1. The Employment Rights Act 2025 implementation wave is accelerating on multiple fronts simultaneously
On 25 September 2026, the UK Department for Business, Innovation, Science and Trade published an updated implementation timeline for the Plan to Make Work Pay and the Employment Rights Act 2025, setting out implementation dates for a range of reforms during 2026 and 2027. From 1 October 2026, Employment Tribunal claim time limits increase from three to six months. From 30 October 2026, new trade union and workplace harassment reforms come into force, including strengthened trade union access rights, enhanced protections for workers participating in industrial action, and expanded employer obligations to prevent sexual harassment — including harassment by third parties. Future measures confirmed in the timeline include flexible working reforms, guaranteed hours, bereavement leave, equalities action plans, and regulation of umbrella companies.
Separately, on 25 September 2026, the government published its consultation response confirming that from 1 January 2027, employers will be required to provide workers with a standardised written statement of their right to join a trade union, including information on recognised unions, statutory access agreements, and relevant statutory protections, with annual reminders and notification of relevant changes. CEOs managing workforces in the UK are dealing with a rolling programme of employment reform — not a single change. The aggregate compliance burden, when viewed across all of these measures simultaneously, is substantially greater than any one update suggests in isolation.
2. Corporate reporting is being fundamentally restructured – and the consultation closes in November
On 7 September 2026, the UK Department for Business, Innovation, Science and Trade launched a public consultation to modernise corporate reporting, with the consultation closing on 30 November 2026. Key proposals include expanding reporting and audit exemptions for medium-sized companies, introducing a simplified reporting regime for SMEs, creating a potential threshold for very large companies, streamlining governance and remuneration disclosures, reforming the financial reporting framework, permitting greater use of digital communications and virtual AGMs, and introducing a solvency-based dividend regime.
The proposal to introduce a solvency-based dividend regime is the most significant corporate governance reform within this consultation and the one most likely to be missed. Replacing the current distributable profits test with a solvency-based framework changes how boards assess the lawfulness of dividend payments and the personal liability of directors who authorise them. Boards and company secretaries need to engage with this consultation before 30 November 2026 — and need to begin planning for the governance and reporting infrastructure changes it will require.
3. UK Deposit Return Scheme – registration is open, and the fee structure is confirmed
On 29 September 2026, Exchange for Change opened the first phase of registration for producers and retailer return points ahead of the UK Deposit Return Scheme's launch in October 2027. On 2 September 2026, Exchange for Change announced that producer fees will be set at 0 pence per unit during the first 15 months of operation — October 2027 to December 2028 — with fees from January 2029 expected to be 0.6 pence per unit for aluminium and steel containers and 2.3 pence per unit for PET containers, subject to review in May 2027.
The DRS registration window is now open. For businesses in the drinks, retail, and packaging industries, this is the point at which DRS compliance transitions from planning to operational execution. The fee structure confirmation allows businesses to begin modelling the financial impact with greater precision. CEOs who are not yet tracking DRS implementation as a live operational priority — rather than a 2027 problem — are behind the curve.
4. GDPR fines are about to become more predictable – and more consistently applied
On 21 September 2026, the European Data Protection Board launched a public consultation on Guidelines 04/2026 concerning the application of administrative fines alongside other corrective powers under the GDPR, with the consultation closing on 13 November 2026. The guidelines propose a harmonised framework for EU supervisory authorities to determine whether organisations should be subject to fines alongside, or instead of, other measures such as warnings, reprimands, compliance orders, or processing restrictions. The proposal sets out a common assessment methodology covering the nature of the infringement, organisational liability, intentional or negligent conduct, and whether a fine would be effective, proportionate, and dissuasive.
For many organisations, unpredictability in GDPR fining decisions has created uncertainty about actual financial exposure. The harmonised methodology these guidelines propose will change that — making enforcement more consistent but also more systematic. Once adopted, these guidelines will make it significantly easier for supervisory authorities to justify and impose fines, and significantly harder for organisations to argue that their particular circumstances warrant leniency. Businesses should review their GDPR compliance posture now, while the methodology is still in consultation.
5. The EU's new Public Procurement Act would replace all existing directives
On 9 September 2026, the European Commission published a proposal for a Regulation on public contracts and concessions — the Public Procurement Act — which would replace the existing EU public procurement directives with a single directly applicable regulation. The proposal aims to simplify procurement procedures, improve consistency across Member States, and support wider EU policy objectives. If adopted, it would affect contracting authorities, utilities, and economic operators by introducing updated procedural and compliance requirements across all public procurement and concession activities.
A directly applicable regulation — rather than a directive requiring national implementation — means that the new procurement rules would apply identically across all EU member states simultaneously. For businesses that participate in public procurement across multiple EU jurisdictions, this would eliminate the current patchwork of nationally transposed rules. However, it also means there will be no national flexibility in implementation. The proposal is at an early stage, but the direction of travel is clear and the commercial implications are significant.
