Twelve-month Legal Timeline

December 2025

• The Employment Rights Bill received Royal Assent on 18th December and became the Employment Rights Act 2025.
• The Employment Tribunals (Early Conciliation: Exemptions and Rules of Procedure) (Amendment) Regulations 2025 are due to come into force on 1st December 2025 and seek to increase the ACAS early conciliation window from six weeks to twelve weeks. This will apply for all claims where early conciliation is commenced on or after 1st December.
• The Data (Use and Access) Act 2025 (Commencement No 4) Regulations 2025 come into force on 1st December, bringing into force most of Part 2 of the Data (Use and Access) Act 2025 (DUAA 2025) which establishes a legislative structure for the provision of digital verification services in the UK, where those services apply to be registered on a government register.
• The Border Security, Asylum and Immigration Act 2025 received Royal Assent on 2nd December 2025. Among other things, the Act extends the obligation undertake right to work checks beyond "employment" arrangements to include "other working arrangements". This will include those working under a worker's contract, those engaging as an individual sub-contractor, and an online matching service providing the details of an individual who is a service provider to potential clients or customers.
• On 3rd December, Ofqual has launched a consultation on proposed statutory guidance for regulating apprenticeship assessments. The proposals are intended to implement the DfE Apprenticeship Assessment Principles, published earlier this year which aim to simplify and modernise how apprenticeships are assessed. Responses are sought by 11th February 2026. 

• The government announced the agency profit cap on 4th December 2025 that once the new CCS Framework launches in June, schools will be expected to source agency staff through the framework, unless they are achieving better value for money through another route. Members should be aware that applications for the CCS Framework (Supply Teachers and Education Recruitment) closes on 19th December 2025.

• On 4th December, the National Insurance Contributions (Employer Pensions Contributions) Bill was published and had its first reading. The Bill implements the government's decision to limit the amount of salary sacrifice pension contributions eligible for NIC relief to £2,000 per year. HM Treasury has also published guidance on changes to salary sacrifice pension arrangements effective from April 2029 available here. 

• HMRC published the 2026-27 tax rates and allowances on 5th December 2025.

• The proposed Finance (No. 2) Bill was published on 4th December 2025, including setting out the proposed legislation surrounding joint and several liability. The 2^nd reading in the House of Commons is due on 16th December 2025.

• On 8th December, the ICO updated its guidance on the right of access under UK GDPR to reflect the changes introduced by the Data (Use and Access) Act 2025. The updated guidance establishes that organisations are only required to carry out reasonable and proportionate searches when responding to Subject Access Requests and may stop the clock when seeking clarification on requests. The ICO has also published a new subject access request template for small businesses. While individuals have the right to request copies of their personal data, they are not required to use the provided template, although it may be helpful.
• The Safeguarding Vulnerable Groups Act 2006 (Prescribed Purposes) Regulations 2025 come into force on 18th December 2025. The Regulations enable the ACRO and NCA to disclose information provided by the DBS, including whether an individual is on the children's barred lists, to assist an employer or prospective employer assess the individual’s suitability to work with children where the appointment decision is made outside the UK.
• On 4th December 2025, HMRC updated the list of 'Named tax avoidance schemes, promoters, enablers and suppliers' on GOV.UK. 
• The Immigration Skills Charge (Amendment) Regulations 2025 come into force on 26th December 2025, increasing the Immigration Skills Charge by 32%.

• On 11th December 2025, HMRC has published details of nine more promoters and their schemes on GOV.UK. Details of the promoters and the schemes published can be found here.

• On 16th December 2025, the Finance (no. 2) Bill, incorporating the Umbrella Company changes, was debated in the House of Commons.

Case Law

• Lockwood v Cheshire and Wirral NHS Foundation Trust (ET case numbers: 2401211/2024, 2407178/2024) – An ET has rejected a non-binary NHS worker’s complaint over harassment and repeated misgendering at work, ruling the worker did not have the protected characteristic of gender reassignment under the EqA 2010 due to the fact that despite the worker changing their name and pronouns, they had not reassigned their sex from female to male. The judge found that the word ‘reassigning‘ means ‘a move from one thing to another’; ‘it requires a from and a to’ and ‘to qualify for the protection within Section 7, they need to have the purpose of reassigning their sex to that of the opposite sex’.

• Peggie v (1) Fife Health Board and (2) Upton (Case No: 4104864/2024) – The claimant brought various claims under EqA 2010 against the first respondent, her employer (Fife Health Board) and the second respondent, a trans doctor employed by the first respondent (Dr Upton) in relation to the permitted use of a female changing room by the second respondent. The tribunal asserted this case defined ‘sex’ for EqA 2010 purposes in the context of provision of public services, not workplace facilities. It emphasised that work context requires balancing competing rights and applying a contextual proportionality assessment. On this basis, it found it was initially lawful to grant permission to the second respondent to use the female changing room while there were no complaints. However, once the claimant complained, the employer should have reassessed that decision, explored alternatives, and revoked the permission on an interim basis.