A lot of organisations have already built internal training capability, and that investment isn’t wasted. But the October 2026 standard asks a specific question about independence and expertise – and internal training, on its own, has a more limited answer to it than many employers currently realise.
A decision most organisations made before the law changed
For years, the case for internal training was straightforward.
It’s cheaper to use people you already employ than to bring in an external provider. An internal trainer knows the organisation, its culture, its language, and the specific situations its people run into. Training can be scheduled flexibly, updated quickly, and delivered without the overhead of booking someone external.
None of that has changed. What has changed is the standard training gets assessed against if a sexual harassment claim reaches an employment tribunal.
From 30 October 2026, the Employment Rights Act 2025 requires employers to demonstrate they took all reasonable steps to prevent harassment. Tribunals will look not just at whether training happened, but at who delivered it, what it covered, how recently it was updated, and whether it would hold up under questioning from an opposing legal team.
This article sets out where internal training genuinely serves organisations well, where it creates risk, and where external expertise is hardest to replace under the October 2026 standard.
The genuine strengths of internal training
Internal training isn’t a compromise. For a lot of organisations, and a lot of training objectives, it’s the most effective option available.
Contextual knowledge is the biggest advantage. An internal trainer understands the organisation’s specific working environment – the sectors it operates in, the power dynamics within its teams, the particular situations its employees are likely to encounter. Generic external training can feel disconnected from the realities of a particular workplace, whereas internal delivery, done well, can anchor the content in scenarios people in the room instantly recognise.
Cultural fit matters too. An internal trainer who’s known and respected within the organisation can make difficult conversations feel safer – people may engage more honestly with a facilitator they already trust than with an external provider they’ve never met.
Speed and flexibility are practical advantages as well. Internal training can be scheduled around operational needs without the lead times an external booking requires, content can be updated quickly in response to policy changes or specific incidents, and the cost model is predictable once a trainer is in place.
For foundational awareness training – making sure staff understand what sexual harassment is, what the reporting process looks like, and what the policy says – internal delivery can be entirely appropriate. The question isn’t whether internal training has value. It’s whether it’s sufficient for every part of what the October 2026 standard requires.
Where internal training runs out of road
The limitations here are structural, not a matter of the trainer’s ability or commitment. They come from the relationship between the trainer and the organisation – and that relationship is exactly what a tribunal will look at.
Independence is the biggest one. An internal trainer is employed by the organisation whose culture and practices are under examination. That’s not a criticism of the individual – it’s a structural fact that shapes what the training can credibly claim to achieve. A tribunal assessing whether an employer took all reasonable steps will ask whether the training was independent enough to challenge existing assumptions, identify cultural blind spots, and address the power dynamics harassment typically exploits. An internal trainer is structurally limited in how far they can do any of that.
The EHRC’s Technical Guidance is clear that training has to be effective, not just delivered. Training that reinforces the existing culture rather than genuinely examining it doesn’t satisfy the reasonable steps standard, however well-intentioned it is.
Legal expertise is the second gap. Sexual harassment legislation has moved significantly in the past two years – the Worker Protection (Amendment of Equality Act 2010) Act 2023, the EHRC’s updated Technical Guidance from September 2024, and the Employment Rights Act 2025 are all material changes an internal trainer has to have actively tracked and built into their content. The risk of stale or legally inaccurate training is real, and at tribunal, a claimant’s legal team will test the content itself, not just the fact that training happened.
Investigation training is where the gap is widest. Impartial evidence gathering, structured interviewing, procedural fairness, and accurate report preparation are specialist skills that most internal HR professionals haven’t been formally trained in. An investigation run without them doesn’t just fail the person who raised the complaint – it creates a second, compounding liability that increases the employer’s exposure at tribunal, as case law has shown repeatedly.
A tribunal won’t simply ask whether training was delivered. It will ask whether the person delivering it was qualified to, whether the content was current, and whether the training could credibly challenge the culture it was meant to address.
The strengths of external training
External training closes the structural gaps internal delivery can’t, whatever the internal trainer’s individual capability.
Independence is its most important quality. An external provider has no stake in the organisation’s existing culture, no reporting line to senior management, and no interest in softening difficult findings. That’s not just ethically significant – it’s evidentially significant. A tribunal assessing the credibility of a training programme will treat externally delivered, CPD-accredited training from a recognised specialist as more robust evidence of reasonable steps than internally produced content, however carefully it was prepared.
Specialist expertise carries the same kind of weight. Providers working specifically in sexual harassment prevention and workplace investigation bring knowledge that’s current, tested across multiple organisations and sectors, and grounded in the legislative framework that actually applies – documented, verifiable, and not dependent on one individual staying in post.
The trainer’s credentials matter in a tribunal context too. Training delivered by former senior police officers, with documented investigative experience, a structured methodology, and CPD accreditation, occupies a different evidential position to training delivered internally by an HR professional, however competent. Where the question is whether the employer took all reasonable steps, the standing of the person who delivered the training is part of the answer.
