September 2026 UK General Legal Update

Purpose

This update summarises the key legal developments included in the September 2026 legal update. It highlights changes affecting Quality, Environment, Information Security, Health & Safety and wider compliance obligations, helping organisations identify new and emerging requirements for legal registers, compliance evaluations and management system reviews.

Download the full update

Upcoming legislation

These measures progressed or were published during September 2026 but were not yet fully in force.

Cyber Security and Resilience (Network and Information Systems) Bill

Status: Completed Grand Committee in the House of Lords and published as HL Bill 49, as amended in Grand Committee, on 7 September 2026. It had not received Royal Assent and was not yet law.

The Bill proposes substantial reform of the UK’s cyber security and operational resilience framework, including:

• Bringing qualifying data centres, managed service providers and large load controllers within the NIS regime.
• Allowing regulators to designate critical suppliers.
• Expanding incident-reporting and customer-notification requirements.
• Strengthening regulators’ information-gathering, enforcement and penalty powers.
• Enabling strategic priorities, codes of practice and national security directions.
• Introducing wider regulatory cost-recovery arrangements.

Organisations should treat the Bill as a horizon-scanning item and monitor its remaining parliamentary stages, final wording, commencement regulations and supporting guidance.

Artificial Superintelligence Bill

Status: Received its first reading in the House of Commons on 8 September 2026. Its second reading was scheduled for 13 November 2026. It had not received Royal Assent and was not law.

The Private Member’s Bill proposes:

• Prohibiting the development, deployment and operation of artificial superintelligence systems.
• Establishing monitoring and control powers.
• Defining the systems and activities falling within scope.
• Creating associated oversight and enforcement arrangements.
• Operating alongside existing data protection, cyber security, product safety and sector-specific requirements.

The Bill remained at an early parliamentary stage. Organisations should record it as proposed legislation rather than a current compliance obligation.

New legislation

These legal texts were made, published, commenced or became applicable during September 2026, or were included because they introduced requirements commencing shortly afterwards.

Employment Rights Act 2025 (Commencement No. 5 and Transitional Provisions) (Amendment) Regulations 2026

Made: 1 September 2026
Commencement: Regulation 5 took effect on 2 September 2026. Section 152 and Schedule 12 to the Employment Rights Act 2025 came into force on 1 October 2026, subject to transitional provisions.

The Regulations:

• Commence provisions increasing the time limits for specified employment tribunal claims.
• Apply the extended periods where the relevant date occurs on or after 1 October 2026.
• Preserve the previous time limits where the relevant date occurred before 1 October 2026.
• Affect claims under employment rights, trade union, TUPE and related legislation.
• Correct wording in earlier commencement regulations.

Employers may need to update dispute-management procedures, template correspondence, litigation trackers and employment record-retention arrangements.

Customs (Tariff and Miscellaneous Amendments) (No. 6) Regulations 2026

Made: 7 September 2026
Commencement: On the dates specified in the Regulations.

The Regulations amend the UK customs and import duty framework by:

• Updating Bhutan’s treatment under the Developing Countries Trading Scheme.
• Revising aspects of the UK Global Tariff.
• Amending customs special procedures and outward processing arrangements.
• Updating import duty reliefs, tariff quotas and tariff suspensions.
• Requiring importers to apply the correct commodity code, origin, duty rate, preference, quota or relief from the relevant commencement date.

Importers, customs agents and supply-chain teams should review classifications, authorisations, origin evidence and customs procedures where affected.

Digital Markets, Competition and Consumers Act 2024 (Commencement No. 3 and Transitional Provisions) (Amendment) Regulations 2026

Commenced: 17 September 2026

The Regulations:

• Extend the transitional period for qualifying alternative dispute resolution providers.
• Replace the previous end date of 5 October 2026 with 7 January 2027.
• Apply the revised date to existing ADR providers and qualifying special ADR arrangements.
• Provide additional time for proposed arrangements appointing the Civil Aviation Authority as a competent authority.
• Allow aviation-sector ADR providers additional time to prepare accreditation applications.

Businesses using ADR providers should confirm that their provider remains accredited or covered by the revised transitional arrangements.

