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Update: 13.07.2026
EHRC draft guidance review
Update: 25.06.2026
Following the Supreme Court Ruling in 2025, and how this might impact trans colleagues, the Equality and Human Rights Commission has published a draft updated Code of Practice for services, public functions and associations, setting out how organisations should interpret and apply the Equality Act 2010 in practice. (source: gov.uk)
The draft was formally laid before Parliament on 21 May 2026 and is currently under review. Parliament has a 40-day scrutiny period, meaning this stage is expected to conclude around 30 June 2026 (subject to parliamentary sitting days). (source: EHRC)
At present, the Code is not yet in force and has no legal status. It will only become legally applicable once the review period is complete and the government sets a formal commencement date.
What this means for organisations
Although still in draft, the Code provides a clear indication of future expectations. Organisations should treat this as a near-final framework and begin preparing now:
- Review customer-facing policies and services to ensure they align with Equality Act duties
- Assess data collection practices, particularly around protected characteristics and how data is used
- Brief senior leaders and operational teams on likely changes and potential risks
- Identify gaps in governance, training, and decision-making processes
Plan updates to internal guidance and staff training ahead of formal implementation
Early preparation will reduce the risk of rushed changes once the Code is finalised and will support stronger evidence of compliance from day one.
In summary: while awaiting formal commencement, this is a critical window for organisations to review, align and strengthen their approach to equality in service delivery.
