In focus by topic
The government’s key employment policy changes, by topic.
Quick links
Diversity and inclusion
Equal pay, pay gaps and equality action plans
In short summary, what is changing?
Large employers (i.e. those with 250 employees or more) will be required to publish an equality action plan on addressing gender pay gaps and actions to support employees going through the menopause and prescribed information in relation to such plans, as well as naming large providers they contract with for outsourced workers. A Regulatory Enforcement Unit will be established for equal pay matters. Measures relating to ethnicity and disability reporting and equal pay rights will be delivered through the (as yet unpublished) Equality (Race and Disability) Bill (ERDB).
What are the next steps?
Equality action plan measures are anticipated in 2027. Subject to prior consultation, regulations will be made to require large employers to (a) develop and publish an equality action plan showing the steps that they are taking in relation to gender equality (including addressing the gender pay gap and supporting employees going through the menopause); and (b) publish prescribed information relating to the plan. Implementation of the measures relating to outsourced workers will be dependent on broader changes to pay gap reporting, including the ERDB. The government launched a consultation on mandatory ethnicity and disability pay gap reporting and call for evidence, both of which have now closed, and which will inform the measures to be included in the ERDB.
What should employers do now to prepare?
Prepare to invest time and resources in assessing and understanding pay gap information and in formulating gender equality action plans. Looking ahead, also plan for additional pay reporting duties under the ERDB which will make it mandatory for large employers to report their ethnicity and disability pay gap. Advance work on data collection, assessment and understanding of pay gaps will be required.
Harassment
In short summary, what is changing?
All employers will be required to take ‘all’ reasonable steps to prevent workplace sexual harassment and third party harassment liability will be introduced (whether related to sex or any other protected characteristic). Disclosure of sexual harassment will be explicitly protected under the whistleblowing legislation.
What are the next steps?
New whistleblowing protections will take effect in April 2026, and third-party harassment liability and the duty to take ‘all’ reasonable steps will take effect in October 2026. Regulations to specify steps that are to be regarded as ‘reasonable’, to determine whether an employer has taken ‘all’ reasonable steps to prevent sexual harassment will then follow in 2027. The government launched an equality law call for evidence (now closed), including to identify measures that have proved to be effective in practice in reducing or preventing sexual harassment in the workplace, and to explore whether any further reforms in this area may be required.
What should employers do now to prepare?
Employers will need to be proactive in how they prevent and tackle harassment at work, with the reasonable steps varying from employer to employer depending on factors such as the employer’s size, the sector it operates in, the working environment and its resources. For example, employers should review and update their anti-harassment policies, training, contractual clauses, reporting channels and mechanisms for handling reports.
Non-disclosure agreements (NDAs)
In short summary, what is changing?
The Bill will make any provision in an agreement between an employer and a worker void if it seeks to prevent the worker from making certain allegations or disclosures of information relating to certain work-related discrimination and harassment. The Bill makes provision for exceptions to this; but further detail is required including further regulations.
What are the next steps?
Further consultation and regulations are expected but there are currently no published timescales.
What should employers do now to prepare?
Depending on the scope of any exclusions, this could significantly impact an employer’s (and worker’s) ability to agree confidentiality terms (or “NDAs”) in certain cases of discrimination and harassment. Employers should anticipate reviewing the current wording and/or the inclusion of any confidentiality clauses e.g. in template settlement agreements in certain cases of discrimination and harassment and how this will affect their approach to defending or settling claims, once in force.
Family-friendly rights
Flexible working
In short summary, what is changing?
In response to an application for flexible working, an employer may continue to rely on the existing statutory grounds to refuse. However, the Employment Rights Bill adds additional requirements: that it must be reasonable for the employer to refuse on that/those ground(s) and, when notifying its refusal, explain why it considers it reasonable.
What are the next steps?
