Revised Code of Practice on Picketing comes into effect under UK health and safety law

Revised Code of Practice on Picketing comes into effect under UK health and safety law: guidance for boards and safety teams

What has changed

The Code of Practice on Picketing has been revised and a specific day of implementation set. The revised code will come into effect on 5 March 2026 and is issued by the Secretary of State under section 205(4) of the Trade Union and Labour Relations (Consolidation) Act 1992. The change clarifies expectations for how protest activity interfaces with workplace safety and access to premises.

Why this matters

For organisations, the update shapes lawful and safe handling of protests at or near workplaces. It affects governance around worker and contractor access, risk management during disruption and the duty to minimise risk to people and operations. It also interacts with general health and safety law where disruption could create hazards or impede safe working conditions.

Key duties for employers

Review and update protest management policies in light of the revised code. Ensure risk assessments cover scenarios such as blocked access, crowd control risks and potential interference with safe systems of work. Communicate with workers and unions, and provide appropriate instructions to supervisors and security teams. Revisit contractor arrangements to ensure any third party engaged in access control understands expectations under UK health and safety law. Align governance with the organisation’s health and safety management system, for example ISO 45001.

• Update incident reporting and near-miss processes during protest activity
• Clarify who has authority to approve access restrictions and how to document decisions
• Review emergency arrangements and communication protocols

Enforcement and sanctions

Non compliance could lead to enforcement actions under health and safety or employment related regimes. Organisations should anticipate heightened scrutiny during periods of protest activity and ensure there is clear evidence of risk assessment, decision making and worker consultation.

Steps to achieve compliance

1. Map where protests could affect operations and assess related risks
2. Review and update policies, procedures and training for managers and frontline supervisors
3. Engage workers and union representatives in planning and drills
4. Update contractor arrangements and ensure competent advice where required
5. Prepare incident response and business continuity plans and test them
6. Ensure ISO 45001 alignment and ongoing compliance with HSE expectations

Governance and practical management

Effective governance supports regulatory compliance and robust risk management during protest activity. Consider engaging a competent person for health and safety advice, and leverage structured management system support to maintain control measures and monitoring. Synergos Consultancy can support with ISO 45001 occupational health and safety management to help integrate protest risk into systematic controls.

Wrap up

The revised Code of Practice on Picketing requires duty holders to refresh protest management arrangements and demonstrate compliance with UK health and safety law when protests intersect with workplace safety. Proactive planning, clear governance and timely training will support continued safe operations and regulatory compliance.

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