A weekly briefing on European HR, labour law and compliance developments for SME HR teams across the EU, UK, Switzerland and the Nordics.
Top story: UK Employment Rights Act delivers first wave of changes this week
After months on the horizon, the UK’s Employment Rights Act 2025 begins reshaping workplace law this week. The first change lands on 1 October 2026, when the standard time limit for bringing employment tribunal claims doubles from three months to six months for substantially all claim types, including unfair dismissal, discrimination and unlawful wage deductions. A second wave follows on 30 October with the strengthened third-party harassment duty and new trade union rights provisions.
The tribunal deadline extension has significant practical consequences. Combined with the Acas early conciliation period, which was extended from six to 12 weeks in December 2025, employees can now delay a claim for nearly 10 months from the triggering event. The tribunal system is already under strain, with 537,000 claims pending as of Q1 2026. Employers should expect a higher volume of claims, longer exposure windows and greater difficulty preserving evidence and maintaining witness availability over the extended period.
The 30 October changes raise the bar further. The existing duty to take “reasonable steps” to prevent sexual harassment, introduced in October 2024, is upgraded to “all reasonable steps”: a higher threshold that will require employers to demonstrate a more proactive and comprehensive approach. The new third-party harassment duty extends protection to situations where employees are harassed by customers, clients, contractors or members of the public, covering all protected characteristics except marriage, civil partnership, pregnancy and maternity. Where an employer hasn’t met the duty, tribunals can apply a compensation uplift of up to 25%.
What to do: UK employers should treat this week as a preparation deadline. Extend HR record retention periods, document internal dispute processes and identify witness contact details early to manage the longer claim window. For the 30 October changes, conduct risk assessments of customer-facing and public-facing roles, train managers on recognising and escalating third-party harassment and review reporting channels. The shift from “reasonable” to “all reasonable” steps means employers will need to show they did everything proportionate, not merely something proportionate.
Also developing
Belgium: Employers have until 16 December 2026 to comply with the Private Investigations Act, which entered into force on 16 December 2024 with a two-year transition period. The Act doesn’t just apply to professional investigation firms: it covers internal HR investigations too, including dismissals for serious cause and fraud inquiries. Employers must now obtain explicit written consent from interviewees before questioning, disclose the reason for the investigation and the subject’s rights (including the right to refuse to answer, to access the interview transcript and to be accompanied), maintain an investigation register and file a written end report within one month of completing the final investigative step. Investigations into political beliefs, union membership, health information and criminal history are prohibited. Evidence gathered without compliance is inadmissible in court, and administrative fines can reach EUR 25,000. What to do: Belgian employers should audit internal investigation procedures against the Act’s requirements now. If your HR team conducts any form of workplace inquiry, from misconduct investigations to whistleblowing follow-ups, prepare written consent forms, update disclosure protocols and set up an investigation register before the December deadline.
Finland: Finland’s draft bill implementing the EU Pay Transparency Directive entered parliamentary debate on 15 September 2026, with the legislation planned to take effect on 1 January 2027. The bill requires employers to disclose salary ranges in job postings, bans pay history questions and gives employees the right to request information on pay levels for comparable roles. Companies with 100 or more employees must report on gender pay gaps by employee group. The first reports are due by 7 June 2028 for companies with 150 or more employees, and by 7 June 2031 for those with 100–149 employees. Where unjustified gaps of 5% or more are found, employers must conduct pay assessments together with employee representatives. The limitation period for pay discrimination claims is three years, with the burden of proof shifting to the employer in cases of non-compliance. What to do: Finnish employers should start auditing pay structures and defining objective, gender-neutral pay criteria now, well ahead of the January 2027 effective date. Update recruitment processes to include salary ranges and remove pay history questions.
Norway: The government proposed a new “wear and tear” early retirement pension supplement (sliterordning) on 24 August 2026, which is now entering its autumn consultation period. The scheme would offer an annual supplement of 0.25 G (approximately NOK 34,000) to employees who retire early after at least 35 years of pensionable income, taken five or more years before the normal retirement age. The proposal targets lower-income workers in physically demanding occupations and sits alongside ongoing negotiations between the LO trade union confederation and employers’ organisation NHO on reforming the AFP private-sector pension from a qualification-based to an accrual-based model, with potential implementation from 1 January 2028. What to do: Norwegian employers in sectors with physically demanding roles should track both the sliterordning consultation and the AFP reform discussions. If either or both proceed, workforce planning and retirement forecasting will need updating.
Denmark: The Eastern High Court ruled that the 12.5% holiday allowance (feriegodtgørelse) should not be included in the salary basis when calculating compensation under the Danish Act on Equal Treatment. The case concerned a male employee dismissed after disclosing his partner’s pregnancy. The ruling narrows how discrimination compensation is calculated, potentially reducing total payable amounts in settlements and awards across all equal treatment cases. Separately, the new Danish holiday year began on 1 September 2026. Unused holiday from the previous year must be taken by 31 December 2026 or risks forfeiture. What to do: Danish employers should update compensation calculation templates for equal treatment disputes in light of the High Court ruling. Review employee holiday balances and schedule outstanding leave before the 31 December 2026 deadline.
Germany: The Federal Ministry of Labour and Social Affairs is actively drafting legislation to transpose the EU Platform Workers Directive ahead of the 2 December 2026 deadline, examining the possibility of a “direct employment requirement” for certain platform workers. While no formal bill has been tabled, the ministry is coordinating with other EU member states and the European Commission’s Expert Group through thematic workshops. The directive will introduce a rebuttable presumption of employment status for platform workers meeting specified criteria, alongside restrictions on automated decision-making. What to do: German companies engaging workers through digital platforms should begin assessing their operating models against the directive’s criteria for employment status. A direct employment requirement, if included in the final bill, would go further than the EU minimum and make early preparation essential.
On the radar
EU Pay Transparency Directive (previously covered): most member states are still working on transposition. Finland is the latest to enter parliamentary debate, with Denmark and Sweden expected to follow in the coming months.
EU Platform Workers Directive (previously covered): member states must transpose by 2 December 2026. Germany is now actively drafting. The Netherlands has acknowledged it will miss the deadline.
Germany Working Time Act reform (previously covered): the internal working draft proposing a shift from daily to weekly working time limits and mandatory electronic time recording has not yet been formally tabled. The requirement that flexible arrangements be negotiated through collective bargaining remains politically contested.
UK fire and rehire ban (previously covered): postponed to January 2027. No material change.
Sources
- Lewis Silkin: longer time limits for bringing tribunal claims from October 2026
- Blake Morgan: Employment Rights Act 2025, October 2026 implementation dates confirmed
- Pinsent Masons: UK employers prepare for new third-party harassment duties
- Jones Day: Belgium adopts new Act on Private Investigations
- Baker McKenzie: Belgian Employment Law Essentials, September 2026
- Borenius: Finland moves to implement the EU Pay Transparency Directive
- DLA Piper: Nordic Employment Law Bulletin, September 2026
- DLA Piper: Germany moves forward on transposing the EU Platform Work Directive
- DLA Piper: Germany prepares shift to weekly working time limits
Europe HR Compliance Pulse Weekly is an informational summary of publicly reported legal and regulatory developments. It is not legal advice. Always confirm obligations for your specific situation and market with a qualified adviser.