A consultation is planned for winter 2025/early 2026 and the government is also expected to issue regulations which specify steps an employer must take in order to comply with the requirement to consult before rejecting an application (a consultation duty was only recently added in 2024). The Acas Code on flexible working will also need to be updated. The measures will not take effect until 2027.
What should employers do now to prepare?
Anticipate more workers expecting to work flexibly and tribunal claims to consider the reasonableness of an employer’s refusal. However, the Bill does not change the potential penalty (eight weeks’ pay). Risk assess the impact on your current flexible working strategy, including policies and culture.
Protection from dismissal during pregnancy, maternity and other leave and upon return
In short summary, what is changing?
The Employment Rights Bill enables regulations to be made to ban the dismissal of women who are pregnant, on maternity leave, and during a six-month return-to-work period, except in ‘specific circumstances’. Protection will also be extended to employees in respect of adoption, shared parental, neonatal care and bereaved partners paternity leave and for a period after returning to work from taking these forms of leave.
What are the next steps?
The new rights will take effect in 2027, following a consultation planned for autumn 2025. Further regulations are required to determine the details, including what the ‘specific’ excepted circumstances will entail.
What should employers do now to prepare?
Employers should expect that dismissing an employee during a protected period will only be lawful in limited circumstances and ensure processes are in place to keep a record of those employees who are within a protected period across the business to reduce the risk of breaches of the proposed new laws (particularly in large organisations).
Parental and other leave
In short summary, what is changing?
Paternity and unpaid parental leave will become day one rights and the current restriction on taking paternity leave after shared parental leave will be removed. In addition, a new right to unpaid bereavement leave will be introduced, which will be extended to cover pre-24 week pregnancy loss.
What are the next steps?
Day one rights to paternity and unpaid parental leave will take effect from April 2026. In relation to bereavement leave, further regulations are required to confirm: the employee’s required relationship to the person who has died (or in the case of pre-24 week pregnancy loss the required relationship to the employee who has suffered the pregnancy loss/child that was due to be born had the pregnancy loss not occurred); the length of the leave (at least one week); and the period in which the leave must be taken (which must extend to at least 56 days after the person’s death). A consultation on this detail is planned for autumn 2025 and bereavement leave will take effect in 2027. Separately, the government has launched a review of the entire parental leave and pay system, expected to run for 18 months and includes a call for evidence. This is likely to lead to further reform.
What should employers do now to prepare?
Amend paternity and unpaid parental leave policies now and anticipate amending parental bereavement leave policies once further detail is published (considering any current compassionate leave policies and how the new right to bereavement leave may interact).
Trade unions and collective labour law
In short summary, what is changing?
There are significant trade union-related changes, including:
- an employer duty to inform all employees of their right to join a union
- a new right, overseen by the Central Arbitration Committee (CAC), by which unions can request, negotiate and enforce workplace access (including digital access) for officials to meet, support, represent, recruit, communicate with or organise workers. A “fast-track” process may apply to secure an access agreement together with enforcement mechanisms
- changes to the statutory recognition process, including: lowering the thresholds to secure recognition (e.g. no longer requiring that a union is likely to have support from the majority of the bargaining unit before an application is initially accepted, removing the 40% support threshold in a recognition ballot and potentially reducing the 10% application threshold); strengthening the unfair practices and access rules; assessing the number of workers in a bargaining unit at the point at which the CAC receives the application; and permitting recognition applications where an employer has an existing agreement with a non-independent union
- industrial action deregulation, including: repealing the 50% and 40% thresholds in ballots and reverting to simple majority voting; reducing the information a union must include on the ballot paper and notice to employers; reducing advance notice of industrial action from 14 to 10 days; extending the expiry of the ballot mandate for industrial action from 6 to 12 months; repealing the 2016 picketing provisions; and introducing electronic balloting
- a new protection against detriment for taking part in industrial action, strengthened protection against blacklisting and extended rules on automatic unfair dismissals for protected industrial action
- new rights and protections for union reps, including new rights for union equality reps and for reasonable accommodation and facilities for reps when carrying out union duties
- repeal of the 2024 changes to public sector employers’ check-off duties and the 2023 minimum service levels legislation
- new powers to create a Fair Pay Agreement (FPAs – a new form of sectoral collective bargaining) in the adult social care sector
What are the next steps?
