The Roadmap outlines three phases of consultation during Summer/Autumn 2025, Autumn 2025, and Winter/Early 2026.  The Bill will take effect in stages during 2025 and 2027, using the common commencement dates of 6 April and 1 October to pass the majority of regulations required.  

Click here to view our traffic light tracker which has been updated to reflect the implementation dates within the Roadmap. 

1.    The Government will consult in Summer/Autumn 2025 on: (i) Reinstating the School Support Negotiating Body, (ii) a Fair Pay Agreement for the Adult Social Care sector, and (iii) ‘Day 1’ right to unfair dismissal (with probationary periods for new hires). 

2.    During Autumn 2025, consultations will follow on: (i) Measures to end ‘exploitative’ zero hours contracts; (ii) Banning fire and re-hire; (iii) Regulating umbrella companies; (iv) Rights for pregnant workers; (v) Bereavement leave; and (vi) Trade union measures including electronic and workplace balloting, simplifying trade union recognition processes, the new duty to inform workers of their right to join a trade union and strengthening trade unions rights of access.

3.    Winter / Early 2026 will feature consultations on: (i) Alternative threshold for collective redundancy consultation; (ii) Flexible working; (iii) Tipping laws; and (iv) Trade union measures including protection against detriments for taking industrial action and blacklisting.

1.    Measures due to take effect on or shortly after the Bill receives Royal Assent in Autumn 2025 are: (i) Repealing the Strikes (Minimum Services Levels) Act 2023 and the majority of the Trade Union Act 2016; (ii) Removing the 10-year ballot requirement for trade union political funds; (iii) Simplifying industrial action notices and industrial action ballot notices; and (iv) Protecting against dismissal for taking industrial action.

2.    Measures taking effect in April 2026 include: (i) Doubling the maximum period of the protective award in collective redundancy situations from 90 to 180 days; (ii) Whistleblowing protection for those reporting sexual harassment; (iii) Simplifying trade union recognition processes; (iv) Electronic and workplace balloting; (v) ‘Day 1’ paternity leave and unpaid parental leave; (vi) ‘Day 1’ right to SSP (no 3-day waiting period); (vii) Removing the lower earnings limit; and (viii) Establishing the Fair Work Agency.

3.    In October 2026 the following will come into force: (i) Ending fire and re-hire in relation to restricted variations (including reductions in pay or holiday and changes to hours), save for where employer has no other option in order to remain viable; (ii) Extending the time limit for bringing an employment tribunal claim from 3 to 6 months; (iii) Reintroducing a ‘two-tier code’ for public sector outsourcing; (iv) Tightening tipping law; (v) Strengthening trade unions’ right of access to the workplace; (vi) Introducing a new duty to inform workers of their right to join a trade union; (vii) New rights and protections for trade union representatives; and (viii) Extending protections against detriments for taking industrial action.

4.    However, some of the most significant measures have been held over for at least another eighteen months.  Measures not now taking effect until 2027 include: (i) ‘Day 1’ rights to unfair dismissal; (ii) Ending ‘exploitative’ zero hours contracts (with corresponding measures for agency workers); (iii) Alternative threshold for triggering collective redundancy consultation; (iv) Mandating gender pay gap and menopause support action plans for employers with 250+ employees; (v) Making it unlawful to dismiss a woman during pregnancy and up to 6 months after her return to work; (vi) Regulating umbrella companies; (vii) Flexible working; (viii) Bereavement leave including pregnancy loss before 24 weeks; (ix) Blacklisting; (x) New industrial relations framework; and (xi) Enabling regulations to specify steps that are ‘reasonable’ to determine whether an employer has taken all reasonable steps to prevent sexual harassment.

On 7 and 8 July, a number of amendments were tabled to the Bill at the Report Stage in the House of Lords.  Whilst some of these are opposition amendments and not expected to pass, the Government amendments outlined below are highly likely to be approved.

