Both elearning and expert-led training have a role to play in meeting the October 2026 standard. The question is which job each one is actually good at – and what you can prove about it if a tribunal ever asks.
The choice most organisations make without thinking about it
For most organisations, the decision between e-learning and expert-led training has historically come down to one thing: cost.
E-learning is cheaper to deploy, easier to schedule, and produces a completion record with minimal administrative effort. Expert-led training needs a trainer, a room or a video call, a block of staff time, and a higher invoice. The calculation has usually gone one way.
That calculation hasn’t changed. But the context around it has. From 30 October 2026, the Employment Rights Act 2025 raises the standard from taking reasonable steps to taking all reasonable steps to prevent sexual harassment at work. Tribunals will look not just at whether training happened, but at whether it was adequate for the purpose – and the type of training delivered, and what you can evidence about it, is now part of that judgement.
This article sets out what each approach genuinely does well, where each one runs out of road, and what the October 2026 standard means for using them together.
The genuine strengths of e-learning
E-learning isn’t a second-rate option. For a lot of organisations, and a lot of training objectives, it’s the right tool – and its strengths are real.
Scalability is the biggest one. An e-learning module can reach every employee at once, whatever their location, shift pattern, or working arrangement. For organisations with large, dispersed, or part-time workforces, that’s an advantage expert-led training simply can’t match without a lot of cost and logistical complexity.
Consistency comes with it. Every learner gets the same content, in the same sequence, assessed the same way – there’s no variation from one trainer or one session to the next. For baseline awareness training, making sure every employee understands what sexual harassment is and how to report it, that consistency is genuinely valuable.
The audit trail is straightforward too. Completion data is captured automatically – who completed the module, when, and in some systems what score they achieved – and that record is easy to produce and easy for a tribunal to understand.
For organisations that need to demonstrate broad workforce awareness of harassment policy, e-learning is a cost-effective, administratively light way to do it. Safecall’s own e-learning offer reflects that – there’s genuine value in reaching large numbers of people with consistent, accessible content.
Where e-learning runs out of road
The limitations here aren’t about the technology. They’re about what learning at a screen can and can’t achieve, and about what the law now expects an employer to be able to evidence.
The Equality and Human Rights Commission’s Technical Guidance, updated in September 2024, is explicit: training that’s a tick-box exercise, or that’s gone stale because it’s old or no longer reflects current legislation, won’t satisfy the reasonable steps standard. An e-learning module completed before the Worker Protection (Amendment of Equality Act 2010) Act 2023 came into force in October 2024 – let alone one that predates the October 2026 changes – would be hard to defend as adequate evidence of current compliance.
Content that was accurate two years ago may no longer reflect where the law stands today. The shift from reasonable steps to all reasonable steps, the new third-party harassment liability, and the EHRC’s updated guidance are all changes a module written before October 2024 won’t address – and a tribunal reviewing training records will draw its own conclusions from the date of the content, not just the fact that it was completed.
There’s a differentiation gap too. The EHRC’s guidance is clear that training shouldn’t be one-size-fits-all – senior leaders, managers, and staff all need different content, and managers in particular need training on how to receive and respond to a concern, not just on what counts as harassment. A single all-staff module doesn’t cover that, however well it’s produced.
And there’s a limit to what it can do behaviourally. E-learning is genuinely effective at knowledge transfer – a learner who completes a well-designed module will know the definition of sexual harassment and understand the reporting process. What it can’t replicate is the experience of applying that knowledge in a realistic, pressured moment. A manager who knows what the policy says may still freeze, deflect, or handle a disclosure badly the first time they actually face one. Scenario-based, facilitated training exists specifically to close that gap.
A completion record proves a module was finished. It doesn’t prove the training was current, adequate, or that the learner can apply it when it matters.
The strengths of expert-led training
Expert-led training fills the gaps e-learning leaves – it does things a screen-based module structurally can’t.
Scenario-based learning is the main one. A skilled trainer can put a manager into a realistic situation – a disclosure made quietly after a team meeting, an allegation involving a senior colleague, a complaint about a client’s behaviour on a site visit – and have them work through it. The discomfort of that exercise is precisely the point. A manager who has rehearsed a difficult conversation is more likely to handle it well when it isn’t a rehearsal.
Interactivity matters just as much. Learners can ask questions a module can’t anticipate, and a trainer can probe assumptions, challenge poor reasoning, and correct misunderstandings in real time. For some of the genuinely counterintuitive legal concepts in this area – that intent is irrelevant, that cumulative behaviour matters, that employers have to act on culture rather than wait for a complaint – that live back-and-forth does more than reading the right answer off a screen.
