The duty most housing teams haven’t clocked yet
The Worker Protection (Amendment of Equality Act 2010) Act 2023 has been in force since 26 October 2024, and most of the commentary on it has gone to retail and hospitality: shop staff harassed by customers, bar staff harassed by patrons. Almost none of it has been written for social housing teams. That’s a gap, because the duty applies just as much to a housing officer conducting a home visit as it does to a till operator, and a further, broader change is due to land in October 2026. Getting the scope right matters here, because it’s easy to overstate what this law actually covers.
What WPA 2023 requires right now
WPA 2023 created a new proactive duty: employers must take reasonable steps to prevent sexual harassment of their employees during the course of their employment, including sexual harassment carried out by third parties such as customers, clients, or (in housing’s case) tenants. This is enforced by the Equality and Human Rights Commission, which updated its technical guidance in September 2024 to set out what “reasonable steps” looks like in practice: a clear anti-harassment policy that explicitly covers third parties, regular risk assessment of where harassment might occur, and a reporting and complaints process staff will actually use. If an employment tribunal upholds a sexual harassment claim and finds the preventative duty was breached, it can increase compensation by up to 25%. See the wider UK compliance framework for the duties alongside this one.
Important scope note: this duty is specifically about sexual harassment. A general legal duty requiring employers to prevent all forms of third-party harassment was actually removed from the Bill during its passage through Parliament, which is a detail most generic commentary skips over. That matters for housing, because it means WPA 2023 as it stands today doesn’t, by itself, cover racial abuse, disability-related hostility, or general verbal aggression from a tenant. That territory is governed separately, and we’ll come back to it below.
Where tenants come in
For a housing officer or repairs surveyor working alone inside someone else’s home, unwanted sexual comments or contact from the resident is a genuine, if under-discussed, part of the sector’s safety picture. It sits alongside the physical violence risk UNISON’s 2024–25 survey documented (72% of respondents experienced violence at work in the past year), as a distinct category with its own legal mechanism. The reasonable-steps duty applies here today, in exactly the same way it applies to a retail worker facing harassment from a customer. If your organisation’s anti-harassment policy and risk assessment don’t explicitly name tenants as a category of third party, that’s a gap worth closing now rather than waiting for October 2026. Read more about UNISON’s housing worker survey.
What’s changing from October 2026 (anticipated)
The Employment Rights Act 2025, which received Royal Assent in December 2025, is bringing a second wave of harassment reforms into force. The government’s roadmap points to 30 October 2026 for this package, though as with any commencement date that hasn’t yet taken effect, we’re treating it as anticipated rather than confirmed until it does. Two changes are expected together:
- “Reasonable steps” becomes “all reasonable steps.” This raises the bar considerably: from a duty to do what’s reasonable, to a duty to do everything reasonable, leaving employers with less room to argue a partial effort was sufficient.
- A new, broader obligation not to permit harassment of employees by third parties, and critically, this strand is not limited to sexual harassment. It’s expected to extend to harassment connected to any protected characteristic under the Equality Act 2010: race, disability, religion, age, sexual orientation, and so on.
That second point is the genuinely new territory for housing. An ASB visit where a tenant directs racist or disability-related abuse at an officer, rather than sexual harassment, currently sits outside WPA 2023’s scope but may fall within the broadened duty from October 2026, depending on the statutory conditions. Detailed regulations spelling out exactly what “all reasonable steps” requires in practice aren’t due until 2027, so until then, the EHRC’s existing technical guidance remains the most useful practical benchmark. For more on high-risk visits, see ASB visits and eviction notices.
What this doesn’t cover, and what still does
It’s worth being precise here, because vague treatment of this topic is common and unhelpful. Ordinary verbal aggression, threats, or violence from a tenant that isn’t connected to a protected characteristic (someone shouting at an officer because they’re angry about a repair delay, for example) was never, and still isn’t, an Equality Act harassment matter. That risk is, and remains, governed by the general duty of care under the Health and Safety at Work etc. Act 1974 and the Management of Health and Safety at Work Regulations 1999: the same duty that requires a lone working risk assessment and adequate control measures regardless of what a tenant says or doesn’t say. WPA 2023 and the incoming ERA 2025 changes sit alongside that duty, covering a specific slice of the risk. They don’t replace it.
What “reasonable steps” looks like for home-visiting staff
For a housing team, reasonable steps in practice tends to include:
- An anti-harassment policy that explicitly names tenants and other third parties, not just colleagues, as a source of harassment it covers.
- A visit-logging and check-in process that creates a record of who visited where and when, which may be useful evidence if a harassment complaint or a tribunal claim follows.
- A reporting route that doesn’t require the affected worker to raise it with the same manager who scheduled the visit, if that’s a barrier to disclosure.
- Regular refresher training, given UNISON’s own data shows 45% of housing workers say they lack the training they need for their job.
How The Sentry helps
The Sentry doesn’t replace your anti-harassment policy, but it can help evidence the reasonable steps you’ve taken. Check-ins and location sharing while active can provide a record of a visit; if an officer needs to report an incident, private incident reporting captures their account without needing to go through a line manager first. And if a visit turns into a live incident, the one-touch panic alarm records video (and audio, on the silent version) throughout, giving both the worker and the organisation a factual record rather than a disputed account after the fact. None of this depends on new hardware; it runs from a phone-based app your team can deploy in under an hour. The same practical concerns arise for local authority social workers.
Reviewing your anti-harassment policy ahead of the October 2026 changes? Book a demo and we’ll show you how check-ins and incident reporting support the reasonable-steps evidence trail.
Key dates
- 26 October 2024: WPA 2023 reasonable-steps duty on sexual harassment, including by third parties, already in force.
- 30 October 2026 (anticipated): ERA 2025’s “all reasonable steps” upgrade and the new, broader third-party harassment obligation covering protected characteristics.
- 2027 (anticipated): detailed regulations on what “all reasonable steps” means in practice, following public consultation.
FAQ
Does the Worker Protection Act cover harassment from tenants? Yes, but specifically sexual harassment. WPA 2023 requires employers to take reasonable steps to prevent sexual harassment of employees, including by third parties such as tenants. It doesn’t, as it currently stands, cover other forms of third-party harassment or general aggression.
What are “reasonable steps” under WPA 2023? The EHRC’s technical guidance points to a clear anti-harassment policy naming third parties, regular risk assessment of where harassment could occur, and an accessible reporting and complaints process. There’s no fixed checklist in the Act itself; tribunals assess it case by case.
What’s changing in October 2026? The Employment Rights Act 2025 is expected, from 30 October 2026, to strengthen the existing sexual harassment duty to “all reasonable steps” and introduce a new obligation covering third-party harassment linked to protected characteristics, not only sex. This date hasn’t yet taken effect at time of writing and should be treated as anticipated.
Can a housing association be liable for general tenant aggression under this law? Not under WPA 2023 or the Equality Act harassment framework, unless the aggression is connected to a protected characteristic. General violence or threats from tenants are covered separately by the ordinary health and safety duty of care under HSWA 1974 and MHSWR 1999.
Does this apply to council housing teams as well as housing associations? Yes. WPA 2023 and the Equality Act 2010 apply to all employers, including local authority housing departments, with no exemption for public sector landlords.
This article was written by Stuart Evans, co-founder of The Sentry.