Third-Party Harassment: What Employers Need to Know

New workplace harassment laws came into force on 30 October 2026, strengthening employers’ responsibilities to protect their staff. One significant change is that harassment doesn’t have to come from a colleague to create legal liability.

Under the Employment Rights Act 2025, employers must now take all reasonable steps to prevent sexual harassment. New provisions also address harassment by third parties, including customers, clients, contractors and members of the public.

Here are five things every employer should know.

1. Harassment Isn’t Just an Internal Workplace Issue

Workplace harassment isn’t always carried out by colleagues. Employees may also experience inappropriate behaviour from customers, suppliers, contractors or visitors.

Under the new legislation, employers can be held liable for harassment by third parties where they have failed to take all reasonable steps to prevent it.

This is particularly relevant to businesses with customer-facing employees or those working regularly with external organisations.

Tip: Consider who your employees interact with and whether those interactions could expose them to harassment.

2. The New Protections Go Beyond Sexual Harassment

While sexual harassment is a key focus of the legislation, the new third-party protections also cover harassment related to protected characteristics, such as race, disability, religion and age.

This means employers need to consider a wider range of inappropriate behaviour when assessing workplace harassment risks.

Tip: Review your harassment policies to ensure they address all relevant forms of harassment, including behaviour by customers, clients and other third parties.

3. Employers Must Take ‘All Reasonable Steps’

Since October 2024, employers have been required to take reasonable steps to prevent sexual harassment. From 30 October 2026, this duty has been strengthened to all reasonable steps.

What is reasonable will depend on the organisation’s size, resources and working environment.

Preventative measures might include risk assessments, clear policies, staff training and accessible reporting procedures.

Tip: Complete a harassment risk assessment, identify appropriate controls and document the actions taken.

4. Training and Reporting Procedures Matter

Having a policy is important, but employees also need to understand what constitutes harassment and how to report concerns.

Managers should know how to respond appropriately, particularly when complaints involve customers or important clients.

Regular awareness training helps employees recognise inappropriate behaviour and understand their responsibilities.

Tip: Include harassment awareness training in employee induction and provide periodic refresher training. Keep records of completion.

5. Prevention Should Be Ongoing

Meeting the new requirements isn’t simply about responding when something goes wrong.

Employers should regularly review harassment risks, consider employee feedback and assess whether existing preventative measures remain effective.

For smaller businesses, this doesn’t need to be complicated. A proportionate approach, supported by clear responsibilities and regular reviews, can make a meaningful difference.

Tip: Include harassment prevention in your regular business risk reviews and update your arrangements when circumstances change.

Supporting a Safer Workplace

The October 2026 changes reinforce the importance of protecting employees from harassment, including inappropriate behaviour by people outside the organisation.

For small businesses, the starting point is straightforward: understand the risks, establish clear expectations and ensure employees know how to recognise and report harassment.

How isowise Can Help

Preventing sexual harassment starts with awareness. Employees need to understand what constitutes inappropriate behaviour, how to recognise it and what to do if they experience or witness it.

Our Sexual Harassment Awareness e-learning course helps businesses educate their employees and support their wider responsibilities for preventing sexual harassment in the workplace.

With accessible online training and completion tracking, isowise makes it simple to build awareness across your organisation.

Explore all our training courses here.