The trainer’s credentials carry evidential weight too. Training delivered by a subject specialist, with documented expertise, CPD accreditation, and a clear record of what was covered, is a more robust piece of evidence in a tribunal or EHRC investigation than a platform-generated certificate for a generic module. Where the question is whether an employer took all reasonable steps, the quality and credibility of the training is itself part of the answer.
It’s also better placed to handle the third-party harassment scenarios the Employment Rights Act 2025 introduces as a new explicit employer liability from October 2026. Harassment by clients, customers, contractors, and suppliers needs contextualised, sector-specific discussion that a general e-learning module rarely provides.
Where expert-led training has limitations
Expert-led training has real constraints too, and they’re worth naming plainly.
Cost per head is higher, and for large organisations that difference is material. A session covering up to ten participants at a fixed price works well for team-level delivery, but rolling it out across an entire workforce of several hundred people needs a level of budget and scheduling that e-learning doesn’t.
Scheduling adds friction too. A face-to-face or live online session needs participants free at a specific time, which gets complicated fast for shift-based workforces, remote teams, or organisations with high turnover – the administrative overhead is a lot more than pressing play on a module.
These are reasons to use e-learning as part of the mix, not reasons to lean on it alone. For most organisations, the practical answer is a layered one: e-learning for broad workforce awareness and audit-trail completeness, expert-led training for managers, senior leaders, and anyone with a role in receiving or investigating a disclosure.
At a glance: how the two approaches compare
Both are doing a genuinely different job, and both produce genuinely different evidence. Here’s where each one earns its place.
| E-Learning | Expert-led training | |
| Skalierbarkeit | Deploys to any number of staff at once, regardless of location or shift pattern | Delivered in cohorts – scales through repeat sessions rather than a single rollout |
| Cost per head | Low – a fixed licence cost makes it efficient across large or dispersed workforces | Higher per head, reflecting specialist delivery and depth of content |
| Consistency | Every learner receives identical content, sequence, and assessment | Adapts to the room – tailored to the specific risks and roles in front of the trainer |
| What it’s best suited to | Building broad, organisation-wide awareness quickly and consistently | Building applied skill in the people who receive, respond to, and investigate concerns |
| Behavioural practice | Strong for knowledge transfer – learners know the policy and the process | Strong for rehearsal – learners practise applying that knowledge under realistic pressure |
| Content tailoring | Efficient as a single, organisation-wide module | Can be tailored precisely to seniority, role, and sector-specific risk |
| Evidence produced | A clear, automatic completion record – who, when, and what score | A documented record of content covered, trainer credentials, and CPD accreditation |
| Role in a tribunal defence | Demonstrates broad completion and baseline awareness across the workforce | Demonstrates depth, currency, and applied competence in higher-risk roles |
| Third-party harassment | Can introduce the topic as part of standard awareness content | Can work through sector-specific, real scenarios in facilitated discussion |
What the October 2026 standard implies
The Employment Rights Act 2025 doesn’t specify which type of training an employer must use.
What it requires is that an employer can demonstrate it took all reasonable steps – and that a tribunal, or the EHRC, finds that answer credible. The EHRC’s Technical Guidance points toward a training programme that is current, differentiated by audience, documented, and evidenced.
A programme built entirely on e-learning – particularly e-learning that hasn’t been updated since 2024, that doesn’t address third-party harassment, or that has no manager-specific content on responding to disclosures – is unlikely to satisfy that standard on its own.
The question isn’t which approach is better in the abstract. It’s what a tribunal will make of your training programme if a claim is brought. Generic e-learning completed two years ago will raise questions. A documented programme of CPD-accredited, expert-led training, covering the specific scenarios and manager responsibilities the legislation addresses, will raise fewer.
For most organisations, the most defensible position is also the most practical one: e-learning to make sure every employee has completed a current awareness module, and expert-led training to give managers, investigators, and senior leaders the applied skills the law now expects them to demonstrate.
How Safecall can help
Safecall has supported more than 1,200 organisations across 150 countries in building speak-up cultures since 1999. 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 underpins the credibility of everything it delivers.
Safecall’s training portfolio spans both approaches. E-learning options provide accessible, scalable awareness training with completion tracking. Tackling Sexual Harassment, Investigating Sexual Harassment, Whistleblowing for Managers, and Investigation Training are delivered by subject experts, and are specifically designed to address the manager-level responsibilities, scenario-based application, and evidential requirements the October 2026 standard demands.
For organisations reviewing their current 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