Some of the industrial action changes take effect two months after royal assent. Repealing the minimum service levels legislation happens immediately on the royal assent. The remaining changes will take longer, reflecting the need for enabling regulations, updated Codes of Practice and further consultation.
These consultations are expected later in 2025 and early 2026, with electronic balloting and changes to the recognition process taking effect in April 2026. The duty to inform workers of their right to join a union, the new right of access and protections against detriment and for reps are expected to be implemented in October 2026 (remaining changes, including to blacklisting, are slated for 2027).
What should employers do now to prepare?
In response to the de-regulation of strikes, unionised employers should review the state of industrial relations, the risk of industrial action and how they can best prepare for situations where it will be simpler and quicker for a union to commence official industrial action.
Unionised employers should also prepare to review and update their facility and time off agreements, reflecting the changes to come.
The new right for unions to access workplaces is a significant change, particularly for workplaces not currently unionised. All employers should prepare for access requests and understand the legal process that will govern such requests and the legal penalties that will apply. The changes to statutory recognition will make it easier, quicker and cheaper for trade unions to apply for recognition and to win a recognition ballot and employers should anticipate an increase in recognition requests.
Adult social care employers should anticipate a lengthy consultation and implementation period, reflecting the complexity and relative novelty of FPAs.
AI in the workplace
Surveillance technologies
In short summary, what is changing?
The government will consult on how these technologies are implemented in the workplace, including the role of trade unions and worker representatives (it is expected to include a duty to meaningfully consult with them).
What are the next steps?
There are no timescales attached to this consultation as yet and it is not expected in the short-term.
What should employers do now to prepare?
Anticipate reform and stay updated. A duty to consult, if included, reflects the direction of travel in recent EU legislation (e.g. on platform workers, which requires employers to involve worker representatives on the use of AI and algorithmic decision-making).
Business immigration
Business immigration
In short summary, what is changing?
In July 2025, the government announced a statement of changes to the Skilled Worker and other work routes. These changes implement the first phase of reforms to work visas which were initially set out in the Immigration White Paper, “Restoring Control over the Immigration System”, published in May 2025. They are due to come into effect from 22 July 2025, and reflect a fundamental shift in how UK businesses can utilise overseas talent.
What are the next steps?
From 22 July 2025, salary changes will take effect increasing the UKVI minimum threshold for:
- new hires from £38,700 to £41,700 and
- for those extending or changing employment in Skilled Worker from £29,000 to 31,300
- Global Mobility Route from £48,500 to £52,500
The SOC Going Rate thresholds are also increasing for both new and current Skilled Workers.
There is also an increase to the required skill level for Skilled Worker visas from RQF Level 3 (approximately A-Level) to RQF Level 6 (approximately graduate level), meaning only graduate positions are now eligible for sponsorship (unless the role is on one of the two new interim shortage occupation lists).
The Social Care Worker visa route will be closed to overseas recruitment meaning sponsors will not be able to sponsor migrants in SOC 6135 Care Workers and Home Carers and SOC 6136 Senior Care Workers after 22 July 2025. In-country switching into these codes will remain possible until 22 July 2028 if certain conditions are met.
What should employers do now to prepare?
Salary reviews - undertake an immediate review of salaries of those on the Graduate Route and Skilled Worker route to identify any employee whose salary will fall below the new minimum thresholds
SOC code reviews – review any commonly used SOC codes to identify if specific areas will be impacted by the uplifted skill threshold
Review recruitment pipeline - any planned new hires will need to satisfy these new Skill and Salary requirements and all offers should be considered to check the new requirements are met
CoS allocation requests – if employers intend on early sponsorship they should have sufficient CoS available and, if needed, request an increase as soon as possible.
