Spring into compliance: April 2026 brings new obligations for UK employers

What:

From 1 April 2026 the hourly rates of all the national minimum wage (NMW) bands will increase, with wages for workers aged 21 and over (the National Living Wage) rising to £12.71 / hour, up from £12.21 per hour.  Younger workers will also see their rates increase to £10.85 / hour for 18–20-year-olds and £8.00 / hour for 16-17-year olds and apprentices.  

Despite pledging in their 2024 manifesto to narrow and remove the age-related pay bands by the next election, the Government is reportedly seeking to review or delay plans to further increase the younger persons minimum wage amid fears that the higher cost of employing young people could be contributing to an increase in youth unemployment rates (the ONS reporting almost 1 in 6 young people out of work between October and December 2025).  We’re likely to gain more clarity when the Government writes to the Low Pay Commission later in 2026.  

Action:

Update your payroll to reflect the new NMW rates.  Consider the most high-risk areas for compliance (e.g. salary deductions for uniform/equipment, failing to increase pay after worker birthdays, incorrect apprenticeship rates or not paying for all hours worked e.g. for training or security checks) especially as the Fair Work Agency will soon have new powers to enforce non-payment or incorrect payment, see below.  

What: 

1. Reporting (4 April 2026): Employers with 250 or more employees on the snapshot date of 5 April (for private, voluntary and all other public authority employers) must report their gender pay gap (GPG) data by 4 April 2026.  
2. Equality Action Plans (6 April 2026): Currently, whilst employers are encouraged to publish action plans outlining their plans to reduce their GPG, only around 50% of employers do so.  However, the ERA 2025 will require employers to publish equality action plans detailing the steps being taken to close the GPG and support for women experiencing menopause. Equality action plans are voluntary from April 2026, becoming mandatory in 2027.  On 6 March 2026, the Government published new guidance for employers including a detailed list of 18 recommended, evidence informed actions.  Further guidance is expected in April 2026.  

Action:

Report your GPG by 4 April 2026 (if relevant).  Review the government guidance on equality action plans and consider the 18 recommended actions.  Consider how many of these your business is already doing and any other actions your business might seek to take.  Whilst there’s no requirement to publish an equality action plan during the next reporting year (2026-27), employers are encouraged to treat this as a practice run before the requirement becomes mandatory in 2027. Note that, in time, the Act will also require employers to name who they receive outsourced work from (to account for any gaps in those organisations), although there’s no timescale for this change yet (see the Government Factsheet here). 

What:

From 5 April 2026, Statutory Maternity Pay, Statutory Paternity Pay, Statutory Adoption Pay, Statutory Shared Parental Pay, Statutory Parental Bereavement Pay and Statutory Neonatal Care Pay will rise to £194.32 per week (up from £187.18).  A new right to Statutory Parental Bereavement Pay will be introduced, also paid at the rate of £194.32 per week.

The maximum weekly pay for the purposes of calculating statutory redundancy payments (payable to those with two years’ service or more) from 5 April 2026 has not yet been confirmed, but is expected to rise from £719 to £751.  

What should you do now? Update your payroll (and anywhere else where the current rates are noted) to reflect the new statutory rates. HMRC guidance details all confirmed statutory rates and thresholds for 2026-27.

What: 

From 6 April 2026:

1. Statutory sick pay (SSP) will increase to £123.25 per week (up from £118.75); and
2. SSP will become a day-one right, removing both the three-day waiting period and the lower earnings limit.  Under the new system, employees on low wages who are unable to work due to sickness will either receive 80% of their normal weekly earnings or the current rate of SSP, whichever is lower.

Action:

Update your payroll to reflect the new statutory rate.  Consider the impact of the new ‘day 1’ right to SSP on all ‘employed earners’ in your business (as defined by the SSP rules, which will include some workers) and ensure compliance, as the Fair Work Agency will have new powers to enforce non-payment or incorrect payment of any statutory payment including SSP, see below.

