Updated: June 2026 • Based on UK Law
What Is a Sexual Harassment Risk Assessment?
A sexual harassment risk assessment is a written record that identifies where and how workers could face sexual harassment — including from third parties such as clients, customers or contractors — and sets out the controls and actions an employer puts in place to prevent it.
This guide covers the new employer duty, what counts as sexual harassment, what to assess across your workforce and third parties, and the 2026 changes.
Picture a complaint landing on your desk: a worker was harassed at the office party, and now asks what you did to prevent it.
Since 26 October 2024, dealing with it after the event is no longer enough — the law now expects you to prevent it.
✓ Create your sexual harassment risk assessment with our template. It guides you through workforce, environment and third-party risk factors, builds your risk register of controls and actions, and records assessor and senior-management sign-off — in a guided interview or a classic editor, with identical output.
Preview the bespoke document in full before you buy. → Sexual Harassment Risk Assessment Template
The New Sexual Harassment Law in the UK
UK employers now have a positive, ongoing duty to prevent sexual harassment — not simply to respond to it after the event.
Two pieces of legislation matter here.
- Worker Protection (Amendment of Equality Act 2010) Act 2023 — in force since 26 October 2024. It added section 40A to the Equality Act 2010, requiring employers to take reasonable steps to prevent sexual harassment of their workers.
- Employment Rights Act 2025 — from October 2026, this raises the bar to “all reasonable steps” and reintroduces employer responsibility for harassment by third parties.
The duty is anticipatory. You are expected to look ahead, spot where harassment could happen, and act before anyone is harmed.
That is exactly why a risk assessment sits at the centre of the Equality and Human Rights Commission (EHRC) expectations.
What Legally Counts as Sexual Harassment at Work
Sexual harassment is defined in section 26 of the Equality Act 2010.
It means unwanted conduct of a sexual nature with the purpose or effect of violating a worker’s dignity.
It also covers conduct that creates an intimidating, hostile, degrading, humiliating or offensive environment for them.
It can be verbal, non-verbal or physical. Common examples include:
- Sexual comments, jokes or “banter”
- Unwanted touching, hugging or invading personal space
- Suggestive looks, gestures or messages
- Displaying sexual images, or sending explicit messages online
- Intrusive questions about someone’s private or sex life
It does not depend on intent. “It was only a joke” is no defence if the conduct had that effect on the worker.
Crucially, the conduct does not have to come from a colleague.
It can come from a client, customer, patient, contractor or visitor — which is why third-party risk belongs in your assessment.
Why a Risk Assessment Matters Now
The EHRC, which enforces the duty, treats risk assessment as a core part of meeting it.
Reacting after a complaint is not enough. You are expected to anticipate risk and act first.
The stakes are real:
- Compensation uplift. Where an employer has breached the duty, a tribunal can increase a sexual harassment award by up to 25%.
- Uncapped awards. Compensation for harassment under the Equality Act 2010 has no upper limit.
- EHRC enforcement. The Commission can investigate and require an employer to put an action plan in place.
A documented, dated and reviewed risk assessment is how you evidence the steps you have taken.
It does not, by itself, decide whether those steps were enough — a tribunal judges that on the facts. But without one, you have little to show.
What to Assess: Workforce, Environment & Third Parties
A useful sexual harassment risk assessment looks across three groups of risk factors.
Workforce factors
- Power imbalances between senior and junior staff
- Lone, night and shift working
- Younger, new, agency or casual workers
- Isolated roles with little day-to-day supervision
Environment factors
- Work social events where alcohol is present
- Isolated areas, or a culture of “banter”
- Online channels and messaging apps
- Remote and hybrid working
Third-party factors
- Clients, customers and members of the public
- Patients and service users
- Contractors, suppliers and visitors
For each risk, you record how likely and how serious it is, what you already do about it, and whether that is enough.
How to Carry Out a Sexual Harassment Risk Assessment
The process follows the same logic as any workplace risk assessment.
- Record your organisation details and the worker types you cover, including agency and contract staff.
- Identify the risks across the workforce, environment and third-party factors above.
- Rate each risk by likelihood and severity to give an overall risk rating.