Updating policy documents and training - HR and Global Mobility teams should ensure they are up to date with the changes and aware of the new applicable skill and salary thresholds. Template offer letters and immigration policies should be updated to reflect any rule changes regarding dependants and training should be given to those in HR and global mobility.
Enforcing workplace rights: by the state and in tribunals
Single enforcement body
In short summary, what is changing?
A new Fair Work Agency (FWA) bringing together existing enforcement bodies will be established. The FWA will have powers to enforce underpayments such as in respect of the national minimum wage and statutory sick pay, to bring employment tribunal proceedings in place of workers, and to provide legal assistance.
What are the next steps?
The FWA body will be established in April 2026.
What should employers do now to prepare?
Expect a targeted approach to enforcement, including on holiday pay, sick pay and the national minimum wage. Employers should consider undertaking a pay audit of their workforce pay practices to identify and address any inadvertent issues.
Employment tribunal time limits
In short summary, what is changing?
The Employment Rights Bill will increase the time limit for making claims in employment tribunals from three to six months. This would bring the time limit for all claims in line with the time limit for statutory redundancy and equal pay claims (which is already six months).
What are the next steps?
The time limit will be increased in October 2026.
What should employers do now to prepare?
Review litigation strategies and processes. A doubling of most tribunal time limits may lead to an increase in tribunal claims, particularly when combined with changes to the qualifying period for unfair dismissal. However, the longer period also increases expectations that employees act to mitigate their loss, by finding new employment, and could provide extra time for complaints to be settled.
Holiday pay records
In short summary, what is changing?
A new employer duty to keep adequate records to show compliance with statutory annual leave entitlements will be introduced.
What are the next steps?
There are no timescales for this change as yet.
What should employers do now to prepare?
Employers should consider setting up record-keeping systems for statutory annual leave where they do not already exist. According to the legislation, the records may be created, maintained and kept in such manner and format as the employer reasonably thinks fit.
Worker status
Single ‘worker’ status
In short summary, what is changing?
Employers should consider setting up record-keeping systems for statutory annual leave where they do not already exist. According to the legislation, the records may be created, maintained and kept in such manner and format as the employer reasonably thinks fit.
What are the next steps?
There are no timescales attached to this consultation as yet.
What should employers do now to prepare?
Expect a lengthy consultation, reflecting the challenges involved and the need to avoid creating new, inadvertent status litigation risks. If a single worker status is to be created, employers should assess potentially significant changes to staffing models, costs, risks and incentives.
Workers supplied by umbrella companies
In short summary, what is changing?
The Employment Rights Bill will bring umbrella companies within existing regulatory and enforcement frameworks, reflecting government concerns that some are depriving workers of their employment rights. The government’s view is that umbrella companies should be subject to regulation in a similar way to employment businesses. Separately, it is also changing the treatment of PAYE, increasing the responsibility of recruitment agencies that supply workers (engaged by an umbrella company) to the end client. Where there is no agency in a labour supply chain, this responsibility will sit with the end client.
What are the next steps?
The government will consult on these measures in autumn 2025 and implementation will not be until 2027. The tax changes are expected to take effect from April 2026.
What should employers do now to prepare?
Employers should risk assess their direct and indirect use of umbrella companies, including in labour supply chains, taking into account the increasing risk of PAYE responsibility and changes to regulation.
Atypical and casual workers
Zero hour contracts (ZHCs) and guaranteed hours
In short summary, what is changing?
