The Employment Rights Act 2025 (ERA 2025) is the most significant overhaul of UK employment law in a generation. Receiving Royal Assent in December 2025, its first wave of provisions came into force on 6 April 2026.
For HR, compliance and L&D professionals, the Employment Rights Act implications extend well beyond the headline changes to unfair dismissal and zero-hours contracts. Two of its provisions have a direct bearing on what workplace training – and manager training in particular – must now cover.
The two Employment Rights Act 2025 changes that affect manager training most
Sexual harassment as a qualifying whistleblowing disclosure
ERA 2025 amended the Public Interest Disclosure Act 1998 to add sexual harassment explicitly to the list of qualifying disclosure categories. From 6 April 2026, a worker who raises a concern about sexual harassment – whether they are the subject of it, a witness to it, or reporting a pattern of conduct – is a protected whistleblower for the purposes of PIDA.
This change closes a gap that previously left some harassment reporters in an uncertain legal position. It also creates a new complexity for managers: the same disclosure may simultaneously engage harassment law under the Equality Act 2010, the preventative duty under the Worker Protection Act 2023, and whistleblower protections under PIDA as amended by ERA 2025. A manager who handles the situation purely as a grievance – without recognising the whistleblowing dimension – risks subjecting the worker to unlawful detriment under a framework they did not know applied.
The Fair Work Agency
ERA 2025 established the Fair Work Agency, which launched on 6 April 2026, consolidating enforcement functions previously held by HMRC’s National Minimum Wage team, the Gangmasters and Labour Abuse Authority, and the Employment Agency Standards Inspectorate. The Fair Work Agency has broad investigation and enforcement powers and is tasked with proactive enforcement rather than reactive complaint-handling.
For organisations in sectors with higher compliance risk – hospitality, logistics, social care, retail, financial services – the Fair Work Agency’s existence creates an additional regulatory audience for employment practice. Documented, current manager training is part of the evidence base an organisation would need to present in an investigation or audit.
How ERA 2025 interacts with existing training obligations
ERA 2025 does not create a standalone duty to train managers in the way the Worker Protection Act 2023 does. Its effect on training obligations is indirect but real: it changes the legal environment in which managers operate, meaning that training produced before ERA 2025 came into force may no longer accurately describe the law.
Three existing training areas are most directly affected:
Whistleblowing and protected disclosure training
Any training that covers what a protected disclosure is – whether standalone whistleblowing training or a broader compliance module – now needs to include sexual harassment as a qualifying category. Training that lists the six original PIDA categories without the ERA 2025 addition is out of date. Managers who have received that training are operating with an incomplete picture of when whistleblowing protections apply and when they are at risk of committing an unlawful detriment.
Harassment and sexual harassment training
Managers trained on the Worker Protection Act 2023 – which came into force in October 2024 – need an update that reflects the ERA 2025 amendment. The conversation about sexual harassment in the workplace now sits at the intersection of three distinct legal frameworks: the positive preventative duty (WPA 2023), equality and vicarious liability law (Equality Act 2010), and whistleblower protection (PIDA as amended by ERA 2025). Training that treats these as separate topics creates the kind of compartmentalised knowledge that fails in practice.
Grievance and disciplinary training
ACAS codes of practice on discipline and grievance are not directly amended by ERA 2025, but the Act’s expansion of whistleblowing protections affects how managers should approach certain grievance situations. Where a grievance contains or implies a concern about wrongdoing – including sexual harassment – managers need to know that the grievance procedure and the whistleblowing procedure may both be engaged, and that misclassifying the disclosure as purely a personal grievance removes protections the worker is legally entitled to.
Practical implications for training design
The cumulative effect of the WPA 2023, ERA 2025 and the ECCTA failure to prevent fraud offence (in force September 2025) is that the legal environment for managers has materially changed in the past 18 months. Training programmes that have not been reviewed since early 2024 are likely to contain gaps or inaccuracies across at least one of these three areas.