The new rights for zero hours workers are one of the most complex areas of the Bill.  Whilst the Bill sets out the overall structure and framework of the new rights, many of the details are yet to be specified in future regulations.  In March 2025, the Government confirmed that qualifying agency workers on a zero or 'low hours' contract will be included in the zero hours contracts measures. 

The Government’s July amendments confirm that end-hirers will be required to make a guaranteed hours offer to an agency worker that protects the agency worker’s pay and conditions, so that these are no less favourable than they had previously been working under (or those of comparable workers who do broadly similar work).  The amendments also clarify that when an agency worker accepts a guaranteed hours offer from an end-hirer, they will become a worker (rather than an employee).

Update:  On 14 July, as well as approving the Government amendments detailed above, the House of Lords also voted to approve opposition amendments to:

• Change the provisions in the Bill from a requirement for an employer to offer guaranteed hours to a right to request guaranteed hours by an employee; and
• Define “short notice” as at least 48 hours before a shift is due to start, and clarify that if this notice is given, the employer will not be required to make a short notice cancellation payment.

However, as the Bill will require approval from the House of Commons before it receive Royal Assent, these opposition amendments can still be challenged by the House of Commons, and, if not agreed, will lead to the Bill being amended again and returned to the House of Lords for approval in September. 

The Government had previously committed to end ‘fire and rehire’ save in extremely limited circumstances where an employer has no alternative to remain financially viable.  However, there were concerns that the new provisions could apply to relocations, which would require employers to budget for significant automatic unfair dismissal costs if not all employees agreed to a change in their place of work.  To address these concerns, the Government’s July amendments relax the ban on ‘fire and re-hire’ in the following ways:

1.    The ban will only apply to ‘restricted variations’, including reductions in an employee’s pay or holidays, changes to hours, pension and other changes defined in regulations (which may include benefits), but not location or duties.  The ban will also include any dismissals relating to an attempt to impose a new flexibility clause covering any of these changes.

2.    Where an employee is dismissed for failing to agree to a variation of their contract that is not a ‘restricted variation’, the dismissal will no longer be automatically unfair and the matters that must be considered in determining whether the dismissal is fair or unfair are set out in a new provision, which requires tribunals to take account of the reason for the variation, any individual or collective consultation and anything the employee was offered in return for the change. 

Separately, another amendment provides that dismissals will be automatically unfair if the reason for dismissal is to replace an employee with someone who is not employed (e.g. self-employed independent contractors, agency workers or other individuals not employed by the employer), if any such replacement is going to do substantially the same work. This is provided that the ‘financial difficulty’ exemption does not apply and the employer could not reasonably have avoided the need to replace the employee.

Originally, the Bill proposed a statutory right to at least one week of unpaid bereavement leave for those in a qualifying relationship to the deceased, but did not reference pregnancy losses before 24 weeks. Now, the Government has extended the new statutory bereavement leave to employees who experience pregnancy loss before 24 weeks. This will entitle mothers and their partners to at least one week of leave, although the exact amount of leave is still to be consulted on. The amendments clarify that the definition of “pregnancy loss” will cover the ending of a pregnancy before 24 weeks in any way other than a live birth, including abortions and implantation failure following IVF treatment.

Perhaps the most significant development is the Government’s announcement that it will amend the Bill to make void any provision in an agreement between an employer and a worker which tries to prevent the worker making an allegation or disclosure about work-related harassment or discrimination (see our earlier report here).  

If passed, these rules will mean that any confidentiality clauses in settlement agreements or other agreements that seek to prevent a worker speaking about an allegation of harassment or discrimination will be null and void.  This is likely to have major implications for employers who will need to review and amend confidentiality wording in contracts, policies and settlement agreements and who may be less willing to settle as many harassment and discrimination claims in the future if they can no longer rely on confidentiality.  However, it is not yet clear when it could come into effect as this provision was not included in the Roadmap.