Twelve-month Legal Timeline
See what legal activity is happening in the coming twelve months .
See the previous months page for earlier activity
December 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.
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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.
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HMRC published the 2026-27 tax rates and allowances on 5th December 2025.
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The proposed Finance (No. 2) Bill was published on 4th December 2025, including setting out the proposed legislation surrounding joint and several liability. The 2nd reading in the House of Commons is due on 16th December 2025.
- 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.
- 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%.
Case Law
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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’.
February 2026
Currently no activity.
March 2026
Currently no activity.
April 2026
- From 6th April 2026, agencies with a direct contractual relationship with end-user clients who use umbrella companies will become strictly liable to HMRC for shortfalls in the PAYE on umbrella company workers’ pay. This will be the case even if the umbrella company employs the worker and the shortfall is down to them. Strict liability means that HMRC only needs to identify a PAYE shortfall for an agency to be liable. This means that it will not be possible for agencies to raise a defence against liability, and HMRC will not consider any steps an agency took to ensure that an umbrella company they were using was making the correct PAYE payments to HMRC through due diligence checks. Whilst the wording joint and several liability is used in the draft legislation on these measures, HMRC has made it clear that it will pursue the party with the direct contractual relationship with the end-user client for liability and this is usually the agency. More information can be found on our Umbrella Company Hub here.
- From 1st April, tax advisers who interact with HMRC on behalf of clients must register with HMRC and meet minimum standards. The changes will improve HMRC's ability to monitor and exclude tax advisers who are objectively unable to meet HMRC's Standards for Agents or cannot lawfully act as a tax adviser. Mandatory registration starts 1 April 2026, with at least a three-month transition period. Further information can be found here.
- The following measures contained in the Employment Rights Bill will take effect in April 2026 (see the Roadmap on Implementing the Employment Rights Bill):
- Collective redundancy protective award – doubling the maximum period of the protective award
- 'Day 1' Paternity Leave and Unpaid Parental Leave
- Whistleblowing protections
- Fair Work Agency body established
- Statutory Sick Pay – remove the Lower Earnings Limit and waiting period
- Simplifying trade union recognition process
- Electronic and workplace balloting
May 2026
Currently no activity.
June 2026
Currently no activity.
July 2026
Currently no activity.
August 2026
Currently no activity.
September 2026
Currently no activity.
October 2026
Currently no activity.
November 2026
Currently no activity.
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