What:  

1. Paternity leave (but not statutory paternity pay) will become a day-one right for eligible employees, removing the 26 weeks’ qualifying period.  The new right will apply to babies born on or after 6 April 2026, or whose expected week of birth is on or after that date, but who are born early.  Restrictions will be lifted to allow parents to take paternity leave and/or receive statutory paternity pay after a period of shared parental leave.
2. Unpaid parental leave will also become a day-one right for eligible employees, no longer requiring one year’s service.
3. The Bereaved Partner’s Paternity Leave Regulations 2026  (currently in draft form) will introduce a new statutory entitlement for an employee to be absent from work to care for a child during the first year their birth, placement for adoption, or entry into Great Britain in connection with / for the purposes of an overseas adoption, in the event that the child’s primary carer dies.

Action:

Update policies and consider whether any enhanced paternity leave provisions need to be amended.  Review and update bereavement and compassionate leave policies and consider whether you will offer paid leave.  

What:

The maximum period of the protective award that a Employment Tribunal can award against the employer for breaching their collective redundancy obligations will double from up to 90 days’ pay to up to 180 days’ pay, per affected employee.  

Action:

This is a significant increase in the cost of non-compliance for employers, which will need to be factored into any restructuring plans.  

NB: The Government is also currently consulting on where to set the level of the new organisation-wide threshold for triggering collective redundancy obligations, with options including either a single fixed organisation-wide threshold or different tiered thresholds depending on the size of the employer.  The consultation closes on 21 May 2026, with the new, alternative, threshold set to come into force in 2027.

What:

Sexual harassment will be added to the list of relevant failures that can form the subject-matter of a “whistleblowing disclosure” i.e. a protected disclosure.  This means that workers will no longer need to identify an existing legal obligation, criminal offence or breach of health and safety to make a qualifying disclosure about sexual harassment, provided they have complied with the other requirements in the legislation, such as holding a reasonable belief that the issue is in the public interest.

Action:

Update whistleblowing policies and train managers and staff to ensure compliance with this new whistleblowing protection coming into force in April 2026.  

What:

Unions will no longer need 40% workforce support in a recognition ballot, but just a simple majority of those voting.  Unions applying for recognition will only need to show 10% membership of the bargaining unit, instead of proving they are likely to win a ballot, with ministers able to adjust the membership requirement to as low as 2% through regulations.  

Simplifying the process for trade unions to apply for recognition paves the way for further reforms in October 2026, which will give any trade union with a certificate of independence the right to apply for access to any workplace, including businesses with no recognised trade union.  

Action:

Review employee engagement strategies, consider establishing employee forums if none exist and engage early with employee representatives to discuss the changes and to strengthen relationships and communication pathways.  

What:

New rules introduced in the Finance Bill 2025-2026 will make employment agencies or end clients joint and severally liable for any amount required to be accounted for under the pay-as-you-earn (PAYE) provisions where an umbrella company forms part of a labour supply chain.  

Joint and several liability will allow HMRC to pursue an employment agency in the first instance for any payroll taxes that a non-compliant umbrella company fails to remit to HMRC on their behalf.  The end client will be liable to HMRC if contracting directly with an umbrella company.  The change is expected to protect around £2.8 billion from being lost to umbrella company non-compliance.  

Action:

Review your supply chains to consider whether the current arrangements remain appropriate.  Consider whether costs will increase and how best to minimise these.

What:

The Fair Work Agency (FWA) will be established to consolidate enforcement of workers' rights, including the national minimum wage, agency worker protections, and gangmaster licencing.  Over time, it will also take on enforcement of additional rights, such as holiday pay and statutory sick pay. The FWA will operate with an expanded civil penalty regime, the power to inspect workplaces and to require employers to produce relevant documents/evidence and the ability to bring tribunal cases on the behalf of workers.  See our article for more information here.  

Action:

Employers should conduct a thorough compliance check ahead of the FWA becoming operational.  It is anticipated that areas of particular focus for the FWA will include non-payment or underpayment of holiday pay and the national minimum wage.  Review contracts, policies and procedures to ensure compliance with holiday pay requirements (especially part-year workers and casual workers), remind workers to use their holiday entitlement and ensure staff are given enough opportunity to take it. Ensure systems for checking NMW compliance are fit for purpose.