September 2026 Legal Briefing

This blog provides a brief overview September’s Legal Updates, which are relevant to Quality, Environmental, Info Sec and Health & Safety to help your organisation stay aligned with the latest legal requirements.  

How to use this Update:

• You should review these updates and decide whether they apply to your company.
• Add all relevant items to your legal register and document your compliance.
• Ensure all policies and procedures align with the new governance and compliance requirements.
• Provide information and training to all relevant personnel to ensure you remain compliant
• Please note that ISO 14001, ISO 45001, ISO 27001 and other standards require you to conduct a compliance evaluation.

The standards and industry information is provided as a guide to help organisations assess relevance. Organisations should review each update in the context of their own activities, locations and legal obligations to determine whether the legislation applies to them.

Where an update is applicable, organisations should consider whether their legal register, policies, procedures, risk assessments, controls, training or other compliance arrangements need to be reviewed or updated.

Need assistance with these updates? We are here to help: Contact us

The Employment Rights Act 2025 (Commencement No. 5 and Transitional Provisions) (Amendment) Regulations 2026
Date	4th September 2026
Country	UK
Category	Employment
Standards	ISO 9001, ISO 45001, ISO 37301
Industries/sectors	Organisations of all sizes and sectors employing staff in the UK, particularly HR, people management and organisations with formal employment grievance and disciplinary processes.
Status	Active
Summary These Regulations bring into force, on 1st October 2026, section 152 of, and Schedule 12 to, the Employment Rights Act 2025 (c. 36) (“the 2025 Act”), which extend time limits for instituting claims to employment tribunals from three to six months.Regulation 4 and the Schedule make transitional provision in relation to Schedule 12 to the 2025 Act so that the amendments to time limits apply where the date of the matter complained of (‘the relevant date’) occurs on or after 1st October 2026.
Legislation:	https://www.legislation.gov.uk/uksi/2026/954/contents/made

The Finance Act 2009, Sections 101 and 102 (Carbon Border Adjustment Mechanism) (Interest) (Appointed Day) Order 2026
Date	8th September 2026
Country	UK
Category	Finance
Standards	ISO 14001, ISO 37301, ISO 14064-1
Industries/sectors	Organisations importing or manufacturing goods within the scope of the UK Carbon Border Adjustment Mechanism, particularly businesses operating in carbon-intensive industrial sectors.
Status	Active
Summary Section 101 provides for late payment interest on sums due to His Majesty’s Revenue and Customs under an enactment but paid late. Section 102 provides for repayment interest on sums to be paid by His Majesty’s Revenue and Customs.
Legislation:	https://www.legislation.gov.uk/uksi/2026/994/contents/made

The Customs (Tariff and Miscellaneous Amendments) (No. 6) Regulations 2026
Date	8th September 2026
Country	UK
Category	Finance
Standards	ISO 9001, ISO 37301
Industries/sectors	Importers, exporters, manufacturers, distributors, logistics providers and other organisations involved in international trade and customs activities.
Status	Active
Summary This instrument makes amendments to subordinate legislation previously made under the Taxation (Cross-border Trade) Act 2018 (“TCTA”), which provided for the United Kingdom’s Customs, Value Added Tax (“VAT”) and Excise regimes to be in place after the end of the Transition Period following the withdrawal of the United Kingdom (“UK”) from the European Union (“EU”).
Legislation:	https://www.legislation.gov.uk/uksi/2026/984/contents/made

The Iran (Sanctions) (Amendment) Regulations 2026
Date	8th September 2026
Country	UK
Category	Sanctions
Standards	ISO 37301, ISO 27001, ISO 37001
Industries/sectors	Financial services, banking, international trade, shipping, aviation, logistics, manufacturing, technology and organisations involved in the supply of goods or services subject to UK sanctions controls.
Status	Active
Summary This instrument amends the 2019 Regulations to introduce prohibitions on the access of financial services by Iran; expand trade measures to cover additional categories of goods, technology, and services; prohibit certain Iranian aircraft used exclusively for the provision of air cargo services from landing in the UK; impose new shipping sanctions; and add specification of ship powers. This instrument amends the 2023 Regulations to expand existing powers relating to the specification of ships.
Legislation:	https://www.legislation.gov.uk/uksi/2026/983/contents/made

The Protection of Freedoms Act 2012 (Relevant Official Records) (Amendment) Order 2026
Date	8th September
Country	UK
Category	Other
Standards	ISO 27001, ISO 37301
Industries/sectors	Public sector organisations, legal and criminal justice services, police and government departments, and organisations responsible for managing relevant official records.
Status	Active
Summary The first scheme is a disregard and pardon scheme which applies to individuals convicted of, or cautioned for, an offence of persistently loitering or soliciting in a street or public place for the purposes of prostitution, where the conduct occurred when they were under 18. The second scheme is a pardon and data deletion scheme which applies to women previously convicted of, cautioned for, arrested for or investigated on suspicion of criminal offences related to abortion when acting in relation to their own pregnancies. The amendment will help ensure that the relevant organisations can identify and deal with records consistently when the schemes come into force. The New Schemes were introduced by the Crime and Policing Act 2026and are not yet in force.
Legislation:	https://www.legislation.gov.uk/uksi/2026/977/contents/made