Finance Act 2009 (Publishing Details of Deliberate Tax Defaulters: Increase to Threshold) Order 2026

Commencement: 2 October 2026

The Order:

• Increases the potential lost revenue threshold for publication of deliberate tax defaulters from £25,000 to £50,000.
• Retains the remaining statutory conditions governing publication.
• Does not change the underlying tax, interest or penalty liabilities.
• Does not require automatic publication whenever the revised threshold is exceeded.

Finance and compliance teams should update relevant tax-risk procedures and internal guidance while maintaining effective controls against deliberate tax non-compliance.

Carbon Border Adjustment Mechanism (Emissions and Verification) Regulations 2026

Made: 8 September 2026
Commencement: 1 January 2027

The Regulations establish detailed requirements supporting the UK Carbon Border Adjustment Mechanism, including:

• Calculation of emissions embodied in imported CBAM goods.
• Use of published default values or verified actual emissions data.
• Treatment of precursor goods and relevant production processes.
• Monitoring periods and emissions-measurement requirements.
• Independence, competence and accreditation requirements for verifiers.
• Verification reports and supporting evidence.
• Emissions and verification record-retention duties.

From 1 January 2027, UK CBAM applies to specified imports in the aluminium, cement, fertiliser, hydrogen, iron and steel sectors. Importers should identify affected goods and establish reliable customs, supplier, emissions and verification information.

Finance Act 2009, Sections 101 and 102 (Carbon Border Adjustment Mechanism) (Interest) (Appointed Day) Order 2026

Commencement: 1 January 2027

The Order:

• Applies the Finance Act 2009 late-payment and repayment interest regime to UK CBAM.
• Extends the interest provisions to penalties assessed in relation to CBAM.
• Aligns commencement with the date on which UK CBAM becomes operational.
• Does not establish a separate CBAM-specific interest rate.
• Does not alter embodied-emissions calculations, CBAM rates or return deadlines.

Affected organisations should include potential interest exposure within CBAM payment, cash-flow and compliance controls.

Regulation (EU) 2026/1975 authorising an exemption pursuant to Regulation (EU) 2024/573 with regard to fluorinated greenhouse gases in certain equipment used for drying compressed air

Entry into force: 29 September 2026
Application: 1 January 2027 to 31 December 2030

The Regulation:

• Introduces a temporary exemption for specified equipment used to dry compressed air.
• Allows qualifying stationary chillers and self-contained air-conditioning equipment to use fluorinated greenhouse gases with a global warming potential of 150 or more.
• Applies only to the equipment types, capacity ranges and industrial purpose specified.
• Requires labels identifying the restricted purpose and the exemption end date.
• Retains wider F-gas requirements concerning containment, servicing, recovery, certification, records and reporting.

The Regulation is relevant to organisations placing affected equipment on the EU or EEA market. Northern Ireland applicability should be assessed under the Windsor Framework.

Wildlife Management and Muirburn (Scotland) Act 2024 (Consequential Amendments) Regulations 2026

Commencement: 10 October 2026

The Regulations support Scotland’s new muirburn licensing framework by:

• Updating nine Environmentally Sensitive Area designation orders.
• Replacing references to historic heather-burning guidance with the statutory Muirburn Code.
• Aligning habitat protection and nature conservation provisions with the new licensing regime.
• Updating the significant environmental harm framework.
• Revising references to authorised muirburn operations.

Landowners, estates, farms, contractors and land managers undertaking muirburn should update procedures, instructions and records to reflect the licensing framework and current Muirburn Code.

Air Pollution Act 1987 (Solid Fuels) (Amendment) Regulations 2026

Jurisdiction: Republic of Ireland
Commenced: 18 August 2026, included in the September legal update.

The Regulations introduce temporary alternative compliance arrangements where accredited smoke-emission testing facilities are unavailable:

• Previously approved products may be deemed approved for the period from 1 September 2026 to 31 August 2027.
• Specified new coal, manufactured solid fuel and part-biomass products may qualify where volatile matter does not exceed 14% by weight on a dry ash-free basis.
• Producer registration, sulphur, moisture, labelling, certification and record-keeping requirements continue to apply.
• The alternative arrangements end on 31 August 2027 unless further legislation is introduced.

Producers and importers relying on the temporary route should retain evidence demonstrating eligibility and the unavailability of accredited testing.

