From 30 October 2026, every employer has to take all reasonable steps to prevent sexual harassment at work, and that includes harassment of your staff by customers, clients and anyone else they deal with. It applies whether you employ three people or three hundred.
When I talk to business owners about this, the reaction is often "that would never happen here". I hope that's true, but the law now asks you to show you've thought about it and acted, rather than waiting for something to go wrong. The good news is that for a small business, the steps are sensible and very achievable.
What's actually changed?
Since 2024 you've had a duty to take reasonable steps. Adding the word "all" raises the bar, because a tribunal will now ask whether there was anything else you reasonably could have done. The other big change is that you can be held responsible when someone outside your business, such as a customer or a client, harasses one of your team and you hadn't taken those steps.
What "reasonable" looks like in a small business
Nobody expects you to behave like a large corporate with a full HR department. What you do need is to think about your own workplace and put a few things in place:
- Think about where the risks are. Late finishes, lone working, client entertaining, the Christmas do and work group chats are all common places for problems to start, so spend half an hour writing down where they might crop up for you and what you'll do about them.
- Have a short, clear policy. It should explain what harassment is, make it clear it won't be tolerated, and tell people exactly how to raise a concern. One or two pages written in everyday language is far better than a long document nobody reads.
- Give people more than one way to speak up. If every complaint has to go through you or one manager, some people will stay quiet, so a second contact or an outside HR adviser makes a real difference.
- Talk to your team about it. A short session or team conversation, with your managers knowing how to respond if someone comes to them, counts for much more than a policy sitting in a drawer.
- Keep a simple record. Note what you've done and when you last reviewed it, so you can show your steps if you ever need to.
Customers and clients
This is the part most businesses haven't thought about yet. If your team deals with the public or visits clients, decide now what you'd do if a customer crossed the line. Let your staff know they can walk away from an uncomfortable situation and that you'll back them when they do, and be prepared to have a word with the client or customer concerned.
If someone does raise a concern
Take it seriously, thank them for telling you, and act quickly and fairly. Listen to everyone involved, keep things as confidential as you can, and make sure the person who spoke up isn't treated any differently afterwards. How you respond in those first few days says far more about your workplace than any policy ever will.
If you'd like help with a risk assessment, a policy or a short training session for your team, in Milton Keynes or online, book your free 30 minute HR chat. You can also read about our people management training.
This article is general guidance rather than legal advice, and reflects the law at the date of publication.