UK film and television employers face a wider legal duty to protect staff, cast and crew after new anti-harassment legislation took effect across the country last Friday.

Under the change, employers can be held liable when workers are harassed by third parties. They must take “all reasonable steps” to prevent that conduct, while claims may be filed up to six months after an incident. The measure forms part of the Employment Rights Act, a major reform from the ruling Labour Party.

“These changes give victims much stronger legal protections,” the government said as the legislation, which applies across all industries, came into force.

A duty that extends beyond the set

For productions, the potential exposure is broad. A company or studio could face a claim if a cast or crew member is harassed by an agent, somebody encountered on location or even a person with no connection to the project.

Elizabeth Peyton-Jones, who runs The Talent Trust, said employers can no longer argue that another person’s conduct was outside their control. “This is a significant change,” she said. “You have to take responsibility. And the duty of care reaches beyond the set.”

That expanded responsibility has prompted questions about wrap parties, late-night work, hotel stays, travel to and from sets, street interviews and filming situations in which crew members must accompany third parties. At least one large production outfit has reportedly included wrap parties, hotels and late-night work in its risk assessments.

Peyton-Jones said the informal nature of a wrap party could complicate matters, particularly if an incident is not reported until after a production ends. She argued that companies should have a mechanism allowing people to raise concerns, rather than relying on an assertion that management did not know what happened.

Studios and producers update their policies

Large UK production groups and studios have been preparing for the new requirements, with some revising their harassment policies. One HR executive at a major company said contractual terms for future productions had been updated to account for the third-party provisions.

Pact, the trade body representing hundreds of UK independent producers, also sent members a legal note last week urging them to update anti-harassment and bullying policies to remain compliant. Training organization ScreenSkills has revised the anti-bullying and harassment module in its training passport.

Awareness is not universal. A recent survey from UK arbitration service Acas found that two-fifths of employers across all industries did not know about the legal changes.

Max Rumney, Pact’s deputy CEO, said members are struggling with the question of “where does the buck stop?” He added that the legislation was, in many respects, designed for working environments different from film and television production.

Detailed guidance is not expected until early 2027, even though the law is already in effect. The UK departments responsible for Business, Innovation, Science and Trade and for Digital, Culture, Media and Sport have been meeting trade associations, holding webinars and encouraging policy updates. They did not provide specific examples establishing when an employer would or would not be liable.

The structure of screen production creates further complications. Some independent companies have only one or two people and no HR department. Movies can also be managed through companies formed for one project and dissolved afterward, raising questions if an incident is reported months later. Rumney nevertheless believes larger productions may prove more problematic, saying smaller indies tend to know how to manage their smaller projects.

Barriers to reporting remain

Industry figures consulted about the legislation rejected the suggestion that it would immediately produce a flood of complaints. Much of the sector’s workforce is freelance, and Peyton-Jones said she expects resistance to reporting misconduct to continue.

Previous Talent Trust research identified a “silence gap” on UK productions. One report found that 40% of respondents did not feel respected or treated with dignity on a production, while 76% worried that speaking up could result in unfair repercussions.

Some industry figures hope that gap will narrow following the launch of CIISA’s long-expected anonymous whistleblowing service. The new legal protections could also help, although their effect may take time to emerge.

The legislation arrived amid continuing attention on harassment allegations in UK entertainment. It took effect on the same day that a prosecuting barrister delivered closing arguments in Russell Brand’s trial. Brand is accused of three counts of rape, three counts of sexual assault and one count of attempted indecent assault. He denies all allegations and says all relationships were consensual.

ShowBiz Take

This is more than a routine policy update for the screen business. Productions routinely move between sets, locations, hotels, transport and social events, while many project companies exist only temporarily. The law’s reach into third-party conduct therefore places new weight on risk assessments, reporting systems and contractual protections beyond the formal workplace.

The central tension is already clear: employers must comply now, but the detailed guidance intended to explain the boundaries will not arrive until early 2027. Until then, producers and studios must interpret what “all reasonable steps” means for the highly varied circumstances of film and television work.

What Happens Next?

Production companies are expected to continue reviewing policies, contracts, training and reporting procedures while awaiting the government’s detailed guidance. The unresolved issue will be how far employer responsibility extends when alleged harassment happens away from set, after hours or after a temporary production company has closed.