The legal position
Acas states that from 30 October 2026 employers will be liable for harassment by third parties unless they have taken all reasonable steps to prevent it. Third parties can include customers, clients, service users and contractors. The current and forthcoming frameworks must be distinguished: this article is a preparation briefing as at 20 September 2026. The appropriate preventive response depends on the organisation’s work and risks.
Source and attribution [1]Using it in practice
Map where staff interact with third parties, including online channels and events. Ask workers about recurring situations and barriers to reporting. Review escalation routes, manager responses and commercial arrangements. Make responsibilities clear across HR, operations, security and procurement. Test whether a worker can get help in a realistic incident instead of relying on a policy’s existence as evidence that the system works.
An example, not a reported case
Worked example · illustrative
A hospitality business has a policy against harassment but staff are uncertain when they can stop serving an abusive customer. The preparation project clarifies escalation, manager authority and support after an incident. It also reviews repeat customer behaviour and how incidents are recorded. The team checks that sales pressures do not quietly undermine the stated standard.
What to watch for
Recheck commencement and final guidance before relying on a future rule. This overview does not replace existing duties or justify waiting until October to address harmful conduct.
Take it into your next conversation
Three useful questions.
- Where do third-party risks arise?
- Can a worker get immediate support?
- Do commercial incentives contradict the policy?
Go to the evidence
Sources & attribution
[1] Acas. Harassment law changes: third-party harassment. ↗
Official guidance supports the legal overview. Application notes and examples are original editorial material, not individual legal advice. Check the linked source for changes and the full qualifications.
Published 2026-09-20 · Reviewed 2026-09-20. Editorial approach