Both dates come from Acas’s own current guidance on the Employment Rights Act 2025, cross checked against briefings from Lewis Silkin, Mishcon de Reya, Bevan Brittan and Blake Morgan.
From 1 October 2026, the tribunal time limit for most claims, including unfair dismissal and discrimination, moved from three months to six, for anything that happens on or after that date. Scotland has a separate date of 9 November for breach of contract claims specifically.
From 30 October 2026, the duty on employers shifts from taking “reasonable steps” to prevent sexual harassment to taking “all reasonable steps.” Acas describes this as a move from responding to incidents toward genuine prevention, applied across the whole organisation rather than only to people who have already been involved in a complaint. Tribunals can apply a compensation uplift of up to 25 per cent where an employer falls short. Alongside it, the existing duty to prevent third party harassment, previously limited to sex, now extends to other protected characteristics, with the exceptions of marriage and civil partnership, and pregnancy and maternity.
Most employment law changes land on an organisation’s own staff, managed by its own HR team, on its own premises. This one lands on a workforce that spends its working day somewhere else.
Cleaning teams, security officers, catering staff and maintenance engineers deployed under FM contracts work inside buildings owned and occupied by other companies. They answer to a client’s visitors, a client’s tenants and a client’s own employees all day, every day. That is precisely the relationship the third party harassment duty is built around, and it is a relationship FM providers have always managed informally through supervision and site conduct, without it previously carrying this level of legal weight.
It also creates a question that genuinely needs an answer rather than a policy document: when the people who might cause harm, or experience it, are not your employees and not on your site, whose “reasonable steps” are they?
Acas’s guidance does not treat this as a single employer’s problem to solve alone. The steps expected scale with the size of the organisation, the sector and the kind of work being done, which for a contract workforce almost certainly means some shared responsibility between the FM provider and the client who controls the site. Neither side has much excuse to wait and find out through a tribunal claim which one of them was supposed to act.
Acas is deliberately specific that this duty is about prevention, not paperwork. For an FM contract workforce, a handful of practical steps start to answer the “what do we actually do” question that most harassment policies leave unanswered:
Build a reporting route that works for someone who is never in the client’s HR office and rarely sees their own line manager face to face. A phone number or app that goes straight to the FM employer, not a form buried on an intranet the worker cannot access.
Put the duty into the contract itself. Site conduct expectations, a shared incident process and agreement on who investigates what, written down before anything happens rather than negotiated after.
Brief site supervisors specifically on third party conduct, separate from the general harassment training most staff already receive, because the scenario here is a client’s employee or visitor, not a colleague.
Review incidents against the “all reasonable steps” standard on a schedule, not only after something goes wrong. A tribunal will ask what was done before the complaint, not just after.
The doubling of the tribunal time limit gets less attention, but it changes something FM and property employers deal with constantly: contract transitions, TUPE transfers and the end of service agreements.
A worker now has six months, not three, to bring a claim after leaving a role or a contract ending. For an industry where staff regularly move between providers as contracts change hands, that is a longer window in which records, witnesses and site details need to stay retrievable. Six months after a contract ends, the people who could explain what happened have often moved on twice over.
Seventeen days is enough time to do three things properly: confirm who, between provider and client, is accountable for which part of the “all reasonable steps” duty on each live contract, give site supervisors a short, specific briefing on third party conduct rather than relying on a general policy refresh, and check that a worker on a client site actually knows how to report a problem without going through that client first.
None of this needs a rewritten employee handbook by the end of the month. It needs a conversation that has probably not happened yet between the people who run the contract and the people who manage the risk.
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