The UK Employment Rights Act 2025 is now law, having received Royal Assent in December 2025. While many of its provisions will be introduced in phases across 2026 and 2027, the Act represents one of the most significant overhauls of employment legislation in decades.
For organisations operating an ISO 9001 Quality Management System (QMS), the Act is highly relevant. ISO 9001 already requires organisations to understand legal obligations, manage risks, ensure competent and engaged people, and maintain effective documented information. The Employment Rights Act 2025 strengthens expectations around workforce management, fairness, and compliance – all of which intersect directly with ISO 9001 requirements.
This article explains how the Employment Rights Act 2025 aligns with key clauses of ISO 9001:2015, and what organisations should be doing now to remain compliant, audit‑ready, and resilient.
What is the Employment Rights Act 2025?
The Employment Rights Act 2025 updates and amends existing UK employment legislation, introducing stronger protections for workers and clearer obligations for employers. Key themes include:
- A reduction in the unfair dismissal qualifying period to six months’ service, effective from 1 January 2027 (with potential future changes to compensation caps subject to confirmation via regulations)
- Strengthened statutory sick pay, including day‑one entitlement and removal of the lower earnings limit (with commencement dates to be confirmed through secondary legislation)
- Guaranteed hours rights for qualifying workers on zero‑hours or low‑hours contracts, requiring employers to offer predictable hours after set reference periods (details and timings to be confirmed by regulations)
- Strict limits on ‘fire and rehire’ practices, making certain dismissals automatically unfair
- Stronger duties to prevent sexual harassment, based on enhanced “reasonable steps” requirements, with operational detail to follow in secondary legislation
- Enhanced trade union and industrial action protections, including automatic unfair dismissal for lawful industrial action from February 2026
- New statutory rights, such as bereavement leave,are subject to phased commencement
Although the Act is now law, many of its provisions rely on secondary legislation, meaning that precise implementation dates and thresholds will be confirmed progressively.
ISO 9001 alignment with the Employment Rights Act 2025
Clause 4 – Context of the Organisation
ISO 9001 requires organisations to understand internal and external issues that affect their ability to achieve intended results.
The Employment Rights Act 2025 is a significant external issue. It affects:
- Workforce structure and costs
- Employee relations and engagement
- Legal and reputational risk
- Operational continuity
Organisations should update their context analysis and interested‑party considerations to reflect employees’ expanded statutory rights and regulators’ increased expectations.
Clause 5.1 – Leadership and Commitment
Top management must demonstrate leadership and commitment to the QMS, including compliance with applicable legal requirements.
Under the Employment Rights Act 2025, leadership accountability becomes more visible in areas such as:
- Fair dismissal processes
- Prevention of workplace harassment
- Ethical treatment of workers on variable or zero‑hours contracts
- Support for employee well-being and absence management
Senior leaders should ensure employment law compliance is clearly owned, resourced, and integrated into the organisation’s management system – not treated as a standalone HR issue.
Clause 6.1 – Actions to Address Risks and Opportunities
ISO 9001 requires organisations to identify and manage risks and opportunities that could affect QMS performance.
The Employment Rights Act 2025 introduces new legal, operational, and financial risks, including:
- Non‑compliance with statutory sick pay reforms
- Failure to offer guaranteed hours where required
- Incorrect handling of dismissals during the six‑month qualifying period
- Inadequate harassment prevention measures
At the same time, it creates opportunities, such as:
- Improved employee retention and engagement
- Reduced disputes through clearer, fairer processes
- Stronger organisational culture aligned with quality principles
These should be captured within risk registers and reviewed as part of management review.
Clause 7.1.2 – People
ISO 9001 requires organisations to determine and provide the people necessary for the effective operation of processes.
The Act reinforces the need for:
- More predictable working arrangements
- Fair and lawful contractual terms
- Adequate resourcing to manage absence and leave entitlements
Workforce planning under ISO 9001 should now explicitly consider statutory rights such as guaranteed hours, bereavement leave, and enhanced sick pay.
Clause 7.2 & 7.3 – Competence and Awareness
Managers and supervisors must be competent and aware of their responsibilities.
With the Employment Rights Act 2025, this includes understanding:
- Updated dismissal thresholds and protections
- Lawful handling of industrial action
- Employer duties around harassment prevention
- Employee rights to leave and pay
Training needs analyses and competence records should be updated accordingly to demonstrate compliance during audits or inspections.
Clause 7.4 – Communication
ISO 9001 requires organisations to determine what, when, and how to communicate.
The Act increases the importance of clear internal communication, including:
- Updated policies and procedures
- Changes to contracts or working arrangements
- Employee awareness of new rights and processes
Poor communication around employment rights can quickly lead to grievances, claims, and nonconformities.
Clause 7.5 – Documented Information
Documented information must be controlled and kept up to date.
In light of the Employment Rights Act 2025, organisations should review and update:
- Employment contracts
- Absence and sick pay policies
- Disciplinary and dismissal procedures
- Harassment and dignity at work policies
- Legal registers and compliance logs
Auditors may increasingly expect to see explicit reference to the Act within documented compliance systems.
Clause 8.1 – Operational Planning and Control
Operational planning must ensure processes are carried out under controlled conditions.
Employment law changes affect operations through:
- Workforce availability
- Absence management
- Shift and hours planning
- Industrial relations
Embedding these considerations into operational planning helps reduce disruption and supports consistent delivery of products and services.
Clause 9 – Performance Evaluation
Monitoring, measurement, internal audits, and management reviews should now consider:
- Compliance with the Employment Rights Act 2025
- Trends in absence, grievances, and turnover
- Effectiveness of harassment prevention measures
This supports evidence-based decision-making and continuous improvement.
Clause 10.2 – Nonconformity and Corrective Action
Failure to comply with employment legislation is a legal nonconformity and should be treated as such within the QMS.
Examples include:
- Outdated policies that conflict with the Act
- Incorrect handling of dismissal or sick pay
- Failure to provide guaranteed hours where required
Corrective actions should address both immediate issues and systemic causes, strengthening compliance and reducing future risk.
Implementation timeline – planning ahead
Although the Act is law, key provisions are being phased in and, in several cases, depend on secondary legislation:
- December 2025 – Employment Rights Act 2025 receives Royal Assent
- February 2026 – Dismissal for taking part in lawful industrial action becomes automatically unfair
- 2026 (dates to be confirmed) – Regulations expected covering:
- Strengthened statutory sick pay (day‑one entitlement)
- Enhanced sexual harassment prevention duties
- Detailed operation and enforcement of fire‑and‑rehire restrictions
- 1 January 2027 – Six‑month qualifying period for unfair dismissal comes into force
- Future commencement (date to be confirmed) – Guaranteed hours rights for qualifying workers, once reference periods, thresholds, and enforcement mechanisms are set out in regulations
ISO 9001 encourages proactive, risk‑based planning, making it important for organisations to monitor secondary legislation and update their management systems as requirements become clearer.
Conclusion
The Employment Rights Act 2025 reinforces many of the principles already embedded in ISO 9001, including leadership accountability, risk-based thinking, competent people, effective communication, and controlled processes.
Rather than viewing the Act as a standalone HR obligation, ISO 9001‑certified organisations should integrate it into their Quality Management Systems. Doing so not only supports legal compliance but also strengthens organisational resilience, culture, and long‑term performance.
CTA: If you would like support updating your legal register, risk assessments, or ISO 9001 documentation to reflect the Employment Rights Act 2025, Assent Risk Management can help.