A new duty will require employers to offer qualifying workers on ZHCs and those with a ‘low’ number of guaranteed hours, who work more than these hours, a guaranteed hours contract which reflects the hours they work over a reference period. Provisions also regulate worker acceptance or rejection of the offer. In addition, there is a new duty to provide reasonable notice of shifts for certain workers, including those on ZHCs, and of any changes in shift, together with a right to payment for cancelled, moved or curtailed shifts. There are related worker protection and tribunal enforcement provisions. Following consultation, the government has confirmed that the measures will also extend to agency workers.
What are the next steps?
Further consultation, planned for autumn 2025, will address further details of the new provisions, such as to scope ‘low-hour’ workers, the scope of possible exemptions, and to ensure that, where work is genuinely temporary, there is no duty to offer permanent contracts. Extensive regulations will also provide detail on how the changes will apply in practice. Given these steps, the measures will not take effect until 2027.
What should employers do now to prepare?
While workers may choose to remain on ZHCs if they wish, or alternatively it is possible to contract out of the measures under the terms of a collective agreement, employers should expect increased costs and administration (in particular, due to the duty to offer guaranteed hours, if applicable). As part of assessing their response to these changes, employers may consider moving away from some ZHCs in favour of alternative contractual arrangements. However, they should first assess the Bill’s ZHC contents (and measures in subsequent ZHC regulations) before deciding their response given the scope and complexity of some of the details.
National minimum wage, sick pay and tips
National minimum wage (NMW)
In short summary, what is changing?
The government has already changed the Low Pay Commission’s (LPC) remit, linking the NMW rate to the cost of living.
It will also remove the age bands to equalise the rate for adult workers (removing the band for 18-20 year olds) and has committed to enforcing the payment of NMW for travel time, if applicable.
What are the next steps?
Equalising the adult rate is expected to happen progressively. This reflects the government’s instruction to the LPC to narrow the gap between the NMW 18-20 year rate and the National Living Wage by taking steps, year by year, in order to achieve a single adult rate. It has also asked that the under 18 and apprentice rates are set as high as possible without damaging the employment prospects of each group.
This approach was confirmed when the government announced the rates which apply from April 2025, including a 16.3% increase for 18-20 year olds (with a £10 hourly NMW rate). The rate for 21 years and over will be £12.21.
What should employers do now to prepare?
Expect increased costs and compliance risks. Audit NMW processes, reflecting the complex rules and risks of inadvertent breaches. HMRC’s enforcement policy makes no distinction between deliberate and accidental breaches and non-compliance risks reputational damage, large financial penalties and back pay to affected workers for up to six years.
Tips
In short summary, what is changing?
Employers will be required to consult with trade union/worker reps (or affected employees if no reps are in place) before producing the first version of a written tipping policy and to review the policy at least once every three years and in consultation with reps or affected employees.
What are the next steps?
The government plans to consult in late 2025 or early 2026 and will implement the measures in October 2026.
What should employers do now to prepare?
Anticipate scheduling review dates on written tipping policies and allow for consultation with appropriate representatives/affected employees as part of that review.
Statutory sick pay (SSP)
In short summary, what is changing?
SSP will be available from the first day of illness, removing the current three day waiting period. In addition the current lower earnings limit (£125 per week) will be removed, making SSP available to lower paid employees. The rate of SSP will be set at either the flat rate in force from time to time (currently £118.75 per week) or 80% of the employee’s average weekly earnings, whichever is lower.
What are the next steps?
This will take effect from April 2026.
What should employers do now to prepare?
Budget for increased SSP costs from April 2026 if employers do not pay enhanced company sick pay. Review sickness absence policies and ensure managers are adequately trained on managing short-term sickness absence, levels of which may rise as a result of these changes.
Restructuring and dismissal
Day one unfair dismissal rights
In short summary, what is changing?
The existing two-year qualifying period will be removed for claims of ordinary unfair dismissal. During an “initial period of employment” (and during the period of three months after the end of that period if the employer has given notice of termination before the end of the period), the test for a fair dismissal will be modified to allow employers to terminate employment more easily for conduct, capability, illegality or some other substantial reason (SOSR) relating to the employee (it should be noted that such reasons do not include redundancy, or SOSR unrelated to the employee).
