--- title: "18 months in speaking up: 2025 to 2026 | Speak Out Safe" description: "From harassment as a protected disclosure to failure to prevent fraud and the National Guardian's Office closing: the UK changes leaders need to know." image: https://speakoutsafe.uk/hubfs/website-2026/sos-paramedics.webp --- [![Speak Out Safe logo](https://speakoutsafe.uk/hubfs/website-2026/sos-logo-white.png)](https://speakoutsafe.uk) - [CONTACT](https://speakoutsafe.uk/contact-us) - [ABOUT](https://speakoutsafe.uk/about-us) - [PLATFORM](https://speakoutsafe.uk/product) - [PRICING](https://speakoutsafe.uk/pricing) - [INSIGHTS](https://speakoutsafe.uk/blog) [LOGIN](https://portal.speakoutsafe.uk/login) [BOOK A DEMO](https://meetings-eu1.hubspot.com/marius-van-aswegen/book-a-call) Safe reporting culture # 18 months in speaking up: the whistleblowing and safeguarding developments that matter, April 2025 to October 2026 From harassment as a protected disclosure to failure to prevent fraud and the National Guardian's Office closing: the UK changes leaders need to know. [Speak Out Safe](https://speakoutsafe.uk/blog/author/speak-out-safe) Oct 14, 2026 --- Eighteen months ago, speaking up was largely treated as a matter of good practice. Since April 2025, it has steadily become a matter of law, regulation and evidence. New statutory protections, regulatory conditions and criminal offences have arrived across employment, finance, higher education, health, charities and sport, and most of them ask the same question of leaders: when someone raises a concern, can you show that you made it safe to do so and acted on what you heard? This roundup brings together the developments that matter most for UK organisations, with links to the primary sources. ## Employment law: harassment and whistleblowing converge ### Sexual harassment became a protected disclosure The [Employment Rights Act 2025 received Royal Assent on 18 December 2025](https://bills.parliament.uk/bills/3737/stages). [Section 23](https://www.legislation.gov.uk/ukpga/2025/36/section/23) amends the list of qualifying disclosures in the Employment Rights Act 1996, so that information tending to show that sexual harassment ["has occurred, is occurring or is likely to occur"](https://www.legislation.gov.uk/ukpga/1996/18/section/43B) can now be a protected disclosure. The change took effect on 6 April 2026. The public interest test still applies, but a worker no longer has to squeeze a harassment report into another category to be protected. ### Fresh guidance for employers On the same day, GOV.UK published its [whistleblowing guidance for employers](https://www.gov.uk/guidance/whistleblowing-guidance-for-employers). It confirms there is still no legal requirement to have a policy, but it is clear about good practice: say how concerns will be handled and what feedback to expect, state that victimisation is unacceptable, confirm that workers do not need evidence, keep disclosures confidential and handle them anonymously where asked, document the process, and train all workers. ### Longer to bring a claim According to the [Government's implementation timeline](https://www.gov.uk/government/publications/implementing-the-plan-to-make-work-pay-and-employment-rights-act/plan-to-make-work-pay-and-employment-rights-act-timeline-update), the time limit for most Employment Tribunal claims increased from three to six months on 1 October 2026. Records of how a concern was handled now need to remain reliable for longer. ### Coming on 30 October 2026 The same timeline confirms that from 30 October 2026 employers must take "all reasonable steps" to prevent sexual harassment of their employees, and must not permit harassment of employees by third parties, such as customers, patients, spectators or members of the public. For leisure centres, clubs, hospitals and emergency services, where staff meet the public every day, the third-party duty deserves particular attention. Regulations on the misuse of non-disclosure agreements in harassment and discrimination cases are expected in 2027. ## Fraud prevention: speaking up is part of the defence The [failure to prevent fraud offence came into force on 1 September 2025](https://www.legislation.gov.uk/id/uksi/2025/349/regulation/3). It applies to large organisations, defined as meeting [two or more of: turnover above £36 million, balance sheet total above £18 million, more than 250 employees](https://legislation.gov.uk/ukpga/2023/56/section/201). The main defence is to prove that [reasonable prevention procedures](https://legislation.gov.uk/ukpga/2023/56/section/199) were in place. The [Home Office guidance](https://www.gov.uk/government/publications/offence-of-failure-to-prevent-fraud-introduced-by-eccta/economic-crime-and-corporate-transparency-act-2023-guidance-to-organisations-on-the-offence-of-failure-to-prevent-fraud-accessible-version) is direct: "organisations should have appropriate whistleblowing arrangements". It suggests independent reporting channels and a culture in which employees feel able to raise concerns. The offence [also covers large not-for-profit organisations](https://www.gov.uk/government/publications/offence-of-failure-to-prevent-fraud-introduced-by-eccta), so major charities are in scope alongside companies. ## Financial services: non-financial misconduct The FCA's [Policy Statement PS25/23](https://www.fca.org.uk/publication/policy/ps25-23.pdf) confirms that, from 1 September 2026, work-related non-financial misconduct, broadly bullying, harassment and violence, falls within the Conduct Rules for non-bank firms, with guidance on how it bears on fitness and propriety. Firms now need confidence that behavioural concerns reach