UK HR To-Do List 2025: Employment and Immigration Law Changes

The U.K. government has announced significant changes to employment and immigration law. Many will not take effect until 2026 at the earliest; however, there are some important things to be aware of over the coming year.

As of Jan. 20, employment tribunals can adjust protective awards by up to 25% if a party has unreasonably failed to comply with the statutory Code of Practice on dismissal and re-engagement.

April will see the annual national minimum wage and statutory rate increases, with the national living wage set to rise to 12.21 pounds per hour. A new right to up to 12 weeks’ neonatal care leave and pay will be introduced as of April 6. Bereaved fathers/partners will get the right to extended paternity leave during the first year of the child’s life if the mother (or a primary adopter) dies — this is expected to take effect in April but has not yet been confirmed.

As of April 2, nonvisa EU nationals, except for Irish citizens, will have to apply and be granted an electronic travel authorization (ETA) before traveling to the U.K. (Others who do not need a visa to enter as a visitor are already required to obtain an ETA.) The government also intends to publish a white paper setting out plans to reduce net migration, reform the points-based immigration system, and ensure that visa routes come with expectations to train domestic workers.

The Employment Rights Bill is expected to be passed later in 2025. At that time, the requirement for certain sectors to operate a minimum service level during industrial action will be removed. Two months later, other trade union laws will be repealed, including the requirement for a minimum 50% turnout for valid industrial action ballots.

It is anticipated that the majority of the other provisions in the Employment Rights Bill will not take effect until 2026 at the earliest, with many subject to consultation. Those proposals include: 

• Unfair dismissal becoming a day-one right (no sooner than autumn 2026), with a new statutory probationary period (expected to be nine months) during which there will be a “lighter-touch” process for fair dismissal.
• Further restrictions on the use of dismissal and re-engagement (“fire and rehire”) to amend terms and conditions of employment.
• New rights for workers on zero-hours and “low-hours” contracts (including agency workers) to be offered guaranteed hours after each 12-week period of work.
• Amended rules on statutory flexible working requests — for example, employers will only be able to refuse a request where it is reasonable for them to do so.
• New collective layoff consultation thresholds and remedies.
• Expanding the duty to take reasonable steps to prevent sexual harassment to “all reasonable steps.”
• Liability for third-party harassment (in relation to all relevant protected characteristics) if an employer fails to take all reasonable steps to prevent it.
• Removal of the lower earnings limit and three-day waiting period for statutory sick pay.
• A reasonable right for trade unions to access workplaces.
• A new six-month time limit for raising tribunal claims.

Later in the year, the government intends to publish the Equality (Race and Disability) Bill, which will introduce mandatory ethnicity and disability pay gap reporting for employers with 250 or more employees and give employees the right to bring equal pay claims based on ethnicity and disability. There are also plans to consult on employment status and introduce a code of practice on the right to disconnect.

Fiona Herrell is an attorney with Brodies LLP in Aberdeen, Scotland. © 2025 Brodies LLP. All rights reserved. Reposted with permission of Lexology.