The government’s revised Code of Practice on Picketing is now in force across Great Britain from Thursday 5 March 2026. The Department for Business and Trade (DBT) has published the update on GOV.UK, replacing the 2024 version and confirming it as the operative guidance for employers, unions and the public. (gov.uk)

DBT’s explanatory memorandum sets out why the change was needed. The Employment Rights Act 2025 amended section 219 of the Trade Union and Labour Relations (Consolidation) Act 1992 and repealed section 220A on union supervision of picketing. It also repealed the Strikes (Minimum Service Levels) Act 2023, so employers can no longer issue ‘work notices’ during strikes. (gov.uk)

Two practical points on scope and process matter for HR. First, the code extends to Great Britain (England, Scotland and Wales). Second, it proceeded under the negative procedure: neither House objected within the 40‑day window, allowing the Secretary of State to bring it into effect by order. (gov.uk)

This is guidance, not statute. The code doesn’t create legal obligations, and failure to follow it doesn’t of itself trigger liability. But it is admissible in evidence and may be taken into account by courts, employment tribunals and the Central Arbitration Committee-so it will frame how disputes are assessed. (assets.publishing.service.gov.uk)

What changes at the gate is the model. With the 2016 supervisor requirement gone, the code recommends appointing an experienced picket organiser, keeping close contact with the police and managing headcount. As a rule of thumb, it says the number of pickets should “in general” not exceed six at any entrance or exit-useful for site planning and steward briefings. (assets.publishing.service.gov.uk)

Location still matters. Lawful attendance is at or near a worker’s own place of work; statute doesn’t define that phrase, which means multi‑site and hybrid arrangements need careful mapping. A union official may also attend where they represent a member on the line. For distribution hubs with shared gates, clarify which entrances are used by workers of the employer in dispute. (assets.publishing.service.gov.uk)

The boundary on secondary action is restated. Statutory immunities don’t cover calls for solidarity action by workers whose employer isn’t party to the dispute. However, peaceful pickets at their own workplace may try to persuade contractors or delivery drivers not to cross the line, so expect potential disruption to third‑party flows even where your own staff aren’t striking. (assets.publishing.service.gov.uk)

Police powers are unchanged but practical. Officers can limit numbers where there’s a risk of disorder, and conditions may be imposed on larger assemblies under the Public Order Act 1986. The code urges organisers to seek police directions on headcount and positioning-HR and site leads should record these conversations and ensure entrance routes remain unobstructed. (assets.publishing.service.gov.uk)

Contingency planning now sits front and centre with work notices gone. The code highlights safeguards for essential supplies and services-from medicines to safety procedures-and recommends agreeing arrangements in advance with unions. In practice, that means mapping critical deliveries, pre‑agreeing access windows and documenting any exceptions. (assets.publishing.service.gov.uk)

Key dates for briefing packs: core industrial action changes in the Employment Rights Act 2025 took effect on 18 February 2026, and the updated picketing code followed on 5 March 2026. HR policies, manager training and site instructions should be updated to reflect both steps, with a focus on evidence‑ready processes if disputes escalate. (gov.uk)