- Record current controls — policy, reporting routes, training and supervision — and judge whether each is adequate.
- Set further actions, each with a named owner and a target date, wherever a control falls short.
- Sign off and set a review date. The assessor and a senior manager should sign, and you should review at least annually or after any incident.
Keep it live. A risk assessment that sits in a drawer does not evidence an ongoing duty.
What’s Changing from October 2026
The Employment Rights Act 2025 tightens the duty in stages. Three changes matter most for your risk assessment.
- All reasonable steps (October 2026). The duty rises from “reasonable steps” to “all reasonable steps” — a higher bar. A policy on its own is unlikely to be enough.
- Third-party harassment (October 2026). Employers become liable where a third party harasses a worker and all reasonable steps were not taken. Public-facing sectors are most affected.
- Whistleblowing (from April 2026). A worker’s report of sexual harassment now counts as a protected disclosure.
Regulations setting out exactly what “all reasonable steps” means are expected in 2027.
Building third-party risk into your assessment now means you are already preparing for the higher standard.
Frequently Asked Questions
What is the new harassment law in the UK?
Since 26 October 2024, the Worker Protection (Amendment of Equality Act 2010) Act 2023 has applied.
It requires UK employers to take reasonable steps to prevent sexual harassment of their workers.
From October 2026, the Employment Rights Act 2025 raises this to “all reasonable steps”.
It also reintroduces employer responsibility for harassment by third parties such as customers and contractors.
What qualifies as harassment in the UK?
Under the Equality Act 2010, harassment is unwanted conduct that violates someone’s dignity.
It can be related to a protected characteristic, or be of a sexual nature.
It also covers conduct that creates an intimidating, hostile, degrading, humiliating or offensive environment.
It is judged by the effect on the worker, not the intent behind it.
What are the 4 D’s of bystander intervention?
The 4 Ds are Direct, Distract, Delegate and Delay — four ways a bystander can step in safely when they witness harassment.
Training staff to use them is a practical, low-cost step you can take as part of preventing sexual harassment.
Pair it with clear reporting routes and a policy.
Do I need a consultant or solicitor to carry out a risk assessment?
Many businesses complete a standard risk assessment without one.
Our template is based on UK law and guides you through the standard risk areas, controls and review dates.
Consider specialist HR or solicitor review for complex, high-risk or large-scale operations.
How often should I review my risk assessment?
Treat it as a living document. Review it at least once a year, and again whenever your workforce, premises or working arrangements change.
You should also review it after any incident or near-miss, and as the October 2026 changes take effect.
What’s the difference between a risk assessment and an anti-harassment policy?
They do different jobs. The risk assessment identifies where harassment could happen and what you will do about it.
An anti-harassment policy sets the rules, reporting routes and consequences. The EHRC expects both as part of taking reasonable steps.
The Truth About “Free” Legal Template Sites (What You’re Really Signing Up For)
Most websites offering a “free legal template” follow the same pattern:
- You click because it’s advertised as free
- You spend 10–15 minutes answering questions
- At the very end, you must create an account or start a “free trial”
- Your card is required upfront
- The subscription auto-renews at £29–£39 per month
This isn’t a free template – it’s a subscription service. Many people only realise after being charged £300–£400 over the year.
Why These “Free” Templates Are a Legal Risk
- Outdated wording: not aligned with current UK law
- Missing mandatory clauses: required for legal validity
- No compliance guidance: leaving users without legal context
- No structured checklist: no way to verify the document works
- Not kept updated: often unchanged when legislation changes
One incorrect clause can weaken or invalidate the entire document.
Hidden Problem: Many “Free Template” Sites Aren’t Even UK-Based
Another major issue is that many free or auto-subscription template sites operate outside the UK and use documents originally drafted for the US legal system. These are then loosely adapted for “international use,” which creates serious problems:
- Incorrect terminology: taken from US contract law
- Missing UK statutory references: essential legal requirements omitted
- Non-applicable clauses: terms that don’t apply under UK legislation
- Legal conflicts: risks breaching UK consumer, employment, or GDPR rules
Why Templates UK Does the Opposite
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Last updated: June 2026
Disclaimer: This guide provides general UK legal information, not legal advice. Laws are current as of June 2026.
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