What are the next steps?
The government will consult this summer or autumn on the modified dismissal process, the duration of the “initial period” (with its stated preference currently being 9 months), how that interacts with the Acas Code of Practice on disciplinary and grievance procedures and the compensation regime for successful claims arising out of the termination of employment during the initial period, which is expected to be subject to a compensation cap. The reforms to unfair dismissal will not come into effect before 2027.
What should employers do now to prepare?
Review recruitment practices, including current probationary periods (and how they are monitored and extended), dismissal processes and prepare to amend contractual clauses, performance management/probationary procedures and manager training to meet the new requirements. Prepare for an increase in unfair dismissal claims and consider how to resource their management.
“Fire and rehire”
In short summary, what is changing?
Where an employee is dismissed for failing to agree to contractual variations of a particular kind (a “restricted” variation), or to enable the employee to be re-engaged or replaced by another employee under a varied contract, which must include a restricted variation, that dismissal will be treated as automatically unfair. A “restricted” variation includes reductions in an employee’s pay or time off, and changes to working hours, pensions or shifts. However, it will not be automatically unfair if the reason for the variation was to eliminate, prevent or significantly reduce/mitigate financial difficulties affecting the employer’s ability to operate as a going concern and it could not reasonably have avoided the need to make the variation (local authorities and public sector employers are subject to different financial hurdles). An employer will also risk an automatic unfair dismissal in situations where employees are dismissed and the principal reason is to replace them with agency workers or contractors – workers who are not employees. There are a number of relevant factors to be considered when assessing fairness of ”fire and rehire” dismissals (whether a restrictive variation or not), including the level of consultation carried out.
What are the next steps?
A consultation is expected in autumn 2025 and the measures will take effect in October 2026.
What should employers do now to prepare?
The changes will significantly limit an employer’s ability to enforce contractual change (in the absence of agreement), notably to pay, hours and holiday provisions, reflecting the introduction of “restricted” variations. An employer that fails to evidence sufficient financial difficulties and/or acts unreasonably, as assessed under the statutory provisions, risks being subject to significant financial penalties and legal risks. As a result, the wording of contracts, the offer of employee incentives, consultation processes, negotiation strategies and the potential replacement of employees with contract labour will all need to be carefully considered in this context.
TUPE
In short summary, what is changing?
The Employment Rights Bill provides powers to reinstate and strengthen the ‘two-tier’ Code of Practice (subject to devolved arrangements in Wales and Northern Ireland), which applies where certain workers are transferred from the public to the private sector and work alongside private sector employees, and is aimed at both sets of workers not being treated less favourably.
What are the next steps?
The two-tier Code will take effect in October 2026.
What should employers do now to prepare?
These changes will have significant implications for affected employers. Employers should also note that the government has committed to: reviewing “a wide variety of issues relating to TUPE regulations and process, including how they are implemented in practice”; and extending the Freedom of Information Act to apply to private contractors providing public services and to publicly funded employers.
Collective redundancies
In short summary, what is changing?
The duty to collectively consult on redundancies will be widened. The trigger for consultation will be either 20 or more employees at one establishment, or, in a case where employees are being made redundant at more than one establishment, a higher number (that number to be determined in regulations). The HR1 notification (to the government) trigger will also be similarly amended. Employer penalties for a failure to consult collectively will increase, with the maximum protective award rising from 90 days’ to 180 days’ pay. Changes are also made to collective redundancy notifications for ships’ crew.
What are the next steps?
The doubling of the maximum protective award takes effect in April 2026 and the new threshold, for triggering consultation, in 2027. Acas and government guidance, and the form HR1, will require updating.
What should employers do now to prepare?