External training is also better placed for the specific requirements the October 2026 changes bring in. Third-party harassment liability – covering harassment by clients, customers, contractors, and suppliers – needs scenario-based content most internal programmes haven’t yet developed, whereas a provider working across sectors will typically have built that in already.
Where external training has limitations
External training has real constraints too.
Cost is the most obvious – specialist external training carries a higher per-session cost than internal delivery, and for large organisations deploying it across multiple teams or locations, the budget implications are material.
Contextual knowledge takes deliberate effort to build. An external provider doesn’t arrive already knowing the organisation’s culture, sector, or risk profile – a good provider invests in understanding these before delivery, but that takes time and briefing that an experienced internal trainer starts with for free.
Scheduling takes planning too. External delivery depends on provider availability, needs participants free at specific times, and carries coordination overhead that internal delivery avoids.
For most organisations, the practical answer is a deliberate combination: internal capability for foundational awareness and policy communication, external specialist delivery where independence, expertise, and tribunal credibility matter most – specifically manager training, investigation training, and content addressing the new third-party liability from October 2026.
At a glance: how the two approaches compare
Both have a genuine role. Here’s where each one is strongest.
| Internal training | External training | |
| Cost | Lower direct cost – makes use of people already on the team | Higher per session, reflecting specialist expertise and delivery |
| Contextual knowledge | Strong from day one – the trainer already knows the culture, sector, and people | Built deliberately through briefing – a good provider invests in understanding the organisation before delivery |
| Independence | Best suited to reinforcing existing policy and culture | Structurally separate from the organisation, which is what lets it challenge culture and blind spots directly |
| Expertise in harassment law | Reflects whatever the individual trainer has kept up with | Consistent and current – maintained by specialists working across many organisations |
| Investigation training | Efficient for volume; best paired with specialist input on technique | Built on structured, specialist investigative methodology |
| Tribunal credibility | Strongest where content is current, documented, and clearly for foundational awareness | Strongest where independence and CPD accreditation are being tested directly |
| Evidential weight | Solid for completion and attendance records the organisation maintains | Adds CPD-accredited, externally verifiable content records |
| Third-party harassment | Can be developed in-house with the right investment | Typically already built into standard delivery |
What the October 2026 standard implies for the choice
The Employment Rights Act 2025 doesn’t prohibit internal training. What it requires is that an employer can demonstrate all reasonable steps were taken – and that the demonstration is credible to a tribunal or the EHRC.
For general staff awareness – making sure every employee understands the organisation’s policy, knows what harassment looks like, and can identify the reporting channel – internal training may well be sufficient, provided the content is current and the delivery is documented.
Manager training is where internal delivery is hardest to justify on its own. Tribunal case law keeps coming back to manager-level failures, and they tend to be the most costly – because managers are the people most likely to have their own conduct tested if a claim reaches a hearing, which means the training they received gets scrutinised hardest.
For investigation training – building the capability to run a legally defensible inquiry into a harassment allegation – the case for external specialist delivery is strongest. The skills involved are the most specialist, the consequences of getting it wrong are the most severe, and the independence of the trainer matters most directly to the credibility of the outcome.
The question for any organisation reviewing its training arrangements before October 2026 isn’t which approach is better in the abstract. It’s where internal delivery is genuinely sufficient, and where the standard asks for something it can’t provide on its own.
How Safecall can help
Safecall has worked with more than 1,200 organisations across 150 countries since 1999, helping them build speak-up cultures that are credible, independent, and can be evidenced.
As a wholly owned subsidiary of The Law Debenture Corporation plc, a FTSE-listed trust company, Safecall operates as a structurally independent third party – the independence that gives external delivery its evidential value in exactly the situations this article describes.
Safecall’s expert-led training programme is built around the areas where external delivery matters most. The Tackling Sexual Harassment course equips managers with the practical skills to prevent, recognise, and respond to harassment – including the third-party scenarios October 2026 introduces as a new employer liability. The Investigating Sexual Harassment and Investigation Training courses are delivered by former senior police officers, each with a minimum of 25 years of interview experience in evidential interviewing, structured investigation, and report preparation – skills internal trainers are rarely in a position to replicate, and the ones tribunals will examine most closely if an employer’s response to a disclosure comes under scrutiny.
All Safecall training is CPD accredited, and completion certificates are provided so organisations have the evidence they need to demonstrate a credible, independently delivered training programme. For organisations reviewing their training mix ahead of October 2026, Safecall’s October Readiness Assessment provides a structured self-diagnostic across the five areas the legislation addresses.
Download the free October Readiness Assessment to identify your specific gaps.
Contact Safecall: [email protected] | +44 (0) 191 516 7720 | www.safecall.co.uk
Sources and references
1. EHRC Technical Guidance on Sexual Harassment and Harassment at Work (updated September 2024)
2. Employment Rights Act 2025 – legislation.gov.uk
3. Worker Protection (Amendment of Equality Act 2010) Act 2023 – legislation.gov.uk