A client abusing your stylist is about to become your bill, and the price list is already published
Short version: from 30 October 2026 the government intends that if a client harasses one of your stylists and you cannot show you took all reasonable steps to stop it happening, that is on you, not just on the client. And from 1 October the window for a member of staff to take you to a tribunal is meant to double, from three months to six. Neither change is law yet, which matters, and not in the way most of the newsletters are telling you.
The two dates, and what is actually on the statute book
The government reissued its Employment Rights Act timeline on 7 August 2026. Two lines on it belong to you:
- 1 October 2026. Employment tribunal claim time limits rise from three months to six. The timeline gives Scotland a separate date of 9 November 2026.
- 30 October 2026. Employers must take all reasonable steps to prevent sexual harassment, and must not permit a third party to harass their staff.
Now go and look at the Act itself. Sections 20 and 21 (the harassment duties) and section 152 (the time limits) all carry the same flag on legislation.gov.uk today: prospective. Not in force. No commencement order has brought any of them in.
So when a compliance email tells you "from 1 October, tribunal time limits double", that is the government's published plan, not the law. Plan for it, because the government confirmed the dates two days before this was written. Just do not let anyone sell you urgency that the statute book does not yet support.
One piece of it is real and dated. The Employment Tribunal (Extension of Time Limits) Regulations 2026 were made on 6 July 2026 and come into force on 1 October 2026. They do the three-to-six-months change, but only for seven narrow regimes: part-time workers, fixed-term employees, information and consultation, blacklists, the two sets of zero-hours exclusivity rules, and NHS protected disclosure. Unfair dismissal and discrimination, the two that actually turn up in salons, are not in there. Those sit in Schedule 12 to the Act, still waiting.
What the new duty says, in its own words
Section 21 inserts this into the Equality Act 2010: "An employer (A) must not permit a third party to harass a person (B) who is an employee of A."
A third party is anyone who is not you and not one of your staff. In a salon that means the person in the chair. It also means the delivery driver, the landlord and the rep.
You have permitted it, on the wording, only if two things are true: the harassment happened in the course of B's employment, and you failed to take all reasonable steps to prevent it.
Section 20 is one word long in effect. It inserts "all" before "reasonable steps" in the existing duty to prevent sexual harassment of employees. That single word moves the bar. "Reasonable steps" is a defence about what a sensible employer did. "All reasonable steps" is a defence about what was left undone, and the person pointing at the gap will be a claimant's adviser, not you.
The number to hold in your head is £12,600
Compensation for hurt feelings in a discrimination or harassment claim is set by published bands, updated every April by the Presidents of the Employment Tribunals. For claims presented on or after 6 April 2026 they are:
- £1,300 to £12,600 for less serious cases.
- £12,600 to £37,700 for cases that do not merit the top band.
- £37,700 to £62,900 for the most serious, and above £62,900 in the most exceptional.
That is injury to feelings on its own. Lost earnings sit on top, and there is no cap on a discrimination award.
Here is the arithmetic that makes it real, and the margin below is an illustration rather than a benchmark. If your salon runs at a 10% net margin, a £12,600 award needs £126,000 of extra service revenue to pay for itself. On a 5% margin it is £252,000. Add your own defence costs, because the employment tribunal does not normally order the losing side to pay the winner's legal bill, so what you spend defending yourself is money you do not get back even when you win.
Set that against what the defence costs to build: an afternoon writing down what you already do, and a folder with dates in it.
Why a salon carries more of this risk than most businesses
Think about where your revenue physically happens. One person, one client, close physical contact, forty-five minutes to two hours, often with nobody else within earshot at the back basin. Late appointments run past the point where the shop is full. Colour clients sit for a long time and get comfortable. Bridal and party bookings involve drink.
None of that is a moral failing in your business. It is just the shape of the work, and it is exactly the shape the new duty is aimed at. A shop where staff stand behind a till two metres from a colleague has less exposure than yours does, on the same rules.
The practical consequence is that "we have a policy" will not carry a salon. What carries a salon is the boring specific stuff: who is on the floor at 7pm, how a stylist ends an appointment early without asking permission, and what you did the first time a client was told about.
The awkward question: does this cover your chair renters?
Section 21 protects "a person (B) who is an employee of A". A self-employed stylist renting a chair is, on the face of it, outside that.
Do not build anything on that. The Equality Act uses its own definition of employment, wider than the tax one: "employment under a contract of employment, a contract of apprenticeship or a contract personally to do work". Whether a particular chair renter falls inside turns on the real arrangement, not the label on the agreement, and there is no case law yet because the section is not in force.
The useful thing to notice is that the facts which decide this are the same facts that decide your tax position: who sets the price, who owns the clients, who controls the hours, who carries the risk. If you have been meaning to get the rent-a-chair paperwork to match reality, this is the second reason. The first one is in our briefing on the employer National Insurance rise and the rent-a-chair gap.
The clock change is the one that will cost real money
The harassment duty gets the headlines. The time limit is the one that changes your books.
