A round-up of key developments in employment law

Employment Rights Bill in its final stages

The Employment Rights Bill, which will bring forward a wide range of employment law reforms, is now in the final stages of consideration in Parliament. A number of significant amendments were agreed by the Lords, but these have since been rejected by the Commons. The bill has now been listed for further consideration in the Lords on 23 October. If the Lords back down, we should expect to see Royal Assent shortly after. If they do not, there may be a period of so-called ‘ping pong’, where the bill is passed between the houses until agreement is reached.

Read our blog on the key dates and what employers need to do to prepare.

Revised EHRC services code handed to Minister

The Minister for Women and Equalities has been handed the revised draft EHRC Code of Practice on services, public functions and associations. The code covers discrimination, harassment and victimisation in services and public functions. It will now be considered by the government and, once it has ministerial approval, will be laid before Parliament for 40 days before it comes into force. Service providers must nevertheless ensure they are currently complying with their legal responsibilities and should not wait for the revised services code to be published.

New corporate fraud prevention offence in force

The Economic Crime and Corporate Transparency Act 2023 (ECCTA) establishes new offences for directors and companies, as well as new rules relating to the mandatory identity verification of directors. From 1 September, large organisations may be held criminally liable where an employee, agent, subsidiary or other ‘associated person’ commits a fraud intending to benefit the organisation. The new legal requirement for new directors and people with significant control (PSCs) to verify their identity, and the 12-month transition plan for existing directors and PSCs to verify their identity, will begin on 18 November 2025, as confirmed by Companies House.

Call for evidence on unpaid internships ends

The government’s call for evidence on unpaid internships, unpaid work trials, voluntary work and work shadowing as part of its Make Work Pay agenda closed on 9 October 2025. One area under consideration is whether to remove the exemption from the national minimum wage for students at UK institutions who are required to undertake a mandatory work placement of up to one year as part of their course. Conversely, UK and international students are entitled to the national minimum wage if the internship is part of an educational course based outside the UK.

The government’s response is expected in early 2026.

Changes to the law on non-disclosure agreements now in force

The law on non-disclosure agreements (NDAs) changed on the 1 October 2025, meaning that NDAs cannot validly prevent a victim of crime from reporting the crime to the police or from disclosing details of the crime to certain bodies and professionals to get confidential advice or support. Victims who sign NDAs may disclose information about relevant criminal conduct to qualified lawyers, regulated professionals including healthcare workers, victim support services, regulators, and close family members for specified purposes. These changes apply only to NDAs signed from 1 October 2025 onwards, with earlier agreements remaining subject to previous rules. The Ministry of Justice has published guidance for victims and individuals who use NDAs, explaining the practical implications of these statutory changes for confidentiality agreements.

The government recently published a white paper, Restoring control over the UK immigration system, which outlined the ways in which the government plans to reform the current immigration system. One of the main proposals in the white paper was reform of the Skilled Worker Visa route.

Some of the changes in the white paper came into force on 22 July 2025. These changes were significant and included:

• The removal of 180 SOC codes.
• Increasing the skill level from RQF level 3-5 to RQF level 6 (degree level) meaning that lower skilled roles are now not eligible for sponsorship to those who will be new to the Skilled Worker route.
• Increasing the minimum salary level to £41,700.

These are just some of the major changes that have been made to the Skilled Worker route and others are said to be coming in at some point this year.

What about those already in the UK on a Skilled Worker Visa?

Transitional arrangements have been put in place for some of those individuals that are already in the UK on a Skilled Worker Visa. It means that they can benefit from a reduced minimum salary level of £31,300, along with additional SOC codes eligible for sponsorship and lower going rates for these SOC codes.

Skilled Worker Visa from July 2025

For those new to the skilled worker route from 22 July 2025 or currently employed under a different time-limited visa route e.g. graduate visa, there is a risk that the role they are currently performing is no longer eligible for sponsorship under the new Skilled Worker immigration rules.

This has had a huge impact on businesses who rely heavily on skilled migrants to fulfil job roles that they cannot fill with domestic workers. The increase in the minimum salary and going rates has meant that businesses can no longer sponsor migrant workers for various highly skilled roles. This is forcing businesses to either have skills gaps in certain work forces or to hire people who do not necessarily have the skills to fulfil the role.

How we can help

If you currently employ migrant workers and are unsure whether their role is eligible for sponsorship going forward, please get in touch with our immigration team and we can discuss this with you.