Last reviewed: 4 October 2026. This guide is general information, not legal advice. The employment measures below apply in Great Britain (England, Wales and Scotland) unless stated; Northern Ireland has its own employment law. Dates are subject to change: the government says so itself.
TL;DR
- The Employment Rights Act 2025 received Royal Assent on 18 December 2025. It is being brought into force in stages.
- 7 April 2026: the Fair Work Agency started operating. It now enforces the rules on employment agencies and businesses.
- 1 October 2026: the time limit for most employment tribunal claims went from 3 to 6 months.
- 1 January 2027: the qualifying period for unfair dismissal drops from two years to six months, for dismissals from that date.
- 2027, no fixed date: regulation of umbrella companies and the right to guaranteed hours.
The source to bookmark
Two primary sources matter here. The Act itself is on legislation.gov.uk (2025 c. 36), and the Parliament record shows it became an Act with Royal Assent on 18 December 2025 (Parliament bills API, bill 3737).
The dates come from the government's Plan to Make Work Pay and Employment Rights Act: timeline update, last updated on 25 September 2026. It carries an important warning: "All future dates remain subject to parliamentary processes and may change." Treat every date after today as a plan, not a promise, and check the page again before you change a contract or a process.
Timeline for recruitment agencies
| Date | Measure | Why an agency should care |
|---|---|---|
| 18 December 2025 | Royal Assent | The Act is law; most measures need regulations to start |
| 6 April 2026 | Day-one paternity leave and unpaid parental leave; Statutory Sick Pay without the lower earnings limit or waiting period | Payroll and contract terms for your own staff and any temps you employ |
| 7 April 2026 | Fair Work Agency established | New enforcer of the agency rules |
| 1 October 2026 | Tribunal claim time limit 3 → 6 months | Longer exposure to claims after a placement ends |
| 30 October 2026 | "All reasonable steps" to prevent sexual harassment; duty not to permit harassment by third parties | Covers harassment of your own staff, including temps you employ, by people such as client staff |
| 1 January 2027 | Unfair dismissal qualifying period two years → six months; compensatory award uncapped | Changes the risk of a short-tenure perm hire, for your clients and your own team |
| 2027 | Regulation of umbrella companies; right to guaranteed hours | Direct impact on contract and temp desks |
Every row comes from the government timeline above, apart from Royal Assent.
Fair Work Agency: the new enforcer (7 April 2026)
The Fair Work Agency (FWA) is an executive agency sponsored by the Department for Business and Trade. The government's guidance on the Key Information Document notes that the FWA "began operating on 7 April 2026" and "replaced the EAS", the Employment Agency Standards Inspectorate.
For an agency, the practical consequence is simple: the rules have not changed overnight, but the body that inspects you has. GOV.UK now hosts guidance for workers on making a complaint to the Fair Work Agency about a recruitment agency, and the FWA's enforcement policy statement.
Tribunal claims: six months instead of three (1 October 2026)
Section 152 of the Act, in force since 1 October 2026, increases the time limits for bringing claims "from three months to six months" (section 152). The government timeline adds one exception: for breach of employment contract claims in Scotland, the change takes effect on 9 November 2026.
For an agency, six months is a longer tail. A dispute with a temp or a contractor can now surface well after the assignment has ended. Keep assignment records, signed timesheets, written terms and correspondence for at least that long, and longer if your own retention policy allows it.
Unfair dismissal after six months (1 January 2027)
Section 25 of the Act replaces "two years" with "six months" in the unfair dismissal qualifying period of the Employment Rights Act 1996, and removes the cap on the compensatory award (section 25). The government timeline schedules this for dismissals from 1 January 2027.
This mostly affects employees: your own recruiters and, for perm placements, your clients' new hires. Expect clients to ask more of probation periods and of the information you give them about candidates before an offer.
Guaranteed hours and umbrella regulation (2027)
Two measures matter most to contract and temp desks, and neither has a firm date.
- Guaranteed hours. Section 1 of the Act creates a right for qualifying workers to be offered guaranteed hours, and section 4 adds a separate chapter on guaranteed hours and shift rights for agency workers. The government lists it for 2027 and says "timings will be updated after consultation". The detail depends on regulations not yet made.
- Umbrella companies. Section 36 extends the definition of an employment business so that umbrella companies can be regulated under the agency rules. The timeline lists "regulation of umbrella companies" for 2027.
Do not confuse that regulation with the tax change already in force: since 6 April 2026, the agency contracting with the end client can be made to pay an umbrella company's PAYE shortfall. We cover it in umbrella company PAYE rules from April 2026.
Where the Act applies
Section 158 sets the extent (section 158): Parts 1, 2 and 4 extend to England and Wales and Scotland; Part 5 (enforcement) and Part 6 extend to Northern Ireland too, and a few specific provisions differ. If you place workers in Northern Ireland, check the Northern Ireland position separately rather than assuming these dates apply.
What to do now
- Name an owner for this timeline in your agency, and diary a check of the government page each quarter.
- Review your record keeping for the six-month claim window: who signed what, and when.
- Update your own staff handbook for the April 2026 leave and sick pay changes and, before January 2027, for unfair dismissal.
- Brief your clients on harassment duties from October 2026: the people you place work on their premises.
- Map your umbrella suppliers now, before regulation arrives in 2027.
How Marvin helps, and its limits
Marvin does not track legislation and does not give legal advice. What it does is keep the evidence that these rules make more valuable: each placement and assignment with its dates and rates, contractor timesheets with the client's signature and a snapshot of what was signed, and the documents you share with each contractor in their personal space. Read how it works in our guides to contract and temp recruitment software and timesheet software for recruitment agencies, or book a demo.
Frequently asked questions
When did the Employment Rights Act 2025 become law?
It received Royal Assent on 18 December 2025. Most of its measures are being brought into force in stages through regulations, from 2026 into 2027 and beyond.
What is the Fair Work Agency?
An executive agency of the Department for Business and Trade, established on 7 April 2026. It replaced the Employment Agency Standards Inspectorate, so it is now the body that enforces the rules on employment agencies and employment businesses.
How long do workers now have to bring an employment tribunal claim?
Six months instead of three, since 1 October 2026. For breach of employment contract claims in Scotland, the change takes effect on 9 November 2026.
When does the unfair dismissal qualifying period drop to six months?
For dismissals from 1 January 2027, according to the government timeline, which also uncaps the compensatory award. Until then, the qualifying period remains two years.
Are these dates final?
No. The government states that all future dates remain subject to parliamentary processes and may change. Guaranteed hours and the regulation of umbrella companies are only scheduled for 2027, without a precise date.
Does the Act apply in Northern Ireland?
Mostly not. The parts that create or change employment rights (Parts 1, 2 and 4) extend to England, Wales and Scotland; Northern Ireland has its own employment law. Part 5 on enforcement, the general provisions and a few specific sections also extend to Northern Ireland, so check section 158 of the Act for any specific measure.
