Business and HR teams now have a firm date. Regulations laid before Parliament on 21 January 2026 revoke the Code of Practice on Reasonable Steps linked to Minimum Service Levels, with the change taking effect on 6 April 2026 across England, Scotland and Wales, according to the Department for Business and Trade’s own guidance page which confirms the code is being withdrawn. (gov.uk)

This tidy‑up follows December’s repeal of the Strikes (Minimum Service Levels) Act 2023 by the Employment Rights Act 2025 on 18 December 2025. DBT trailed the policy shift in August 2024; the legislative follow‑through has now removed the legal scaffolding that supported Minimum Service Levels. (legislation.gov.uk)

Practically, two elements fall away for employers that operate in affected services or supply them. First, the ability to issue ‘work notices’ naming individuals required to work during a strike. Second, unions no longer face the statutory ‘reasonable steps’ obligation that sat alongside those notices. Both were concepts created by the now‑repealed Strikes Act and explained in the government’s code. (gov.uk)

Planning should pivot over the next ten weeks. Replace any Minimum Service Levels playbooks with strike‑day staffing plans built on voluntary overtime, mutual‑aid agreements and advance rota modelling. Re‑establish escalation routes with recognised unions and agree information‑sharing protocols for safety‑critical roles ahead of the Easter period, when staffing is already tight for many operators.

For context, DBT’s code set out six sectors where Minimum Service Levels could apply: health, fire and rescue, education, transport, nuclear decommissioning and border security. Even if you are not directly in scope, your exposure may be indirect via patient transport, exam timetables, rail access, ports or airports. Map those dependencies now and rehearse contingency steps without assuming a legally mandated minimum service. (gov.uk)

Retire any ‘compliance notice’ templates that were drafted to reflect the code’s recommended steps for unions. Those letters were designed for a regime that no longer exists and will only inflame already tense disputes if repurposed. Focus instead on updated manager scripts, strike‑day briefings and agreed safe‑operating thresholds. (gov.uk)

Keep data hygiene front and centre. The withdrawn framework itself warned against handling special‑category data such as union membership in operational documents. Whatever your internal systems, keep HR, legal and data teams aligned on what can be recorded, who can access it and how long it is retained. (gov.uk)

Territorially, this change covers Great Britain; the government page for the code specifies England, Scotland and Wales. Northern Ireland was not in scope of the Strikes Act and maintains its own industrial relations framework, so GB‑based employers with NI operations should plan separately. (gov.uk)

Budgeting needs a refresh. Without a work‑notice fallback, more employers will lean on pre‑agreed overtime banks, training additional cover and short‑term outsourcing. Build those costs into Q2 forecasts, keep a watching brief on supplier SLAs and be ready to flex service levels or opening hours when labour availability is constrained.

What’s next: further Employment Rights Act commencements land from April 2026, including day‑one rights on statutory sick pay and family leave. One consequential SI on parental and paternity leave has already been made, signalling an active secondary‑legislation pipeline. Expect more guidance and sector updates through March. (vwv.co.uk)