Regulation (EU) 2026/1216 setting out durability multipliers for gaseous pollutants from heavy-duty vehicles in categories M3, N2 and N3

Entry into force: 2 September 2026

The Regulation completes part of the Euro 7 durability framework by:

• Setting a durability multiplier of 1.2 for relevant gaseous pollutant emissions.
• Applying the multiplier during the additional vehicle lifetime extending 25% beyond the main lifetime.
• Covering specified M3, N2 and N3 heavy-duty vehicle groups.
• Updating Table 2 of Annex IV to Regulation (EU) 2024/1257.
• Supporting consistent type-approval assessments for emissions-control durability.

UK manufacturers placing affected vehicles, engines or systems on the EU or EEA market must consider the amended requirements. Northern Ireland applicability should be assessed under the Windsor Framework.

Iran (Sanctions) (Amendment) Regulations 2026

Commencement: 29 September 2026

The Regulations significantly expand the UK sanctions regime relating to Iran by:

• Extending designation powers and financial restrictions.
• Introducing further controls on loans, credit, investments, banking and capital markets.
• Expanding restrictions on energy-related goods and technology.
• Controlling specified gold, precious metals, diamonds, maritime goods, natural gas, oil, petroleum products and petrochemicals.
• Restricting specified sectoral software and technology, including certain intangible transfers.
• Introducing additional aviation and shipping restrictions.
• Strengthening licensing, enforcement, disclosure and maritime powers.

UK organisations should reassess customers, beneficial ownership, transactions, goods, technology, vessels, aircraft, intermediaries and service arrangements against the amended regime.

Protection of Freedoms Act 2012 (Relevant Official Records) (Amendment) Order 2026

Commencement: 29 September 2026

The Order:

• Removes wording that linked relevant official records specifically to applications under section 92 of the Protection of Freedoms Act 2012.
• Allows the definition to operate across the wider statutory disregard and pardon framework.
• Supports changes introduced through the Crime and Policing Act 2026.
• Does not create new categories of records or change the underlying eligibility tests.

The amendment primarily affects courts, police forces, government departments and other public bodies managing qualifying official records. For most private organisations, it is an awareness item rather than a directly applicable legal-register obligation.

Terrorism (Protection of Premises) (Principal Use of Premises) Regulations 2026

Commencement: 15 October 2026

The Regulations support the Terrorism (Protection of Premises) Act 2025, commonly known as Martyn’s Law, by establishing how the principal use of mixed-use qualifying premises should be determined.

They require consideration of:

• The use most closely connected with the purpose and nature of the premises.
• Whether the premises were built or modified for a particular use.
• The physical characteristics of the premises.
• How the relevant local authority treats the premises.
• The proportion of the premises and time associated with each use.
• Whether one activity supports another Schedule 1 use.

The assessment determines the person controlling the premises in connection with the principal use and therefore identifies the responsible person under the Act. Organisations responsible for mixed-use premises should document their assessment and monitor commencement of the substantive duties.

Significant Amendments

The following matters represent substantive changes or emerging compliance issues arising from the September 2026 update:

• Extended time limits for specified employment tribunal claims, supported by transitional provisions and potentially longer employment-record retention periods.
• Amendments to customs tariffs, trade preferences, special procedures, quotas, suspensions and import duty reliefs.
• Extension of the transitional accreditation period for qualifying consumer ADR providers to 7 January 2027.
• Increase in the deliberate tax defaulter publication threshold from £25,000 to £50,000.
• Establishment of detailed UK CBAM emissions calculation, verification, record-keeping and interest arrangements ahead of commencement on 1 January 2027.
• A temporary EU F-gas exemption for specified compressed-air drying equipment, subject to defined scope and labelling conditions.
• Alignment of Scottish environmental legislation with the statutory muirburn licensing regime and Muirburn Code.
• Temporary alternative solid-fuel approval arrangements in the Republic of Ireland where accredited smoke-emission testing is unavailable.
• Completion of part of the Euro 7 durability framework for gaseous emissions from specified heavy-duty vehicles.
• Significant expansion of UK sanctions concerning Iran, including financial, trade, technology, aviation and shipping restrictions.
• Technical changes supporting the expanded statutory disregard and pardon framework for historical offences.
• Continued progression of major UK cyber resilience reforms through the Cyber Security and Resilience Bill.
• Introduction of an early-stage Private Member’s Bill proposing restrictions on artificial superintelligence.
• New rules for determining the responsible person at mixed-use premises under Martyn’s Law.