Flexible working, umbrella company regulation and day-one unfair dismissal have all slipped to 2027 in the UK
The UK government updated its Employment Rights Act implementation roadmap on 14 October 2026, and several measures moved. Flexible working reform, umbrella company regulation and day-one unfair dismissal rights are now all placed in 2027.
Two other changes are in the revision. The duty on employers to give workers a written statement of their right to join a trade union has been deferred from 30 October 2026 to 2027. And the two-tier workforce reforms have been removed from the roadmap entirely, with no replacement date given.
Why this matters
Flexible working is the measure with most direct bearing on remote and hybrid work. The reform attaches a reasonableness test to refusals and requires a process before a request can be turned down, which together change a request from something an employer may decline on one of eight statutory grounds into something they have to justify. That protection is now a year further away than the original roadmap implied.
Umbrella company regulation matters to a different group: contractors placed through intermediaries, which includes a good share of UK remote contract work. The regime was intended to bring umbrella companies within the scope of employment agency enforcement.
Removal is a stronger signal than deferral. The two-tier workforce reforms leaving the roadmap with no date is the clearest indication yet of which parts of the Act are being carried and which are being set down.
Context
The tranche that commences on 30 October 2026 is unaffected: the “all reasonable steps” harassment duty, third-party harassment liability and statutory union workplace access, including digital access. The Commons approved the union access regulations in three divisions on 14 October.
What to watch
Whether the 2027 dates firm up into actual commencement instruments. Remote Work Europe has noted before on this Act that announced dates and made statutory instruments are not the same thing, and the roadmap is a statement of intent rather than law.