Employment, contingent workforce and immigration | UK Regulatory Outlook July 2025

Employment 

Employment Rights Bill: Government publishes roadmap to implementation 

On 1 July, the government published its roadmap for implementing the Employment Rights Bill to provide "clarity for workers and businesses on how and when Government will engage and consult on those details", together with anticipated commencement dates for different parts of the bill.  

The roadmap stresses that "employers, workers, trade unions and other stakeholders should, and will, get a proper amount of time to prepare for the Make Work Pay reforms while ensuring we deliver tangible, and much needed benefits to working people at pace". 

Headline proposed implementation dates are that April 2026 will see reforms to statutory sick pay, simplification of the trade union recognition process and day one paternity and unpaid parental leave rights coming into force. 

Under current proposals, these will be followed, in October 2026, by changes to the fire and rehire rules, strengthening of trade unions' right of access, and changes to employment tribunal time limits. The changes to unfair dismissal, requirements around gender pay gap action plans and reforms to tackle exploitative zero-hours contracts, and oblige hirers to offer agency workers guaranteed hours, will not now happen until 2027. 

Indicative 'consultations' timetable 

As anticipated, the roadmap confirms that, for many measures, the government will consult on the detail of policy and implementation. Following consultation, it will develop final policy positions to deliver on its measures. The roadmap notes that, in some instances, this will be regulations, and in others, guidance or codes of practice by the government or others such as Acas. 

Some measures may require more than one round of consultation, particularly if there is a need to update or develop a code of practice. The consultations will be sequenced to enable meaningful consultation to take place. 

For a list of measures on which the government intends to consult, see our Insight. 

Indicative 'commencement dates' timetable 

The roadmap states that commencement timings will be informed by the insights from consultation and engagement with the government seeking "to further understand impacts related to commencement" and ensuring that "employers, workers, trade unions and other stakeholder are given time to prepare for change".  

The government plans to use common commencement dates for the majority of regulations laid using the powers provided for in the bill – these will be 6 April and 1 October. 

For a list of which key policy areas and points at which it is the government's "initial view" they will take effect, see our Insight. 

What does this mean for employers? 

The government's roadmap highlights the work that is needed to implement such wide-ranging and significant employment law reforms. It has restated its wish to work with all stakeholders and to ensure that "there is a proper business readiness so that businesses and organisations fully understand the details of our reforms and can prepare long before they come into force". It has also committed "to ensuring the enforcement landscape has the necessary capacity and capability to uphold the new requirements" which will "include support for Acas, the employment tribunal system and the new Fair Work Agency".  

The government has also committed to producing guidance (by it or via other organisations, including Acas) to clarify new requirements and help users to support compliance and which may also be accompanied by further consultation. 

We are currently updating our dedicated microsite to reflect the government's roadmap. If you do have any questions on the government's employment law reforms and the implications for your organisation, please speak to your usual Osborne Clarke contact. Our workforce solutions team look at what the roadmap means for suppliers and users of contingent workforces in light of the significant reforms proposed in this area. 

Umbrella tax legislation – draft legislation due to be published on 21 July 2025 

The government is expected to publish draft legislation relating to how the tax liabilities of umbrella companies and employers-of-record can pass up the supply chain to staffing companies, and in some cases end hirers.  

The new tax regime is expected to come into force in April 2026 and is expected to force a complete redesign of labour design arrangements in some sub-sectors where aggressive tax avoidance schemes have been common. This includes health, care, logistics and construction. How hirers in those industries engage staff will have to be rethought and this may in many cases lead to substantial additional labour costs. We expect a lot of analysis and restructuring to take place in the last quarter of 2025 to prepare for this. 

New corporate offence: failure to prevent fraud 

The new failure to prevent fraud offence in the Economic Crime and Corporate Transparency Act 2023 will come into effect on 1 September 2025. The offence holds companies accountable for fraudulent activities carried out by associated persons for their benefit and understanding the implications and preparing for compliance is crucial. 

To defend a claim under the Act, a commercial organisation must demonstrate that it had reasonable procedures in place to prevent fraud. The starting point for this will be for a business to conduct an objective and proportionate risk assessment to identify any fraud risks that it may face and take appropriate steps accordingly.  

The risk assessment should then be repeated at regular intervals, including where developments in the business may alter the overall risk profile of the organisation. You can read more in our latest Insight. Employers should ensure that relevant documentation (including employment contracts and applicable policies and procedures) are updated and that up to date, appropriate and effective training is provided, particularly for employees in high-risk positions.  

If you would like to understand more about the new legal obligations and how we can support you with compliance, please contact Jeremy Summers, partner in our commercial disputes team, or your usual Osborne Clarke contact who will be happy to assist. 

Immigration 

Reforming the immigration system: immigration white paper May 2025 

We previously covered the immigration white paper in the May 2025 edition. To assist with tracking developments, we have created an online hub: the UK Immigration white paper tracker, as discussed in our recent Insight.   

The four main areas currently in consideration are: 

• reform focusing on language proficiency, high-talent routes, and skills integration;
• opportunities for skilled workers and changes to the Regulated Qualifications Framework;
• amendments to student and graduate visas; and
• timelines for the reforms.