All Reasonable Steps on Set: The New Harassment Duty and the Screen Industry’s Own Principles

From 30 October 2026 the law expects more of businesses on harassment, and for the screen industries it meets a framework the sector already built for itself. The legal duty to prevent sexual harassment is strengthened, and the industry's own Set of Principles already sets out how that looks on a production. The two line up closely, and a business that follows the Principles is a long way towards meeting the duty.

This article covers England, Scotland and Wales; Northern Ireland has its own law and no equivalent statutory duty, so the legal part of this does not apply there, though the good practice does.

Businesses already have a duty to take reasonable steps to prevent sexual harassment of their staff. From 30 October 2026 two things change:

1. Preventative duty is raised to a duty to take all reasonable steps, a higher bar: a business would need to show that no further step could reasonably have been taken
2. A separate liability for third-party harassment is reintroduced, so a business can be liable where it fails to take all reasonable steps to prevent harassment of its people by others, such as audiences, visitors, contributors or suppliers, and this is not limited to sexual harassment as it covers harassment related to any protected characteristic.

The duty is anticipatory, meaning it is about mapping and reducing risk before anything happens, not just responding to a complaint. Breach of the preventative duty is enforced by the Equality and Human Rights Commission (EHRC) and can increase the compensation in a successful harassment claim, while the third-party liability gives a claim in its own right. Harassment awards are uncapped and include injury to feelings. The EHRC’s technical guidance and its eight-step employer guide set out what reasonable steps are expected to look like, and regulations are expected to spell them out further from 2027.

The sector is not starting from scratch. The screen industries' Set of Principles, developed by the BFI with BAFTA and expanded in 2021 to cover bullying, harassment and racism, set out a shared, zero-tolerance approach: everyone has a role, there are clear and confidential reporting routes handled by trained people, and victims and witnesses are protected from reprisal. They are built into the BFI Diversity Standards, so productions that take BFI funding already commit to them. In other words, the industry has already spent time turning the idea of a safe set into concrete, production-ready expectations.

The new legal duty asks a business to take all reasonable steps, and the Principles are a ready made way to show it has. Naming a trained point of contact for concerns, mapping harassment risks before a shoot (including third-party and location risks), briefing cast and crew, and running a reporting route that people trust are the steps the duty is looking for, and they sit squarely with what the Principles ask for.

The third-party liability matters most in the places screen work often happens: on location among the public, at venues and festivals, with audiences and contributors, and across a chain of suppliers and facilities. Those risks belong in the pre-production risk assessment alongside the physical ones.

Reporting has changed too. The Creative Industries Independent Standards Authority (CIISA) is now a ‘prescribed person’ for whistleblowing in the screen, music and theatre industries, so someone who raises a concern about harassment, discrimination or safety with CIISA can be protected under whistleblowing law. That sits alongside a production's own reporting routes. It also sharpens a point the Principles already make: confidentiality clauses and non-disclosure agreements must not be used to stop people reporting harassment or to silence those who have experienced it. A business relying on an NDA to manage a harassment problem is doing the opposite of taking reasonable steps.

The duty rewards preparation, and most of the work is organisational rather than legal so in practice, a production can:

• appoint and name a trained welfare or designated contact before the shoot, and tell everyone who it is and how to reach them;
• add harassment to the pre-production risk assessment, mapping third-party and location risks as well as internal ones, and record what is being done about them;
• adopt and actually circulate a Dignity at Work or anti-harassment policy, and build the Principles into contracts and call sheets rather than leaving them on a website;
• brief cast and crew at the start of each production, and give heads of department the backing to act on concerns early;
• run a reporting route that people trust, making clear that CIISA and other external routes also exist, and never use an NDA to prevent reporting; and
• keep a written record of the steps taken, since the duty is judged on what was done in advance, not on what is said after an incident.

The legal change and the industry's own rules are pulling in the same direction. A production that has a named welfare contact, a real risk assessment, a policy people have seen and a reporting route they trust is both meeting the duty and running a safer set. One that has none of these is exposed on both counts: to uncapped claims, and to the harm and loss of trust that the Principles exist to prevent.