EHRC Code Implementation: Key Themes Emerging from Our Recent Network Discussions
Supporting colleagues through change with clarity, respect and inclusion
As organisations prepare for the implementation of the revised EHRC Code of Practice, we recently brought together HR, DEI professionals, legal specialists and LGBTQ+ Network Chairs from a range of sectors to share experiences, challenges and practical approaches.
While organisations are at different stages of preparedness, a number of consistent themes emerged. The discussions highlighted that, for many organisations, the challenge is no longer understanding the legal position alone. It is managing the human impact, maintaining trust and supporting all colleagues through a period of uncertainty.
The legal changes may be limited. The cultural impact is not.
Across the discussions, there was broad agreement that many employees are feeling anxious, regardless of whether significant operational changes are required within their organisation.
For transgender, non-binary and intersex colleagues, concerns centred on what the changes might mean for their sense of safety, belonging and inclusion. Participants observed that the fear often relates less to the practical implications of the Code itself and more to concerns that wider public debate could influence workplace behaviour or embolden inappropriate conduct.
At the same time, organisations recognised that some women and other colleagues also have genuine questions about privacy, dignity and the practical implementation of policies. These perspectives should not be dismissed or assumed to be incompatible with creating an inclusive workplace.
The consensus was that organisations should avoid framing this as one group versus another. Instead, the focus should remain on ensuring everyone is treated with dignity and respect while applying organisational policies consistently, fairly and lawfully.
Communication is critical
One of the strongest themes was the importance of proactive communication.
Several organisations noted that silence can increase uncertainty, allowing misinformation or speculation to fill the gap. Others shared that they had deliberately taken a low-profile approach to policy changes to avoid creating unnecessary concern.
There was no single right approach. However, there was clear agreement that organisations should communicate openly about:
- what has changed;
- what has not changed;
- the organisation’s expectations around respectful behaviour; and
- where colleagues can access support and ask questions.
Participants agreed that communication should be factual, balanced and reassuring rather than reactive.
Different groups need different support
A recurring theme was that different colleagues may require different types of support.
Many organisations are establishing or expanding listening sessions for transgender, non-binary and intersex colleagues, recognising that these employees may be particularly affected by the current climate.
Equally, several participants felt there should be opportunities for women, allies, managers and colleagues with questions to seek information in a respectful environment. Providing separate spaces for these conversations can encourage more open discussion and avoid placing undue pressure on any one group to educate others or defend differing viewpoints.
The objective is not necessarily to bring everyone together into a single conversation. Different groups may have different concerns, experiences and support needs. Organisations should create opportunities for each group to be heard while ensuring everyone understands the organisation’s expectations around dignity, respect and inclusion.
Network Chairs continue to play a vital role
LGBTQ+ Network Chairs described balancing their network responsibilities alongside their day jobs while supporting colleagues through a particularly sensitive period.
Many have become the first point of contact for anxious employees, providing reassurance, signposting support and feeding concerns back into HR and Inclusion teams.
Participants highlighted the importance of recognising this additional emotional labour and ensuring Network Chairs have access to clear organisational messaging, senior sponsorship, decision-makers and appropriate resources. Employee networks should be partners in supporting inclusion, not expected to manage organisational risk or interpret legal changes on behalf of the business.
Preparation is already underway
Many organisations are taking practical steps to prepare for implementation.
Examples shared included:
- reviewing facilities and workplace policies;
- auditing buildings against current requirements;
- updating internal guidance for managers;
- developing transition guidance and support materials;
- monitoring employee relations data for emerging trends; and
- expanding allyship and inclusive leadership training.
For some organisations, these reviews confirmed that relatively few physical changes would be required. Sharing this information internally has helped reassure colleagues that existing arrangements already align with legal requirements.
A changing landscape for DEI
The discussions also reflected broader changes affecting diversity, equity and inclusion.
Many organisations continue to experience budget pressures, restructures and increased legal scrutiny, particularly those operating internationally or working with global clients. At the same time, participants noted a growing shift away from highly prescriptive approaches towards more flexible, evidence-based and intersectional models of inclusion.
There was strong support for practical benchmarking tools that help organisations understand their current position and identify meaningful areas for improvement without imposing a one-size-fits-all model. Participants also discussed the importance of ensuring future benchmarking reflects organisational maturity and business context, rather than rewarding a checklist of activities.
Looking ahead
As organisations move towards implementation of the revised EHRC Code, participants agreed that leadership will be defined not simply by legal compliance, but by how organisations support their people through change.
Creating psychologically safe workplaces means recognising that colleagues may experience this moment differently. Some employees may be seeking reassurance about their own safety and inclusion. Others may have genuine questions about privacy, dignity or practical implementation. Both deserve to be heard respectfully.
The role of employers is not to resolve every societal debate. It is to provide clear leadership, apply policies fairly, comply with the law and foster a workplace culture where everyone is treated with dignity and respect.
Key Takeaway
This is a moment for thoughtful leadership.
Organisations should focus on clear communication, consistent application of policies and creating opportunities for colleagues to ask questions in safe and respectful environments.
Supporting transgender and non-binary colleagues remains essential. Equally, organisations should provide space for women, allies and other colleagues who may have questions or concerns. These conversations do not always need to happen together because different groups may need different types of support.
The common thread is mutual respect. Every colleague should feel listened to, organisational values should be upheld, and everyone should understand the standards of behaviour expected in the workplace. By approaching implementation with empathy, fairness and transparency, organisations can strengthen trust and reinforce an inclusive culture for everyone.
Resources
This includes practical guidance for leadership and team leaders implementing the Code, and a toolkit for DEI and Inclusion managers on Coming Out at Work.
For live updates on the Equality Act Code of Practice (Services & Public Functions) as it takes effect on 5 August, visit our dedicated update page. Read the live update
