October Starts Tomorrow. Here's Your Ten-Minute Checklist

Well, here we are. Tomorrow the month turns, and the first of this autumn's employment law changes lands with it. If you've been following along this month, none of it should come as a surprise. If you've only just tuned in, take a breath. There's still time to get the essentials in place, and this piece is here to help you do exactly that.

One thing to be crystal clear about before we go any further, because plenty of write-ups have blurred it and I don't want you working to the wrong deadline. October's changes do not all land tomorrow. Tomorrow, 1 October, two things happen: tribunal time limits double from three months to six, and right to work checks expand well beyond employees. That's it for the 1st. The harassment cluster, which is the bigger job for most small businesses, lands four weeks later on 30 October, along with the trade union changes.

Which is mostly good news. The tribunal change asks nothing new of you on the day, and you have a full month to finish the work on the harassment duty. The right to work change is the one that actually needs a decision from you tomorrow, and I'll come to it in a moment.

Think of this as your one-page recap. Not new information, but everything from the past few weeks pulled together into a calm, final run-through. Read it, tick off what you've done, note what you haven't, and go into October knowing where you stand. That's the whole aim: not perfection, but confidence that the important things are handled.

The changes landing in October, at a glance

Here's the cluster, one more time, sorted by the date it actually happens.

Tomorrow, 1 October 2026

Tribunal time limits double. Most claims move to a six-month window instead of three, which means twice as long for a claim to come around and twice as long your records need to hold up. Nothing to switch on, nothing to write. It simply changes how long everything you do from here has to stand up. That applies across England, Wales and Scotland from tomorrow. The one narrower Scottish date is 9 November 2026, which is when breach of employment contract claims in Scotland move to six months, and it's being widely misreported as the Scottish start date for everything. It isn't. One more detail worth holding on to: the new limit applies where the relevant event happens on or after 1 October, so anything that happened in September keeps the old three-month clock on it.

Right to work checks expand. Section 48 of the Border Security, Asylum and Immigration Act 2025 comes into force tomorrow, and it takes the duty to check beyond employees to workers, individual subcontractors and people engaged through online matching platforms. Liability can also reach down a subcontracting chain, so you can be responsible for someone you never hired, including a substitute sent in place of the person you booked. Genuinely self-employed people running their own business and contracting directly with you as a customer stay outside it, but the label on the contract doesn't decide that, the reality of the arrangement does.

This is not a demand to re-check your whole workforce overnight. It applies to new engagements from tomorrow and to repeat checks falling due after that date. So the job for tomorrow morning is small and specific: know who does work in your name, know who has never been checked, and make sure nobody new starts without one. There's a full piece on the blog from the 21st walking through it properly, and note the Codes of Practice are still in draft, so some detail will firm up over the coming weeks.

Four weeks later, 30 October 2026

The harassment duty gets stronger. You'll have to take all reasonable steps to prevent sexual harassment, not just reasonable steps. That upgrade is specific to the preventative duty on sexual harassment. The bar rises, and you'll be expected to show your thinking.

Third-party harassment becomes your responsibility. Employers can be liable for harassment of their staff by customers, clients, contractors and members of the public, not just by colleagues. This one is broader than the duty above: it covers harassment related to any protected characteristic, so race, disability, age, religion or belief, sex, sexual orientation and gender reassignment are all in scope, not only sexual harassment. And the old "three strikes" rule, where it had to have happened twice before, has gone.

The honest caveat on all of that. The regulations setting out what actually counts as reasonable steps are expected in 2027, after a public consultation. So you're being asked to meet the higher standard from 30 October, before the detail defining it exists. That isn't a reason to wait. It's a reason to do the obvious, proportionate things now and write them down, because "we did what a sensible employer would do, and here is the evidence" is the defence either way.

Trade union changes. A new duty to tell workers about their right to join a trade union, alongside strengthened access rights.

Later in the year, not October

Tipping. If you handle tips or service charges, you'll need to consult your workers before setting or changing a tips policy. That duty is expected by the end of 2026 rather than this month. The earlier draft Code of Practice was pulled after criticism, but its replacement has already been and gone: the revised draft statutory Code on the fair and transparent distribution of tips opened on 19 August and closed to responses at 11.59pm last night. The final version is what you'll be working to, so watch for it.

So: one change tomorrow, three on the 30th, and one still to come. Now let's make sure you're ready for all of it.

Your final checklist

Work down this list and be honest with yourself. Anything you can't tick is simply your priority for the first days of October, not a reason to panic.

Harassment and dignity at work

Your anti-harassment policy is up to date and reflects the "all reasonable steps" standard.
It clearly covers third-party harassment, so customers, clients and contractors are named, not just colleagues.
Your team actually knows the policy exists and knows they're protected, because you've told them, not just filed it.
Your managers know how to receive and handle a concern calmly and fairly.
There's a safe, credible route for someone to raise a concern, especially if it involves a senior person. Remember that since April, reporting sexual harassment can count as whistleblowing, so how you handle these reports really matters.

Right to work (live from tomorrow)

You have a written list of everyone who does work in your business's name, including casual staff, self-employed regulars, subcontracted trades, couriers, chair renters and agency placements.
You know which of them have had a right to work check and where the evidence is kept.
Nobody new starts from tomorrow without a check, whatever their contract is called.
Your subcontractor and agency contracts require checks, let you see the evidence, and say what happens if a substitute turns up.
One named person in your business owns this, so it doesn't fall between operations and whoever does the hiring.

