Few people today can credibly claim they “don’t know” what sexual harassment is. While there’s still a place for awareness training, learning and development (L&D) teams need to take a more strategic approach to understanding the specific risks employees face and designing training accordingly.

That need is becoming more urgent in the UK as employers prepare for new sexual harassment prevention requirements taking effect October 30, 2026. Under the new requirements, employers will need to demonstrate that they have taken “all reasonable steps” to prevent sexual harassment in the workplace.

For L&D, this raises an important question: Is a once-a-year, company-wide training course enough? The answer increasingly appears to be no. Recent research from VinciWorks on organizational readiness for the new requirements suggests many employers still have significant gaps to address.

What the Data Tells Us About Harassment Preparedness

In July 2026, VinciWorks surveyed 985 UK-based HR and compliance professionals about their organizations’ readiness for the new requirement. The results revealed significant gaps in workplace sexual harassment training. Nearly half (47%) said their organization’s training needed improvement, while 14% said they provided no sexual harassment training at all. Only 7% rated their training as excellent.

Managers are a particular area of concern. One in five organizations (21%) provide no specific sexual harassment training for managers, even though managers are often the first people employees turn to when something has happened.

Sexual harassment training is one of the trickiest compliance obligations to get right. For years, compliance training has had a reputation for being overly legalistic, generic or disconnected from employees’ day-to-day experiences.

That creates an opportunity for L&D to help change the conversation on sexual harassment by building a broader prevention strategy that reflects the actual risks employees face.

Start With Risk, Not Training

A company-wide course still has an important role. Employees need to understand their organization’s standards, know how to recognize sexual harassment, understand how to report concerns and know their responsibilities when they witness inappropriate behavior. But those baseline expectations should be only the starting point.

Different employees face different risks. A salesperson who regularly travels to conferences may encounter situations that are very different from those faced by an employee who works almost entirely from home. A receptionist interacting with members of the public face different risks from a software developer. A night-shift manager has responsibilities that an entry-level employee may not.

This is why the sexual harassment risk assessment should inform the training strategy, not the other way around. If an organization has not conducted a comprehensive assessment of where and how sexual harassment could occur, simply rolling out another course is unlikely to address the underlying risk. For training to be meaningful as part of an organization’s “all reasonable steps” approach, it should connect to the situations employees and managers are actually likely to encounter.

Give Managers Training They Can Use

Manager-specific training should be a cornerstone of the learning strategy. Managers are oftentimes the first person an employee approaches after experiencing or witnessing sexual harassment. How a manager responds in that initial conversation can have a significant impact on the employee’s experience, and on the organization’s subsequent response.

That first hour after disclosure, even in those first five minutes, is when trust is built or lost. Managers should understand how to respond when an employee makes a disclosure, including how to take the concern seriously, avoid making promises they cannot keep and follow the organization’s established reporting and escalation procedures.

They also need to understand what not to do. For example, a manager should not attempt to conduct their own investigation, make promises about confidentiality or dismiss a concern because they do not believe the behavior meets the definition of harassment.

This has taken on an additional compliance dimension since April 6, 2026. Under the Employment Rights Act, sexual harassment was added to the whistleblowing framework, meaning a disclosure about sexual harassment may qualify for whistleblowing protection when the statutory tests are met. A poorly handled conversation can therefore develop into several overlapping legal risks.

Make Scenarios Relevant to Employees

Effective training depends on relevance. Employees are more likely to engage with training when they can see how it connects to their work. Even something as simple as American accents for a British audience, or a factory floor scenario to office workers, takes people out of the learning experience and makes them more likely to think, “this doesn’t apply to me.”

Instead, training should reflect the situations different groups of employees may encounter. For example, frontline employees might need to practice responding to harassment by customers. Sales teams might need scenarios involving clients at conferences or after-work events. Remote teams may need examples involving messaging platforms and video calls.

This type of role-based approach also becomes increasingly important as employers prepare for the October 30 requirements. The Employment Rights Act includes an extension of third-party liability, beyond just sexual harassment. Employers can’t treat third-party harassment as unpredictable simply because the harasser is outside the organization. If third-party contact is part of the work, the risk is foreseeable, and the employer needs to show that it planned for it.

That makes scenario-based training particularly valuable. All reasonable steps is a broad legal standard, and one that’s tricky to show with one broad-based course rolled out to everyone once a year. A broader, risk-informed learning strategy can demonstrate how training connects to the organization’s actual prevention efforts.

Measure More Than Training Completion

As fundamental as training is to preventing sexual harassment, it’s only ever part of the picture. A 98% completion rate tells you that people opened the course. It does not tell you whether a manager knows what to do tomorrow morning when somebody reports harassment.

L&D needs to build deeper effectiveness measures into a compliant sexual harassment prevention program. This could include conducting a brief survey to understand if employees know how to report an incident or whether managers feel confident receiving a disclosure. Other sources of information, such as anonymous employee surveys, incident data and finding from investigations, can provide additional insight into whether the organization’s prevention efforts are addressing its actual risks.

Build the Foundation Now

The October 30 deadline is approaching, but organizations do not need to solve every aspect of their sexual harassment prevention strategy overnight. They do, however, need the foundation in place.

That starts with an up-to-date and comprehensive risk assessment that considers where sexual harassment could occur across the organization and which employees may face particular risks. From there, organizations can develop a plan to mitigate those risks through training, policies, manager support, reporting processes and other preventive measures.

The last thing we want is to be hauled before a tribunal or court and asked to explain why perfectly reasonable steps that could have prevented harassment were never done.