Collective redundancy obligations in the UK currently arise under the Trade Union and Labour Relations (Consolidation) Act 1992 (TULRCA) when an employer proposes 20 or more redundancies within a 90-day period at one establishment.
In practice, an “establishment” is usually interpreted as a specific site – such as a store, office, or warehouse. As a result, organisations operating across multiple locations may carry out large-scale redundancies across different sites without triggering collective consultation obligations, provided that fewer than 20 redundancies occur at any single establishment.
A proposed shift in the law
Section 29 of the Employment Rights Act 2025 proposes amendments to TULRCA that would introduce an additional, alternative threshold based on the total number of redundancies across the entire business.
In other words, even if fewer than 20 redundancies are proposed at any single establishment, employers could still be required to undertake collective consultation if the total number of proposed redundancies across the organisation reaches a specified level.
Government consultation now open
The UK government recently launched a consultation to determine what this new threshold should be.
Its preferred approach is a single fixed threshold, likely to fall somewhere between 250 and 1,000 redundancies across the business as a whole.
However, the consultation also explores a tiered model, where the trigger would vary depending on organisational size:
- 250 redundancies for organisations with 0–2,499 employees
- 500 redundancies for organisations with 2,500–9,999 employees
- 750 redundancies for organisations with 10,000+ employees
What this means for you
If implemented, these changes could significantly expand the circumstances in which collective consultation is required, particularly for large organisations with complex or multi-site workforces:
- Redundancy planning may need to be assessed across the whole organisation, not just site-by-site.
- Workforce reduction strategies that previously fell outside collective consultation rules may soon fall within scope.
- Early workforce planning and legal input will become even more important.
The consultation is open until 21 May 2026.
