Head of Legal Compliance at VinciWorks, said, “A tribunal asks what steps were available to you and what you did about them. Having no training is very hard to defend, because almost no employer can argue training was beyond them. Tribunals have also found that training delivered years ago and never refreshed is essentially ineffective."

Preparedness claimed without evidence

Fewer than one in 20 respondents (4 per cent) say they are completely prepared for 30 October. Almost two-thirds (64 per cent) say they are somewhat prepared, and almost a third (31 per cent) are unsure or not prepared.

Of the respondents who described themselves as prepared, three-quarters (74 per cent) have no dedicated manager training, and over half (56 per cent) rated their training as no better than “OK” and 4 per cent run none at all.

Among small businesses with one to 250 staff, a third (34 per cent) give managers the same training as everyone else, against a fifth (20 per cent) of employers with more than 250 staff. Dedicated manager training runs at 17 per cent in small businesses and 28 per cent in larger ones.

Henderson-Mayo added: "Most employers have the basics, a policy and some training. But the new standard under the Employment Rights Act asks what risks you found in your own organisation, what you decided to do about each one and what evidence you have that it works.”

What employers should do before 30 October

Carry out a documented sexual harassment risk assessment covering client entertainment, business travel, work social events, remote working and digital communications
Train managers specifically on receiving a disclosure and on avoiding anything that could look like retaliation
Provide more than one reporting route, so nobody has to report to the person closest to the problem
Record the measures considered and the reasons behind each decision, including anything ruled out on cost
Set a review date, and review whenever a complaint is made

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