Increasing the maximum protective award will introduce significant new risks for a failure to comply with collective consultation and employers should review their redundancy processes. The new threshold will require pro-active assessment of all redundancies across the employer. It may also result in more collective consultation, involving workplace representatives and trade unions, and employers should consider how they will manage any such increase. The legislation does confirm that employers are not required to consult all representatives together, or to consult with a view to reaching the same agreement with them all (presumably where the reasons are unrelated).
Health, safety and wellbeing at work
Health and safety (H&S) review
In short summary, what is changing?
The government has stated that it will review, and modernise, existing H&S regulation, including taking steps to strengthen the H&S rights of the self-employed, to address the needs of a diverse workforce and extreme temperature risks at work.
What are the next steps?
The timing of the review is currently unclear.
What should employers do now to prepare?
Stay updated with developments and expect a consultation before any changes are introduced.
ESG and sustainability: employment policies
ESG and sustainability: employment policies
In short summary, what is changing?
The government is reviewing how it might strengthen corporate transparency and accountability in relation to modern slavery and trafficking risks, in companies’ operations and supply chains. In March 2025, it strengthened its expectations of businesses in its guidance (Transparency in supply chains: a practical guide).
What are the next steps?
The timing is unclear and the government has said it will set out next steps in due course.
What should employers do now to prepare?
There is a growing pressure on the government to act, further to parliamentary investigations into forced labour risks. Employers should expect some changes, for example, to strengthen the enforcement of modern slavery reporting obligations.
Pensions
Pensions review
In short summary, what is changing?
The Pension Schemes Bill contains a number of major reforms to implement the government’s vision for workplace pensions in the UK.
In particular, the Bill contains measures which will:
- require trustees of schemes that provide money purchase benefits to offer a default retirement solution that provides regular income in retirement to their members (either within the scheme or via an arrangement with an external scheme or provider), and
- introduce a regime to require schemes to automatically consolidate small pension pots (worth less than £1,000) which remain left behind when individuals change jobs
To deliver the government’s vision of having fewer, larger, better run workplace pension schemes, the Bill will also introduce new scale requirements for master trusts and group personal pension plans that are used by employers for automatic enrolment. Broadly speaking, from 2030, these schemes will be required to have at least £25bn worth of assets in their largest default fund in order to continue to be able to be used as an automatic enrolment scheme.
The Bill will also make important changes affecting defined benefit (DB) schemes. In particular, it will introduce more flexibility over when surplus assets within a DB scheme can be returned to the sponsoring employers while the scheme is ongoing.
The government has concluded phase one of its pensions review which focused on how to drive scale within the workplace DC pensions market and the local government pension scheme with a view to increasing investment in UK private assets and boosting member outcomes. The final report was published on 30 May 2025 and many of the recommendations are reflected in the Pension Schemes Bill.
In the final report the government confirmed it does not intend to take forward proposals to require employers to regularly review their workplace pension arrangements or to nominate an executive at board level who is responsible for the retirement outcomes of staff.
The government has confirmed it plans to launch phase two of the review, which will be more wide-ranging and consider issues such as how to ensure people are saving enough for their retirement, in the coming months.
What are the next steps?
The Pension Schemes Bill is now going through the Parliamentary process and changes may still be made to the legislation. It is expected it will receive Royal Assent in 2026.
Many of the reforms contained in the Bill will require secondary legislation. The government has published a roadmap which sets out when it anticipates the various reforms to workplace pensions will be implemented.
The government has said it will confirm the scope of phase two of its pensions review and who the reviewers will be in due course.
What should employers do now to prepare?
Employers should consider how their pension arrangements may be impacted by the reforms due to be implemented through the Pension Schemes Bill.
Employers with DB schemes that are in surplus on a low dependency basis may also want to consider whether they can use the proposed new flexibilities to make use of the surplus within their scheme.
Employers should be ready to engage with phase two of the pensions review, which will consider (among other things) whether the employer and member auto-enrolment minimum contribution rates should be increased and, if so, when.
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