Records and process

You have a consistent, documented process for disciplinary, grievance, absence and dismissal, and you follow it every time.
Notes are written at the time, not reconstructed later, and they're kept somewhere you can find them.
Absence issues are handled through a fair process with occupational health where needed, never through shortcuts or surveillance.
People get a fair hearing and a proper right of appeal.

Tips and unions (if they apply to you)

If you handle tips, you have a plan to consult workers before setting or changing your tips policy.
Your written statements and onboarding materials mention the right to join a trade union.

The September consultations, and the one that closes tonight

Three have now closed: holiday pay compliance and enforcement on 22 September, the Acas draft Code of Practice on disciplinary and grievance procedures on 23 September, and the revised tipping Code of Practice last night.
One is still open, and only until 11.59pm tonight. The workplace monitoring technologies consultation covers the fair, transparent and responsible use of technology used to monitor, manage or make decisions about workers. If you use tracking, cameras or AI anywhere near managing people, you have this evening to say what would and wouldn't work in a business your size.
Still open past tonight: equal pay and pay discrimination, which closes at 5pm on 27 October 2026 and covers pay gaps affecting disabled people and people from ethnic minority backgrounds, pay transparency and outsourced workers.
One line to file away. The Fair Work Agency is now a body that prosecutes, having secured its first conviction and its first Labour Market Enforcement Order in July, and it is being lined up to enforce statutory holiday pay. Holiday pay is the thing small businesses most commonly get slightly wrong, so if yours has been quietly approximate for years, this is the moment to fix it.

The bigger picture

You know where your genuine gaps are, and you've got a date against fixing each one.
If anything sizeable is on the horizon, such as larger-scale redundancies, you've noted to take advice early, because the rules and penalties around consultation are stricter than many expect.
Your team is already using AI at work, and you've decided what your rules on it are. If nothing is written down, that's a short readable policy rather than a big project, and there's a separate piece on the blog this week walking through the four real risks and what to put in it.

If most of that is ticked, you're in good shape. If several items aren't, that's completely normal, and it's exactly the sort of thing that's very manageable with a bit of focused help.

Two or three things to do first

If the list above has left you with more gaps than you'd like, don't try to fix everything at once. Some things matter more than others, and a bit of prioritising will get you to safe ground quickly.

Start with your reporting route, because it protects your people and gives you the record you now need. If someone had a serious concern this week, would they have somewhere safe and credible to take it? If the honest answer is no, that's your first job.

Next, make sure your team actually knows about the harassment protections, including the new third-party duty. A quick, warm team message telling people they're protected and that you want to hear about problems is worth more than a fifty-page policy no one reads. It's also, in itself, one of those "reasonable steps" you're now expected to be able to show.

And if the honest answer to "would my managers know what to do?" is "they'd wing it", the first block of Cake, Coffee and Compliance starts on Tuesday 13 October. It's an hour a week of practical HR and employment law training for line managers, with a real document to keep at the end of every session, and it puts the harassment sessions in front of them with time to spare before the 30th.

Then turn to your records. Pick your most recent tricky case, absence, disciplinary or grievance, and check whether the notes and decisions would still make sense to a stranger in six months' time. If they wouldn't, that tells you where to tighten up going forward. You can't rewrite the past, but you can make sure everything from here is clean.

Everything else on the checklist can follow in the first couple of weeks of October. Getting these first few right means the important protections are in place from day one.

A calm word about doing this every year

Here's something worth saying out loud as the month turns. October 2026 is a big moment, but it isn't the end of the story. Employment law keeps moving. More of the Employment Rights Act phases in through 2027, and the big one lands on 1 January 2027, when the unfair dismissal qualifying period drops from two years to six months, the compensation cap is removed, and fire and rehire becomes automatically unfair. Anyone hired since 1 July 2026 is already inside that window. There will be another cluster, and another checklist, and another autumn of getting ready.

I don't say that to tire you out. I say it because it points to something important: keeping up with all of this, on top of actually running your business, is a genuine job in itself. The businesses that handle change well aren't the ones that scramble heroically each time a deadline looms. They're the ones who have steady support in place, so that when something new lands, it's already being watched, planned for and handled long before it becomes urgent.

You don't have to carry this alone, and you certainly don't have to become an employment law expert on top of everything else you do. That's what having HR in your corner is for.

Going into October ready, not rushed

If there's one feeling I'd want you to take into tomorrow, it's calm. Not because the changes are trivial, but because you've had a runway, you've done the thinking, and the essentials are within reach. A clear policy, a safe way to speak up, fair and well-recorded processes, and managers who know what to do. Get those right and October is just another month, handled.

For what it's worth, I've spent years explaining these changes in plain English across the national and trade press, from the Guardian and GB News to People Management, and the coverage lives on our press page. The through-line is always the same: prepared businesses barely feel these changes at all.

If you'd like an honest picture of where you actually stand against everything above, our free HR Health Check is the calm place to start. It tells you which of these changes you genuinely need to worry about and which ones you've already got covered, which is a much better use of October than worrying about all of them equally.

And if you'd rather not face the next round of changes on your own, that's the whole point of ongoing support: someone keeping an eye on what's coming so you can get on with running your business. Our service plans set out how steady, sensible HR support could work for you, and let's make the autumn a calmer one.