UK employment law places clear duties on employers to train their managers.
Those manager training duties have grown significantly since 2023, with new legislation sharpening the consequences of getting it wrong.
This guide sets out the legal framework, identifies the obligations that matter most to HR and compliance teams, and explains what defensible training practice looks like in 2026.
Why the legal landscape has shifted
Three pieces of legislation now sit at the centre of manager training obligations in the UK.
Worker Protection Act 2023 – in force since October 2024, this Act introduced a positive duty on employers to take reasonable steps to prevent sexual harassment. Unlike the reactive harassment law that preceded it, this is a proactive obligation. Employment tribunals can uplift compensation by up to 25% where an employer is found to have breached the preventative duty. The Equality and Human Rights Commission has published enforcement guidance making clear that staff training – particularly manager training – is a core component of what “reasonable steps” looks like in practice.
Employment Rights Act 2025 – receiving Royal Assent in December 2025, with its first wave of provisions taking effect on 6 April 2026. Among the significant changes, sexual harassment is now explicitly listed as a category of protected disclosure under whistleblowing law. This means employees raising concerns about harassment now benefit from whistleblower protections, and managers who handle such disclosures poorly face both employment and regulatory exposure.
Economic Crime and Corporate Transparency Act 2023 (ECCTA) – the failure to prevent fraud offence came into force on 1 September 2025. Organisations in scope – broadly, large companies and their associated persons – must have adequate fraud prevention procedures in place or face criminal liability. Training managers on how fraud is detected, reported and escalated is a direct component of those procedures. The Serious Fraud Office has confirmed it is actively enforcing.
The core legal obligations for manager training
Worker Protection Act: reasonable steps
The positive duty under the Worker Protection Act requires employers to take “reasonable steps” – a standard that will be assessed by tribunals against the size and resources of the organisation, the nature of the work, and the risks involved. The EHRC’s guidance identifies training as one of the primary steps employers should take, alongside policy reviews and risk assessments. Critically, training must reach managers, not just frontline staff. Managers set the tone, handle disclosures and are most likely to witness or be implicated in harassment incidents.
Public Interest Disclosure Act 1998 and ERA 2025
The Public Interest Disclosure Act 1998 (PIDA) established the framework for protected disclosures in the UK – what whistleblowing is, what protections apply and what detriments are prohibited. Managers trained only on company policy rather than the underlying law risk misclassifying disclosures, failing to protect reporters, or taking retaliatory action they do not recognise as retaliation. ERA 2025 expands the category of qualifying disclosures to include sexual harassment concerns, adding a new layer of complexity for managers who now sit at the intersection of harassment law and whistleblowing protection.
Equality Act 2010
Employers carry vicarious liability for acts of discrimination and harassment committed by their employees unless they can demonstrate they took all reasonable steps to prevent those acts. Training is the primary mechanism for meeting that defence. Untrained managers who commit or overlook discriminatory conduct expose their organisation to tribunal claims with no statutory cap on compensation in discrimination cases.
ACAS codes of practice
ACAS codes on discipline and grievance are not legally binding, but tribunals take them into account when assessing whether an employer acted reasonably. Managers who have not been trained on the ACAS disciplinary and grievance process – including how to handle complaints fairly, conduct investigations and document outcomes – are more likely to make procedural errors that increase compensation awards even where a dismissal or sanction was substantively justified.
The financial consequences of non-compliance
The cost of failing to train managers is not abstract. Consider the headline figures:
- Employment tribunal compensation in discrimination cases is uncapped and can run to six figures in complex cases involving harassment, victimisation and constructive dismissal
- The Worker Protection Act allows a 25% uplift on harassment compensation where the preventative duty is breached – directly linked to the adequacy of training
- The ECCTA failure to prevent fraud offence carries unlimited fines for organisations convicted under it
- ACFE research from 2024 found that fraud losses in organisations without anonymous reporting channels were 50% higher than in those with them – and 52% of fraud tips came from employees, with managers’ ability to receive and handle reports directly affecting detection rates
Beyond tribunal risk, the reputational and cultural costs of management failures around harassment, whistleblowing and misconduct are significant. Freshfields’ 2023 whistleblowing survey found that 43% of employees had been involved in a whistleblowing situation – up from 32% in 2020. The pressure on managers to handle disclosures correctly has never been higher.
