The Equality and Human Rights Commission (EHRC) has extended its legal agreement with McDonald’s after further serious allegations of workplace sexual harassment came to light. Announced on 7 November 2025, the strengthened action plan is designed to ensure the company takes more effective steps to prevent harassment and protect its workforce.
This move reflects a broader shift in regulatory expectations following the introduction of the Worker Protection (Amendment of Equality Act 2010) Act 2023, which took effect on 26 October 2024. The law places a proactive duty on employers to take reasonable steps to prevent sexual harassment—before issues arise.
McDonald’s first entered into a legal agreement with the EHRC in February 2023, after more than 400 workers reported bullying and harassment. The newly extended agreement suggests the regulator is not yet satisfied that risks have been adequately addressed.
Under the strengthened plan, McDonald’s must:
- Conduct regular site inspections
- Strengthen risk assessments
- Survey staff every quarter
- Ensure complaints against managers are handled independently
- Work with external safeguarding experts to create a chainwide safeguarding plan
EHRC Chair Kishwer Falkner emphasised that these updated steps are tailored to how McDonald’s operates and will offer employees “clear routes to report and resolve complaints.”
EHRC enforcement action as unusual and it signals significant concerns at the company.
What the Law Now Requires
Under the Worker Protection Act amendments, employers must take reasonable steps to prevent sexual harassment, whether it comes from colleagues, managers, customers, clients, or other third parties.
You cannot wait for sexual harassment to occur before acting. If an incident has already happened, measures must be put in place to prevent recurrence.
Failure to meet this proactive duty can result in enforcement action from the EHRC, and higher compensation awards in successful tribunal claims
Practical Steps for Organisations
The law does not prescribe a fixed list of actions. What is considered “reasonable” depends on factors such as:
- Organisational size
- Nature of the work
- The working environment
- Contact with third parties
- Previous incidents
- Available resources
Areas to consider include:-
Risk Assessment: Identify where and how sexual harassment risks might arise. This includes both internal interactions and contact with customers, clients, or the public.
Preventative Measures: Depending on the risks identified, proportionate measures may include:
- Clear and accessible policies
- Regular training
- Anonymous or confidential reporting routes
- Independent investigation procedures
- External safeguarding or cultural audits
Visible Leadership Commitment: Cultural change depends on genuine commitment from leadership. This includes consistent modelling of expected behaviours and clear responses when standards are breached.
Documentation: Keep written evidence of policies, training, risk assessments, and steps taken. This helps demonstrate compliance and readiness if the EHRC or a tribunal requires proof of reasonable steps.
