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Updated EHRC Code of Practice for Services, Public Functions and Associations

On 21 May 2026 the Secretary of State laid the updated EHRC Code of Practice for Services, Public Functions and Associations before parliament. 

While this is not the code of practice for employers, it may impact some areas of your work. As a Proud Employer, Stonewall will continue to provide you with updates and information about the code and its implications. For our previous briefing on the Supreme Court Ruling in April 2026 and the subsequent interim update from the EHRC please see here.

Information on the Code 

The Equality and Human Rights Commission (EHRC) is responsible for promoting, explaining and enforcing the Equality Act 2010. The EHRC produces guidance to help organisations understand their legal obligations under the 2010 Act, including the Code of Practice on Services, Public Functions, and Associations (the “Services Code”).

The purpose of the Services Code is to provide explanations and examples of how the 2010 Act should be interpreted in practice. The Code is not law, but it is statutory guidance, meaning that Courts and Tribunals are required to take it into account when deciding discrimination claims. Organisations to which the Code applies therefore need to be familiar with its requirements.

The Code is relevant to those providing services, those exercising public functions, and membership associations. Updates to the Code are likely to have particular implications for organisations that provide single- or separate-sex services, and associations that limit their membership to particular groups.

There is a separate Code which covers employment directly and we are continuing to push for information about whether and how this will be updated.

The updated Code comes into force on 5th August at which point the 2011 code will be revoked. We are continuing to work with sector partners and parliamentarians to ensure the concerns of the trans+ community are heard and the challenges being faced by organisations are highlighted.

Information for Employers 

We have developed and will continue to provide you with a range of support. 

Briefings  

Stonewall have commissioned legal experts at Bates Wells LLP to support Proud Employers to better understand the updated Code and its potential implications in your work. These briefings are created for information purposes, they are not legal advice and should not be used as a substitute for legal advice.  

Read the written briefing prepared by Bates Wells here. 

Rewatch the webinar hosted by Bates Wells for Proud Employers. 

Read the FAQ document produced in response to common questions from Proud Employers.

Read the framework to help organisations decide how to provide their services. 

Peer Exchanges  

Stonewall have developed peer exchanges for organisations to come together to share ideas and reflect on next steps, as they prepare their organisational responses. To sign up to our bi-weekly peer exchange sessions please go to our member events page here  

Help Shape Our Work  

Stonewall recognises the impact of the updated Code continues to be a priority for you. We are keen to understand the practical implications the updated code is having on your workplace. We will use this information to continue to shape our support for you and to build an evidence base for our policy and influencing work

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