Organisations reviewing their training programmes should consider:
- Whether whistleblowing training content reflects the ERA 2025 expansion of qualifying disclosures
- Whether harassment training integrates the whistleblower protection dimension alongside the WPA positive duty
- Whether managers have received, or are scheduled to receive, refreshed training that reflects the current legal position
- Whether training records are sufficiently detailed to demonstrate currency of content, not just completion dates
- Whether bespoke or sector-specific training requirements – particularly in regulated industries – align with the ERA 2025 framework
ERA 2025 and the broader compliance picture
ERA 2025 sits alongside a broader shift in UK employment regulation. The Freshfields Whistleblowing Survey 2023 found that 43% of employees had been involved in a whistleblowing situation, up from 32% in 2020. Protect’s 2025 Impact Report recorded 3,589 cases – an 8% year-on-year increase – with governance and staff conduct accounting for 30% of cases. These figures reflect a workplace environment in which managers encounter disclosure situations more frequently than before and face greater legal and reputational consequences when they handle them badly.
ACFE’s 2024 research found that tips from employees account for 43% of fraud detections – three times any other detection method – and that anonymous reporting channels reduce fraud losses by 50%. ERA 2025’s expansion of whistleblowing protections is designed to increase the confidence with which workers raise concerns. Organisations that invest in manager training to match that expanded framework are better positioned to receive and act on those concerns before they become regulatory or reputational events.
What ERA 2025-compliant manager training looks like
Training that reflects the post-Employment Rights Act2025 legal position needs to do more than add a slide about the new Act. It should be integrated – treating whistleblowing, harassment and disciplinary procedure as interconnected areas of practice, not separate compliance boxes. Specifically, it should address:
- The current categories of qualifying disclosure under PIDA as amended, including sexual harassment
- The interaction between ERA 2025 whistleblowing protections and the WPA 2023 positive preventative duty
- How to handle a disclosure that may simultaneously be a grievance and a protected disclosure
- The detriment framework, including inadvertent detriment, and personal manager liability
- The role of the Fair Work Agency and the regulatory environment post-ERA 2025
- Documentation and escalation standards that satisfy the evidential requirements of both employment tribunals and regulatory review
Training delivered by facilitators with direct experience of how disclosures play out in practice – rather than derived solely from statutory text – equips managers to handle the ambiguous situations that real-world disclosures typically present.
Related resources
Legal Obligations for Manager Training in the UK (hub): https://www.safecall.co.uk/resource/legal-obligations-for-manager-training-in-the-uk/
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’s whistleblowing and harassment training for managers
Safecall’s facilitated manager training courses are updated to reflect the current legal position under ERA 2025, the Worker Protection Act 2023 and PIDA. Listen Up – Whistleblowing for Managers and Tackling Sexual Harassment – A Guide for Managers are both CPD Certified and available online or in person. Both draw on anonymised real-world case material from 25+ years of live whistleblowing reports, providing managers with the practical grounding to handle disclosure situations confidently and correctly.
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
Employment Rights Act 2025 – UK Parliament. Full text: legislation.gov.uk/ukpga/2025/legislation
Public Interest Disclosure Act 1998 (as amended by ERA 2025) – UK Parliament: legislation.gov.uk/ukpga/1998/23
Worker Protection (Amendment of Equality Act 2010) Act 2023 – UK Parliament: legislation.gov.uk/ukpga/2023/51
Equality and Human Rights Commission – Employer guidance on the Worker Protection Act positive duty: equalityhumanrights.com/guidance/worker-protection-act-2023
Fair Work Agency – GOV.UK: gov.uk/government/organisations/fair-work-agency
ACAS – Code of Practice on Disciplinary and Grievance Procedures: acas.org.uk/acas-code-of-practice-for-disciplinary-and-grievance-procedures
Protect – 2025 Impact Report: protect-advice.org.uk/protect-2025-impact-report/
ACFE Report to the Nations 2024: acfe.com/report-to-the-nations/2024
Freshfields Whistleblowing Survey 2023 – Freshfields Bruckhaus Deringer: freshfields.com/en-gb/our-thinking/campaigns/whistleblowing-survey-2023/