The draft published on 30 July 2026 is exactly that: a draft. Acas is asking for views before midnight on 23 September 2026. After that, Acas will consider the responses and may revise the draft further. Only then does it go to the Secretary of State for Business, Innovation, Science and Trade for approval, and only after that is it laid before Parliament.

No employer needs to change anything yet. On a realistic timetable, the earliest the updated Code could come into force is late 2026, and a move into 2027 is just as likely. The current 2015 Code (itself only lightly amended since 2009) remains the one that tribunals apply until the new version is formally in force.

That said, the direction of travel is clear, and several of the changes matter more for screen than for most sectors, because of how the screen workforce is structured.

The Code carries real weight. A failure to follow it doesn't automatically make an employer liable, but employment tribunals take it into account, and can adjust any award by up to 25% either way for unreasonable failure to follow it. That applies whether the case is brought by the employer or the worker.

Screen is a sector built on freelance and project-based engagement more than almost any other. The draft Code's shift in terminology reflects this: it moves from “employee” to “worker” throughout, except where the specific legal status of employee is intended. Worth flagging: the 25% tribunal adjustment itself only applies to employees, under section 207A of the Trade Union and Labour Relations (Consolidation) Act 1992, so the practical effect of the wider “worker” language needs care in a sector where freelancers make up such a large share of the workforce.

A few points stand out from the draft:

Informal resolution gets its own statutory footing. The current Code only touches on resolving things informally in its non-statutory foreword. The draft brings this into the statutory text itself (paragraphs 16 to 23 for employer concerns, 53 to 61 for worker concerns), meaning tribunals will take it into account directly. For a sector where people already prefer to sort things out through conversation rather than paperwork, this is a welcome formal recognition of what good managers already do, but it also means informal handling will now be scrutinised against a written standard.

Less adversarial language throughout. Terms like “allegations”, “case to answer” and “first offence” are being replaced with plainer, less legalistic wording, and “disciplinary” and “grievance” issues become “concerns” outside formal procedures.

New guidance on equality and reasonable adjustments. The draft signposts the Equality Act 2010 explicitly for the first time (paragraphs 14 to 15), with examples such as accessible venues, accessible documents, and allowing a support worker or interpreter. Screen productions, with their mix of freelancers, short contracts and locations, will need to think about how this applies in practice. Our own guide on the Equality Act and tackling discrimination in creative workplaces covers the underlying obligations in more detail.

Tighter limits on suspension. Suspension during an investigation should only happen where necessary to protect the investigation, the organisation, other staff or the person under investigation, and it should be brief and kept under review (paragraphs 28 to 30). Given how disruptive a suspension can be on a production, this is a useful discipline to build in now.

A new section on mediation and facilitated conversations. This doesn't exist in the current Code at all. The draft encourages considering mediation at multiple points in a process, which may suit the relationship-heavy, crew-based dynamics of screen work better than a formal hearing. See our guidance on why you should consider mediation to resolve disputes, and our e-learning module on understanding mediation in the screen industry.

Shorter, clearer grievances expected from both sides. Workers will be expected to set out what they'd like to happen and what informal steps they've already tried, and to keep the initial written grievance short. Employers face a mirrored expectation when notifying someone of a formal disciplinary meeting.

Consolidated, clearer guidance on the right to be accompanied, including new guidance reflecting the 2018 Talon Engineering Ltd v Smith case on postponing a meeting for more than five working days when a companion isn't available.

AI in disciplinary and grievance processes is flagged as an open question, with no proposed guidance yet. Given how quickly AI tools are being adopted in production and post-production workflows, this is one to watch and worth responding on if you have a view.

Nothing here is confirmed, and nothing needs to change in your policies today. But three things make it worth getting ahead of this rather than waiting for the final version:

First, most of what's proposed reflects good practice Acas already recommends, regardless of whether it ends up in the statutory Code. Encouraging early, informal conversations, using plain language, and thinking about reasonable adjustments are all things worth doing now, consultation or not.

Second, screen's freelance-heavy structure means disciplinary and grievance issues are often handled by people without HR support, on tight production timescales, where a fair, well-documented process matters most and is hardest to get right under pressure. Building the habits the draft Code describes now, rather than scrambling to update a policy once it's in force, is the lower-risk path.

Third, once the Code does come into force, tribunals will apply it to how a matter was actually handled, not to when your written policy was last updated. Getting your practice, not just your paperwork, aligned with the direction of travel reduces exposure either way.

Our Compliance Library already reflects much of the direction this draft Code is taking, in plain language written for screen, and is a good place to start.

Acas wants to hear from employers, workers, and representative bodies across all sectors, including from organisations without ready access to legal advice. If the freelance-heavy structure of screen, or any of the points above, raises something Acas should hear about, read the full draft Code and respond to the consultation before 11:59pm on 23 September 2026.

We'll update this guidance once the Code's final form is confirmed.