the right people and are recorded well enough to inform conduct and fitness decisions. ## Higher education: condition E6 The Office for Students' [condition E6 came into force on 1 August 2025](https://www.officeforstudents.org.uk/for-providers/student-protection-and-support/harassment-and-sexual-misconduct/condition-e6-harassment-and-sexual-misconduct/). Registered providers must maintain a single comprehensive source of information on harassment and sexual misconduct, which must explain how students, staff and others can report concerns. Staff must be appropriately trained, and new contracts must not include provisions that stop students disclosing allegations. ## Health: the end of the National Guardian's Office Following the Dash Review and the 10 Year Health Plan, the Government agreed that the [National Guardian's Office would close at the end of June 2026](https://www.england.nhs.uk/publication/the-future-of-freedom-to-speak-up/), with NHS England delivering some of its activities from 1 July and healthcare organisations taking "greater responsibility and accountability" for Freedom to Speak Up. The [guardian role remains part of the NHS Standard Contract for 2026/27](https://nationalguardian.org.uk/2025/08/14/freedom-to-speak-up-guardian-role-will-remain-part-of-nhs-standard-contract/). With less central scaffolding, local arrangements, and the evidence behind them, matter more. ## Charities: a ten-year high The Charity Commission [received 594 whistleblowing disclosures in 2025 to 2026](https://www.gov.uk/government/publications/whistleblowing-disclosures-made-to-the-charity-commission-for-england-and-wales-2025-to-2026/whistleblowing-disclosures-made-to-the-charity-commission-for-england-and-wales-2025-to-2026), the highest in ten years. Safeguarding disclosures rose from 84 to 138, and 61% came from current or former employees. Many of those people went straight to the regulator. Trustees should ask whether their own channels were trusted first. ## Sport: structure and scrutiny The [Football Governance Act 2025](https://www.legislation.gov.uk/ukpga/2025/21/contents) received Royal Assent on 21 July 2025, establishing the Independent Football Regulator and a licensing regime for clubs. On safeguarding, The FA's [year one review of its safeguarding strategy](https://www.thefa.com/news/2025/dec/11/year-1-review-of-safeguarding-strategy) describes a new case management system across The FA and County FAs, and more than 241,000 learners completing safeguarding courses. Structured recording is becoming the expectation at every level of the game. ## The common thread Read together, these changes share three themes. First, harassment and misconduct are now firmly speak-up issues, not simply HR matters. Second, regulators and courts want evidence of what was done, when and by whom. Third, the channel must be one that people trust, including those who will only speak if they can stay anonymous. Speak Out Safe was built for exactly this. Each organisation, or site, has its own portal and QR code. Concerns can be raised by tick-box form or by voice note, turned into text, in 29 languages, and reporters can stay anonymous while exchanging messages with the case handler. Case management keeps a full audit trail, and the platform runs under an ISO/IEC 27001:2022 information security management system, holds Cyber Essentials and supports UK and EU GDPR compliance. ## What to do now - **Update your policy** to name sexual harassment and third-party harassment explicitly, and align it with the April 2026 GOV.UK guidance. - **Prepare for 30 October** by documenting the steps you take to prevent harassment, including how staff report incidents involving the public. - **Test your channels**: can someone report anonymously, out of hours, in their own language, and still receive feedback? - **Review your records** so that each concern, decision and outcome is traceable for at least the new six-month claim window and beyond. - **Brief your board** on the sector-specific changes above, whether fraud prevention, Conduct Rules, condition E6 or Freedom to Speak Up. - **Train the people who receive concerns**, especially line managers, who are often first to hear. If you would like to see how a concern moves from first report to closure, [book a short demo](https://meetings-eu1.hubspot.com/marius-van-aswegen/book-a-call) with our team. This article is general information, not legal advice. [Safe reporting culture](https://speakoutsafe.uk/blog/tag/safe-reporting-culture) [Whistleblowing law](https://speakoutsafe.uk/blog/tag/whistleblowing-law) ## Similar posts Safe reporting culture ### [Sexual harassment is now a whistleblowing matter: what the Employment Rights Act 2025 means for UK employers](https://speakoutsafe.uk/blog/employment-rights-act-2025-whistleblowing) Sexual harassment became a protected disclosure on 6 April 2026, with a stronger prevention duty from 30 October. What UK employers should do now. Speak Out Safe Oct 14, 2026 Safe reporting culture ### [How to build a speak-up culture: a practical checklist for boards and leaders](https://speakoutsafe.uk/blog/speak-up-culture-checklist-boards) A practical checklist for boards and trustees on leadership, policy, reporting routes, case handling, records and learning, based on UK guidance. Speak Out Safe Oct 14, 2026 Safe reporting culture ### [Anonymous reporting: myths, facts and how two-way anonymity works](https://speakoutsafe.uk/blog/anonymous-reporting-myths-facts) Anonymous and confidential are not the same. What UK guidance says about anonymous reports, and how two-way messaging makes them investigable. 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