Employment Update: News in Brief | Autumn 2025

A round-up of key developments in employment law

Employment Rights Bill in its final stages

The Employment Rights Bill, which will bring forward a wide range of employment law reforms, is now in the final stages of consideration in Parliament. A number of significant amendments were agreed by the Lords, but these have since been rejected by the Commons. The bill has now been listed for further consideration in the Lords on 23 October. If the Lords back down, we should expect to see Royal Assent shortly after. If they do not, there may be a period of so-called ‘ping pong’, where the bill is passed between the houses until agreement is reached.

Read our blog on the key dates and what employers need to do to prepare.

Revised EHRC services code handed to Minister

The Minister for Women and Equalities has been handed the revised draft EHRC Code of Practice on services, public functions and associations. The code covers discrimination, harassment and victimisation in services and public functions. It will now be considered by the government and, once it has ministerial approval, will be laid before Parliament for 40 days before it comes into force. Service providers must nevertheless ensure they are currently complying with their legal responsibilities and should not wait for the revised services code to be published.

New corporate fraud prevention offence in force

The Economic Crime and Corporate Transparency Act 2023 (ECCTA) establishes new offences for directors and companies, as well as new rules relating to the mandatory identity verification of directors. From 1 September, large organisations may be held criminally liable where an employee, agent, subsidiary or other ‘associated person’ commits a fraud intending to benefit the organisation. The new legal requirement for new directors and people with significant control (PSCs) to verify their identity, and the 12-month transition plan for existing directors and PSCs to verify their identity, will begin on 18 November 2025, as confirmed by Companies House.

Call for evidence on unpaid internships ends

The government’s call for evidence on unpaid internships, unpaid work trials, voluntary work and work shadowing as part of its Make Work Pay agenda closed on 9 October 2025. One area under consideration is whether to remove the exemption from the national minimum wage for students at UK institutions who are required to undertake a mandatory work placement of up to one year as part of their course. Conversely, UK and international students are entitled to the national minimum wage if the internship is part of an educational course based outside the UK.

The government’s response is expected in early 2026.

Changes to the law on non-disclosure agreements now in force

The law on non-disclosure agreements (NDAs) changed on the 1 October 2025, meaning that NDAs cannot validly prevent a victim of crime from reporting the crime to the police or from disclosing details of the crime to certain bodies and professionals to get confidential advice or support. Victims who sign NDAs may disclose information about relevant criminal conduct to qualified lawyers, regulated professionals including healthcare workers, victim support services, regulators, and close family members for specified purposes. These changes apply only to NDAs signed from 1 October 2025 onwards, with earlier agreements remaining subject to previous rules. The Ministry of Justice has published guidance for victims and individuals who use NDAs, explaining the practical implications of these statutory changes for confidentiality agreements.