The Carbon Border Adjustment Mechanism (Emissions and Verification) Regulations 2026
Date	9th September
Country	UK
Category	Environment
Standards	ISO 14001, ISO 50001, ISO 14064-1
Industries/sectors	Manufacturers and importers operating in the aluminium, cement, fertiliser, hydrogen, and iron and steel sectors, particularly organisations importing covered goods into the UK.
Status	Active
Summary Finance Act 2026 (FA 2026) includes provisions that will introduce the Carbon Border Adjustment Mechanism (CBAM) from 1 January 2027. CBAM is a new tax which will ensure that emissions within highly traded, carbon-intensive goods which are imported into the United Kingdom (UK) face a comparable carbon price to that paid by manufacturers producing the same goods in the UK. It will apply to specific goods across the following five industrial sectors: aluminium, cement, fertiliser, hydrogen, and iron and steel.
Legislation:	https://www.legislation.gov.uk/uksi/2026/995/contents/made

The Terrorism (Protection of Premises) (Principal Use of Premises) Regulations 2026
Date	10th September
Country	UK
Category	Other
Standards	ISO 45001, ISO 22301
Industries/sectors	Organisations responsible for premises used for retail, hospitality, leisure, entertainment, events, education, healthcare, transport, religious, sporting and cultural activities.
Status	Active
Summary This instrument introduces regulations under the Terrorism (Protection of Premises) Act 2025 (“the Act”), more commonly known as Martyn’s Law. It clarifies how to determine the “principal use” of premises that are in scope of the requirements of the Act (“qualifying premises”), where those premises have more than one use specified in Schedule 1 to the Act (“Schedule 1 use”).1 Determining the principal use of qualifying premises will establish the “responsible person” for those premises who must ensure that the requirements of the Act are met.
Legislation:	https://www.legislation.gov.uk/uksi/2026/1005/contents/made

The Finance Act 2009 (Publishing Details of Deliberate Tax Defaulters: Increase to Threshold) Order 2026
Date	11th September
Country	UK
Category	Finance
Standards	ISO 37301
Industries/sectors	Organisations across all sectors with UK tax obligations, particularly businesses and professional services organisations with significant tax liabilities.
Status	Active
Summary This instrument increases the potential lost revenue threshold for HMRC to publish a deliberate defaulter’s details to £50,000. This means that when this instrument comes into force, HMRC will only publish details of deliberate defaulters where the potential lost revenue exceeds £50,000.
Legislation:	https://www.legislation.gov.uk/uksi/2026/1000/contents/made

The Finance Act 2009 (Section 101) (Vaping Products Duty) (Appointed Day) Order 2026
Date	14th September 2026
Country	UK
Category	Finance
Standards	ISO 37301
Industries/sectors	Manufacturers, importers, wholesalers, distributors and retailers involved in the sale or supply of vaping products, and businesses with obligations relating to vaping products duty.
Status	Active
Summary This Order appoints 1st October 2026 as the day on which the interest regime set out in section 101 of the Finance Act 2009 (c. 10) on late payment interest comes into force for the purposes of vaping products duty. Section 101 has already been brought into force for other purposes.
Legislation:	https://www.legislation.gov.uk/uksi/2026/1024/contents/made

The Finance Act 2026 (Scottish and Welsh Property Income Rates) (Appointed Day and Tax Year) Regulations 2026
Date	14th September 2026
Country	Scotland & Wales
Category	Finance
Standards	ISO 37301
Industries/sectors	Property owners, landlords, property management and real estate businesses, and organisations or individuals receiving property income in Scotland or Wales.
Status	Active
Summary The Regulations appoint 16th September 2026 as the day on which section 8 of, and Schedule 2 to, the Finance Act 2026 come into force. They also appoint the tax year 2027-28 as the first tax year in relation to which the amendments made by section 8 and Schedule 2 have effect. Those amendments accordingly have effect for the tax year 2027-28 and subsequent tax years.
Legislation:	https://www.legislation.gov.uk/uksi/2026/1023/contents/made

The Digital Markets, Competition and Consumers Act 2024 (Commencement No. 3 and Transitional Provisions) (Amendment) Regulations 2026
Date	22nd September 2026
Country	UK
Category	Business
Standards	ISO 9001, ISO 37301
Industries/sectors	Consumer-facing organisations, including retailers, e-commerce businesses, technology companies, online marketplaces, and organisations providing digital or consumer services.
Status	Active
Summary These Regulations amend the transitional provisions set out the Digital Markets, Competition and Consumers Act 2024 (Commencement No. 3 and Transitional Provisions) Regulations 2026 (S.I. 2026/284 (C. 21)) to extend the transitional period from 5th October 2026 to 7th January 2027. The Regulations commence on the day after the day on which they are made.
Legislation:	https://www.legislation.gov.uk/uksi/2026/1040/contents/made

ISO 14001, ISO 45001, ISO 27001 and other standards require you to conduct a compliance evaluation. If you haven’t done this, we can help.