With April's Employment Rights Act 2025 (ERA 2025) implementation wave now complete, attention is turning to further imminent changes, including data protection reform, the impact of increased visa sponsorship costs, and forthcoming ethnicity and disability pay gap reporting requirements.  

As additional ERA 2025 implementation dates approach in July and October, HR practitioners are navigating overlapping legal changes. The resources outlined on this page provide members with guidance and practical tools to support both immediate compliance and longerterm workforce planning.

Employment Rights Act 2025 

As April 6-7 rolled over, the wave of changes from the ERA 2025 came into force. There are resource hubs linked to from the ERA 2025 tracker - these hubs are there to support members with each step of these changes. 

The support will not end there. People need to be ready for the unfair dismissal change – this is planned to come into force earlier than expected (1 January 2027) and will be, effectively, backdated for existing staff. This will mean that anyone employed after 1 July 2026 will have an immediate right to claim unfair dismissal from the start of 2027. 

Data protection upcoming law change 

In a notable change for all organisations, a new statutory right relating to data protection is rolling out across the UK on 19 June 2026.  

From this date, the Data (Use and Access) Act 2025 (DUAA) is amending UK GDPR to create a new statutory right for individuals to complain directly to the organisation about the handling of their personal data. The change also puts an obligation on the organisation's data controller to receive, acknowledge and respond to complaints within certain limits. This is significant as, if handled well, it could provide an opportunity for organisations to reduce risk and minimise the cost of processing complaints.   

As people professionals, staying ahead of data protection law is critical – particularly where individual rights, organisational risk and employee trust intersect (as in this case). Find further information in the CIPD member data protection law page 

Updated immigration fees and settlement rules - alongside rising statutory employment costs 

As organisations face increased statutory costs and fees following April's annual rate changes, many employers are experiencing compounded affordability pressures.

Notably, for employers recruiting from overseas, the general salary threshold for Skilled Worker visas increased from £38,700 to £41,700 per year in January 2026. Therefore, any organisation employing someone on a Skilled Worker visa must pay at least this threshold, or the occupation‑specific 'going rate' for the role, whichever is higher. While there are limited exceptions or lower rates for some roles, the £3,000 increase per sponsored worker per year is significant for many employers, particularly those employing multiple visa holders.

As we move past Spring, the rise in such costs are landing at the same time as wider employment cost changes, for example:

  • The change in Statutory Sick Pay (SSP) means that employers must pay it more often (from day one of illness) and to more employees (the Lower Earnings Limit was removed).
  • There is a higher risk and cost exposure in redundancy situations due to the doubling of the maximum Protective Award (for failing to follow a fair process when consulting collectively on redundancies). Added to this, new organisation‑wide redundancy thresholds are set to be introduced, thereby increasing the likelihood that collective consultation duties will be triggered.

These are two examples of many. For employers considering restructures, or changes to workforce design, it is essential that your organisation understands the legal obligations when employing sponsored workers, in addition to the increased risk of non‑compliance in many areas of employment.

Please remember that CIPD members can also use the legal helpline for confidential advice on employment law issues, particularly where cost pressures are driving complex workforce decisions.

Upcoming Equality (Race and Disability) Bill  

With all the discussion around the ERA 2025, it is easy to forget that the Act is part of a broader ‘plan to Make Work Pay’ proposed by the UK Government. As part of this plan, the draft Equality (Race and Disability) Bill is expected to be published later in 2026.  

In response to a consultation building up to this Bill, the Government has confirmed that it intends to bring in mandatory ethnicity and disability pay gap reporting for large British employers (250+ employees). Contextually, employers can understand this reporting requirement to be largely similar to gender pay gap reporting – where these employers will be required to publish a set of figures that demonstrate the ethnicity and disability pay gap(s) in their organisation. 

In addition, the UK Government has indicated its intention to introduce mandatory action plans to tackle ethnicity and disability pay gaps – these will follow the gender pay gap action plans that have been introduced in the ERA 2025. It is anticipated that gender, ethnicity and disability action plans will be rolled into one Equality Action Plan to make the process more streamlined for employers.  You can review the CIPD response to the consultation on this matter here.

With major employment law rollout dates in October and April annually, watch this space for further information on this matter.   

TUPE and trade union and further consultations 

For employers in Great Britain, one final note on the 'plan to Make Work Pay'. A Call for Evidence on the efficiency of the TUPE regulations (open until 1 July 2026), and a consultation on what should be included in a statutory Code of Practice on trade unions' right of access (open until 20 May 2026) provides employers with the opportunity to impact future legislation. The CIPD respond to calls for action and consultations on members’ behalf, but individuals and organisations can also respond directly. Find a list of open consultations on the tracker. 

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