No business thinks their employees will face sexual harassment and no business plans for the moment someone needs to report it. It’s the kind of thing that only feels relevant once it’s already happened, but by then it’s too late.

From 30 October 2026, employers face a stronger legal duty to prevent sexual harassment before it happens. That’s a significant shift for organisations, and paired with the changes introduced in April protecting sexual harassment whistleblowing protections, it’s something employers can’t afford to ignore. It’s not something they should want to ignore either.

October 2026 Update: Take ‘all reasonable steps”

From 30 October 2026, the existing duty on employers to prevent sexual harassment gets substantially stronger. Businesses will need to show they’ve taken “all reasonable steps” to prevent it happening, with regulators empowered to set out what counts as reasonable.

It sits within the wider harassment protection framework strengthened by the Employment Rights Act 2025, and shifts the standard from having a policy that exists on paper to being able to demonstrate active, ongoing prevention.

This is a prevention measure, designed to protect employees from sexual harassment before it happens. But how do you protect staff from something you don’t know is happening?

Who does this apply to?

This isn’t a duty that only applies to large employers. It applies to every organisation with staff, regardless of size or sector. There’s no exemption for small businesses and no headcount threshold to clear.

If you employ people, the duty applies to you from 30 October 2026, whether that’s a five-person office, a hotel, a sports club, or a national organisation.

What counts as a reasonable step?

Regulators haven’t set out an exhaustive list, but a reporting process people actually use is likely to sit close to the centre of it.

Training and policies matter, but they can only address what actually gets flagged. A reasonable step that holds up needs a way for staff to raise something before it escalates, and evidence that it’s being used and acted on.

Without that, “all reasonable steps” risks becoming another box left ticked on paper, a policy that exists, with no way of knowing whether it’s working.

It’s not just about staff on staff

The prevention duty doesn’t stop at protecting employees from each other. It also covers harassment from third parties, customers, clients, guests, contractors or members of the public. For businesses in hospitality, events, sport and any customer-facing sector, this matters just as much as internal HR policy.

A guest making an inappropriate comment to a member of staff. A parent behaving inappropriately toward a coach at a sports club. A client crossing a line with a contractor. All of these fall within the scope of the duty, and all of them raise the same question as before: how do you take reasonable steps to prevent something you have no way of hearing about?

April 2026: whistleblowing protection for harassment disclosures

From 6 April 2026, sexual harassment complaints became explicitly protected as whistleblowing disclosures. This is a whistleblowing law change, and it means that if someone does raise a concern, they now have clear legal protection from dismissal or unfair treatment as a direct result of speaking up.

But that protection only helps if people feel safe enough to use it. Sexual harassment is something people hesitate to report by name, often because they fear how it will affect them at work, whether they’ll be believed, or what happens to their relationship with colleagues afterwards. For a lot of people, feeling safe enough to come forward depends on being able to do it anonymously.

This is also why prevention and protection need to work together. Whistleblowing protection matters, but it exists for when something has already gone wrong. Business ahead of the game are the ones catching things early, before they reach that point. If people have a way to report something inappropriate the moment they notice it, there’s a far smaller chance it ever needs to become a whistleblowing case at all.

What happens if you don’t comply

The consequences of getting this wrong are real. Where a sexual harassment claim succeeds and a tribunal finds the employer failed to take reasonable steps to prevent it, compensation can be increased by up to 25%. That uplift applies on top of any award for financial loss, injury to feelings or aggravated damages, and compensation in these cases is uncapped.

Beyond individual claims, the Equality and Human Rights Commission has the power to investigate organisations and take enforcement action over the preventative duty, even without an individual bringing a case first.

Where iTrust fits in

None of this starts with expecting the worst. It starts with giving people somewhere to say something small, before it becomes something serious.

iTrust gives people an anonymous, instant way to report concerns, including inappropriate behaviour, without needing an app or a login. For the October duty, it’s a straightforward way to show a reporting process is in place and actually being used to investigate and take action. For April’s changes, it works on both sides, catching concerns early reduces how often they need to become a formal whistleblowing disclosure at all, and for the people who do need that protection, anonymity is what makes them feel safe enough to come forward in the first place.

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