What legally defensible manager training looks like
Organisations that can demonstrate defensible training practice share several characteristics.
Training is targeted by role
All-staff awareness training and manager training serve different purposes. Managers need to understand the legal framework and their specific obligations – not just what the company policy says. This means training that covers PIDA, the Worker Protection Act, ACAS codes and, where relevant, the failure to prevent fraud framework.
Training is documented
Tribunals and regulators will ask for evidence. Organisations should be able to show who was trained, what was covered, when training took place and how it has been refreshed. SCORM-compliant eLearning that integrates with an LMS makes this straightforward for digital learning. Facilitated courses should generate attendance records and completion certificates.
Training is current
The pace of legislative change since 2023 means that training produced before the Worker Protection Act, ERA 2025 or ECCTA came into force may no longer reflect the legal position. Outdated training can be actively harmful – it creates a false sense of compliance. Annual review of training content is now a baseline expectation.
CPD accreditation adds defensibility
CPD-certified training carries an independent quality mark. For regulated organisations – financial services, legal, healthcare – demonstrating that manager training meets a recognised professional standard is increasingly important when dealing with regulators. CPD accreditation by an independent body confirms that course content is accurate, relevant and fit for purpose.
Training records and compliance audit trails
Record-keeping is not an administrative nicety – it is a legal requirement in several respects. Under GDPR, training records involving sensitive personal data must be handled appropriately. Under sector-specific regulation, particularly in financial services, evidence of manager competency forms part of regulatory supervisory reviews. HR teams building a compliance case for C-suite sign-off should be able to produce:
- A training needs analysis aligned to legal obligations by role
- Completion records covering all relevant managers
- Evidence of refresh cycles, particularly following legislative changes
- Certificates of accreditation for CPD-certified programmes
- Documentation of any bespoke tailoring to organisational context
Related resources
Whistleblowing Training for Managers: https://www.safecall.co.uk/service/whistleblowing-training-for-managers-online-and-on-site/
Tackling Sexual Harassment – Manager Training: https://www.safecall.co.uk/service/prevention-of-sexual-harassment-training/
Safecall Whistleblowing Resources Hub: https://www.safecall.co.uk/resources/
About Safecall training
Safecall has delivered whistleblowing and workplace training since 1999. Its facilitated manager training courses – including Listen Up (Whistleblowing for Managers), Tackling Sexual Harassment and Investigations Training – are CPD Certified by the CPD Certification Service. Courses are delivered online via Microsoft Teams or in person, with bespoke tailoring available for organisations that need training aligned to their own policies and risk profile. eLearning courses are fully SCORM-compliant and can be hosted on clients’ own LMS. Safecall is part of Law Debenture Corporation, a FTSE 250 company.
Find out more about Safecall’s training courses at safecall.co.uk/service/compliance-training/ or contact the team at [email protected] | +44 (0) 191 516 7720
Sources and further reading
Worker Protection (Amendment of Equality Act 2010) Act 2023 – UK Parliament
Employment Rights Act 2025 – UK Parliament (Royal Assent December 2025; first provisions in force 6 April 2026)
Economic Crime and Corporate Transparency Act 2023 – failure to prevent fraud offence in force 1 September 2025
Equality and Human Rights Commission – Technical Guidance on Sexual Harassment and Harassment at Work; enforcement guidance on the Worker Protection Act positive duty
ACAS – Code of Practice on Disciplinary and Grievance Procedures
ACFE Report to the Nations 2024 – Association of Certified Fraud Examiners
Freshfields Whistleblowing Survey 2023
Public Interest Disclosure Act 1998 (as amended)