Today a stylist has three months less a day from the act to start a claim. Doubling that to six does two things. It roughly doubles the period in which any awkward departure can still turn into a tribunal claim, and it gives the person who left far more time to talk to an adviser, get angry, and add a discrimination claim to a resignation you thought was settled.
The regulations that are actually made carry a transitional rule worth knowing: the extension "do not apply to cases where the relevant date occurs before 1st October 2026". Expect the same shape when the big ones commence. In other words this is not retrospective, and every leaver before the switch stays on the old clock.
Then look at January 2027 on the same timeline: the unfair dismissal qualifying period drops to six months and the cap on the compensatory award goes away. For scale, that cap is currently £123,543 or 52 weeks' pay, whichever is lower, with a week's pay capped at £751 since 6 April 2026. A longer window and a removed ceiling are the same trend pointing at the same place.
What "all reasonable steps" looks like on a salon floor
None of this needs a consultant. It needs evidence, dated.
- A line on your booking confirmation and on the door saying abuse of the team is not tolerated and the appointment will end.
- Written authority for every stylist to end an appointment on the spot, without calling you first, with no comeback on their pay.
- A named way to report it that is not "tell me when it is quiet", and a note of what you did within a day.
- A rule about lone working: which appointments never run with one person in the building.
- Ten minutes at a team meeting, with the date and who was there written down.
The paperwork is not the point. The paperwork is the proof, and the proof is the whole defence.
What this does to what your salon is worth
Every previous piece of employment law we have covered moved a cost line. This one moves something else: the tail of claims that can still land after you have sold.
A buyer's lawyer prices what could still come at the business after completion. That is not usually reflected in the multiple. It is reflected in the deal structure: a warranty about employment claims, an indemnity behind it, and cash retained out of your proceeds for as long as the claim window runs. Double the claim window and you widen the period the buyer wants covered. Remove the cap on unfair dismissal awards and you raise the number they want covered for.
So the salon that gets the cleanest exit in 2028 is not the one with the best-drafted policy. It is the one that can hand over a dated file showing that every complaint was recorded and answered, because that file is what shrinks the retention from a real number to a token one. Money held back out of your sale proceeds for eighteen months is money you cannot spend, and you get it back only if nothing turns up.
Worth knowing what your insurer thinks too. Employment practices cover varies, and whether an award for injury to feelings is inside the policy is a question to ask in writing before October, not after.
What to do about it
Practical moves to protect the margin, and grow it.
- Write the boring version down this month, with dates on it. From 30 October the defence is not what you believe, it is what you can evidence, and an afternoon spent recording the appointment-ending rule, the lone-working rule and the reporting route is the cheapest protection your net margin will ever buy.
- Give every stylist the standing right to end an appointment, in writing. It costs you one booking and it protects the two things a salon actually sells, the stylist's hours and the stylist staying, because replacing a good stylist costs far more than the walk-out did. See hiring and keeping staff.
- Ask your insurer, in writing, what your employment practices cover pays for, and specifically whether an injury-to-feelings award is inside it. A £12,600 gap you find in August is a phone call; the same gap found in a tribunal bundle is real cash out of profit.
- Fix the rent-a-chair agreements so they match what actually happens. The same facts decide your tax exposure and whether a renter is covered here, and an agreement that contradicts reality is the kind of thing a buyer discounts on sight in due diligence.
- GOV.UK, Plan to Make Work Pay and Employment Rights Act: timeline update (published 7 August 2026): 1 October 2026 for employment tribunal claim time limits from three to six months, Scotland 9 November 2026; 30 October 2026 for the all-reasonable-steps duty and the obligation not to permit third-party harassment; January 2027 for the six-month unfair dismissal qualifying period and the uncapping of compensatory awards
- Employment Rights Act 2025, section 21 (harassment by third parties), inserting into section 40 of the Equality Act 2010 that "An employer (A) must not permit a third party to harass a person (B) who is an employee of A"; shown as prospective, not in force. Section 20 inserts "all" before "reasonable steps" in section 40A of the Equality Act 2010, also prospective
- Employment Rights Act 2025, section 152 and Schedule 12 (increase in time limits for making claims from three months to six, including section 111 of the Employment Rights Act 1996 and section 123 of the Equality Act 2010); shown as prospective, not in force
- The Employment Tribunal (Extension of Time Limits) (Miscellaneous Amendments and Transitional Provisions) Regulations 2026 (SI 2026/758), made 6 July 2026, in force 1 October 2026: extends time limits from three to six months across seven subordinate regimes, with regulation 10 providing that the amendments "do not apply to cases where the relevant date occurs before 1st October 2026"
- Presidential Guidance, Ninth Addendum (issued 30 March 2026), Employment Tribunal awards for injury to feelings and psychiatric injury: for claims presented on or after 6 April 2026 the bands are £1,300 to £12,600, £12,600 to £37,700 and £37,700 to £62,900, with exceptional cases capable of exceeding £62,900, uprated by the RPI All Items Index released 20 March 2026
- The Employment Rights (Increase of Limits) Order 2026 (SI 2026/310), made 16 March 2026, effective 6 April 2026: limit on a week's pay raised from £719 to £751 and the maximum unfair dismissal compensatory award from £118,223 to £123,543