The Employment Rights Bill (ERB) received Royal Assent in December 2025 and is now officially the Employment Rights Act (ERA). As a central pillar of the government's manifesto, the ERA introduces extensive changes to employment law in England, Scotland, and Wales. For recruitment agencies and end-hirers, understanding the specific timing of these changes is now critical for both compliance and commercial planning.
The Timeline of Change
The government has published an implementation roadmap that staggers these reforms throughout 2026 and 2027.
- Q1 2026: The focus is on industrial relations, with changes regarding trade union legislation and the removal of barriers to industrial action.
- Q2 2026: "Day One" rights will take effect, including the removal of the three-day waiting period for Statutory Sick Pay (SSP) and the removal of the Lower Earnings Limit. Paternity and Unpaid Parental Leave will also become "Day One" rights. Simultaneously, the Fair Work Agency (FWA) will launch with powers to fine employers up to £20,000 per underpaid worker for breaches in holiday pay, SSP, and minimum wage.
- Q4 2026: Protections expand further, including a ban on "Fire and Rehire" practices and new liability for employers regarding third-party harassment of their staff.
- 2027: Reforms continue with changes to Unfair Dismissal protections (reducing the qualifying period to six months) and new rights for zero-hours workers, including guaranteed hours based on a reference period.
Implications for the Industry
The introduction of the Fair Work Agency, combined with joint and several liability legislation, means the supply chain's risk profile is changing. Agencies face immediate financial exposure from SSP changes, which require a review of commercial agreements involving lower-paid workers. Furthermore, the upcoming third-party harassment laws will extend the duty of care owed by end clients, potentially leading to significant tribunal awards.
Moving Forward
At Champion, we recommend taking action now. From modelling cost impacts to insulating agencies from compliance risks, we are ready to assist through this transition. As an FCSA-accredited and SafeRec-certified provider, we offer the transparency needed to navigate this new landscape confidently.
For further guidance, please contact Champion Contractors on 0161 703 2549 or email info@championcontractors.co.uk.