Employment Rights Bill implementation roadmap: Key dates for HR

By Stephen Simpson
Brightmine Acting Content Manager – Employment Law and Compliance

With the completion of the lengthy House of Lords committee stage on 24 June 2025 and the publication of the Government’s implementation roadmap on 1 July 2025, the Employment Rights Bill is becoming an ever more pressing reality for HR departments. What happens next and what is the likely legislative timetable?

The committee stage in the House of Lords, which involved a line-by-line examination of the individual clauses of the Employment Rights Bill, finished on 24 June 2025.

Members of the House of Lords worked through the Bill’s clauses in order, considering amendments or proposals for brand-new clauses.

The House of Lords allocated 11 days for the committee stage, which took place on various non-consecutive dates from 29 April until 24 June. This is an unusually long time for this stage, reflecting the size, scope and complexity of the Employment Rights Bill.

What happens next?

The Employment Rights Bill now moves on to the House of Lords report stage, which is the ninth of 12 stages. The report stage is the penultimate stage in the House of Lords before the Bill returns to the House of Commons.

The House of Lords report stage starts on 14 July. It is expected to be shorter than the committee stage. Generally, this stage, during which detailed examination of the Bill continues, needs half the number of days taken for the committee stage, which means that it is likely to need five or six days.

This is followed by the third reading in the House of Lords – the tenth stage overall – before the Employment Rights Bill returns to the House of Commons for:

• Final considerations of amendments; and
• Royal Assent, at which point the Bill becomes the Employment Rights Act 2025.

What is the likely legislative timetable?

What does this all mean for HR professionals who need to prepare for the looming employment law changes contained in the Employment Rights Bill?

Parliament goes into recess in late July 2025 and does not return until early September. In addition, September is the party conference season. This will undoubtedly have an impact on how long Parliament takes to finalise the Employment Rights Bill.

Even if the House of Lords finishes with the Employment Rights Bill in July, the Bill still has to return to the House of Commons for the final two stages. This is likely to be after the summer recess.

Therefore, it looks increasingly likely that the Bill will not receive Royal Assent and become the Employment Rights Act 2025 before late September or early October 2025.

Roadmap for the implementation of individual measures

It is estimated that the Employment Rights Bill will introduce at least 28 major employment law changes. Even after the Bill receives Royal Assent, many of these measures will need public consultation followed by secondary legislation to flesh out the details. Realistically, this means that the changes will have to be introduced over a number of years before the next general election, which must take place no later than August 2029.

On 1 July 2025 the Government published a roadmap timetable, setting out its approach to consultation on and final implementation of the individual measures in the Bill. It announced that policies would take effect in phases, with common commencement dates of 6 April and 1 October.

Measures that will come into force at Royal Assent or soon after include:

• Repeal of the Strikes (Minimum Service Levels) Act 2023, and
• Changes to the rules on industrial action ballots.

Measures that will take effect in April 2026 include:

• Changes to entitlement to statutory paternity leave and ordinary parental leave to make them day-one employment rights;
• The simplification of the trade union recognition process;
• The establishment of a single, consolidated enforcement body, the Fair Work Agency (FWA), to monitor and enforce core employment rights; and
• The removal of both the requirement to earn at or above the lower earnings limit and the three-day waiting period to qualify for statutory sick pay.

Measures that will take effect in October 2026 include:

• Making “fire and rehire” dismissals automatically unfair in most circumstances; and
• The reintroduction of employer liability for third-party harassment and addition of the word “all” before “reasonable steps” in respect of the positive duty for employers to prevent sexual harassment.

Measures that will take effect in 2027 include:

• The introduction of a requirement for employers with 250+ employees to publish a gender pay gap and menopause action plan alongside their gender pay gap figures (introduced on a voluntary basis in April 2026);
• The extension of unfair dismissal protection to all employees from day one in a job and the accompanying introduction of a statutory probationary period;
• Procedural reforms to the right to request flexible working;
• Provision for zero and low hours workers to be given the right to a guaranteed number of hours and reasonable notice of a cancellation of, or change to, a shift;
• Increased protection from dismissal for pregnant employees and those on or returning from family-related leave;
• The widening of statutory bereavement leave beyond the death of a child to provide employees with time off to grieve for the loss of loved ones; and
• Reforms to the triggers for collective redundancy consultation obligations.

Employment Rights Bill: How we will help HR prepare

1. Horizon scanning for employment law changes

• We are constantly monitoring what is happening with upcoming legal changes and translating what is happening into practical steps that you can take to prepare.
• We are keeping track of multiple amendments to the Employment Rights Bill made during the parliamentary process and potentially dozens of pieces of secondary legislation that will be needed.
• After the Employment Rights Bill provisions have been introduced, they will have an impact on case law rulings for decades to come. We also monitor, and report on, developments from court and tribunal judgments.

2. HR policy updates

• Our HR templates are consistently our most popular resources used by HR professionals, including our suite of 150 model policies and over 500 accompanying model HR letters and forms.
• As the Employment Rights Bill progresses and we get more details of how the changes will work, we will set out clearly any changes you need to make to your policies and other documentation, and indeed any new policies that you will need to introduce from scratch.
• For example, you are going to have to review and update your organisation’s policies and processes on:
  • onboarding
  • probation
  • flexible working requests
  • bereavement leave
  • paternity leave
  • ordinary parental leave
  • sickness absence
  • bullying and harassment
  • varying terms and conditions of employment
  • redundancy

3. Implementation of HR policies and procedures

• We are always acutely aware that your organisation can have a perfectly worded and up-to-date policy, but that it is worthless if it is not implemented properly. That is why we will have additional practical guidance on how your organisation can actually put any changes to employment law into practice.
• In particular, we recognise the key role that line managers play on the ground, which is why we accompany our new and updated HR policies with up-to-date line manager briefings that you can use to train managers.
• We also provide detailed “how to” guides to help HR professionals with implementation, as well as leading practice guides, which focus more on HR strategy.

4. Day-to-day queries and firefighting

Once the dust has settled on the changes, our reference materials are ideal for HR professionals who need to check on something from a legal standpoint.
For example, it could be how to deal with a specific situation in the new post-Employment Rights Bill world, or it could be checking what someone’s rights are under the new legal landscape.
We have several hundred detailed employment law guides and 100s of FAQs to answer all your legal questions.

5. Research/surveys of employers

• We recognise the increasing importance that data plays in HR’s decision-making. That is why we are running a number of surveys relevant to the Employment Rights Bill, to help your organisation to:
  • Chart progress towards implementation of the Bill;
  • Compare what your organisation is doing to prepare against what other employers are doing; and
  • Plan which changes to prioritise and budget for.
• For example, we have already surveyed hundreds of employers on which proposed changes they think will require the most resources to implement.
• More surveys of employers are to follow, including research on how employers currently operate probationary periods and what they are doing to prepare for the probationary period changes contained in the Employment Rights Bill.