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    September 2026 Legal Update

    ByAssent Risk Management·
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    Legal Update provided by Assent Risk Management

    This monthly legal briefing highlights recent legal and regulatory changes that may be relevant to Quality, Environmental, Information Security, and Health & Safety requirements. It is produced by Assent Risk Management to help organizations stay aware of developments that could affect their legal and regulatory responsibilities.

    Each briefing provides details of the relevant legislation or regulatory change, including its title, date, country, category, potentially applicable standards and industries/sectors, together with a summary and a link to the relevant official source.

    The standards and sector information is intended as a useful guide when considering relevance. Organizations should assess each update against their own activities, locations and existing legal obligations to establish whether any changes apply to them.

    Where legislation or regulatory requirements are relevant, organizations should review their existing arrangements and consider whether updates are needed to their legal register, policies, procedures, risk assessments, controls, training or other aspects of their compliance framework.

    Webinar: ISO 9001:2026, Understanding the Changes and Preparing for Transition

    Assent Risk Management is hosting a joint webinar with SGS on ISO 9001:2026, covering the changes and preparation for transition.

    • Date: 8 October 2026
    • Time: 1:00pm to 1:45pm BST
    • Cost: Free to attend

    The webinar will provide organizations with a practical overview of the revision, focusing on what has changed, why the standard is being updated, what organizations need to understand, and what the transition means from a certification perspective.

    Register: Register for the Assent and SGS webinar

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

    • Date: 4 September 2026
    • Country: UK
    • Category: Employment
    • Standards: ISO 9001, ISO 45001, ISO 37301
    • Industries and sectors: Organizations of all sizes and sectors employing staff in the UK, particularly HR, people management and organizations with formal employment grievance and disciplinary processes.
    • Status: Active

    These Regulations bring into force, on 1st October 2026, section 152 of, and Schedule 12 to, the Employment Rights Act 2025 (c. 36) (“the 2025 Act”), which extend time limits for instituting claims to employment tribunals from three to six months.

    Regulation 4 and the Schedule make transitional provision in relation to Schedule 12 to the 2025 Act so that the amendments to time limits apply where the date of the matter complained of (‘the relevant date’) occurs on or after 1st October 2026.

    Legislation: https://www.legislation.gov.uk/uksi/2026/954/contents/made

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

    • Date: 8 September 2026
    • Country: UK
    • Category: Finance
    • Standards: ISO 14001, ISO 37301, ISO 14064-1
    • Industries and sectors: Organizations importing or manufacturing goods within the scope of the UK Carbon Border Adjustment Mechanism, particularly businesses operating in carbon-intensive industrial sectors.
    • Status: Active

    Section 101 provides for late payment interest on sums due to His Majesty’s Revenue and Customs under an enactment but paid late. Section 102 provides for repayment interest on sums to be paid by His Majesty’s Revenue and Customs.

    Legislation: https://www.legislation.gov.uk/uksi/2026/994/contents/made

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

    • Date: 8 September 2026
    • Country: UK
    • Category: Finance
    • Standards: ISO 9001, ISO 37301
    • Industries and sectors: Importers, exporters, manufacturers, distributors, logistics providers and other organizations involved in international trade and customs activities.
    • Status: Active

    This instrument makes amendments to subordinate legislation previously made under the Taxation (Cross-border Trade) Act 2018 (“TCTA”), which provided for the United Kingdom’s Customs, Value Added Tax (“VAT”) and Excise regimes to be in place after the end of the Transition Period following the withdrawal of the United Kingdom (“UK”) from the European Union (“EU”).

    Legislation: https://www.legislation.gov.uk/uksi/2026/984/contents/made

    The Iran (Sanctions) (Amendment) Regulations 2026

    • Date: 8 September 2026
    • Country: UK
    • Category: Sanctions
    • Standards: ISO 37301, ISO 27001, ISO 37001
    • Industries and sectors: Financial services, banking, international trade, shipping, aviation, logistics, manufacturing, technology and organizations involved in the supply of goods or services subject to UK sanctions controls.
    • Status: Active

    This instrument amends the 2019 Regulations to introduce prohibitions on the access of financial services by Iran; expand trade measures to cover additional categories of goods, technology, and services; prohibit certain Iranian aircraft used exclusively for the provision of air cargo services from landing in the UK; impose new shipping sanctions; and add specification of ship powers. This instrument amends the 2023 Regulations to expand existing powers relating to the specification of ships.

    Legislation: https://www.legislation.gov.uk/uksi/2026/983/contents/made

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

    • Date: 8 September 2026
    • Country: UK
    • Category: Other
    • Standards: ISO 27001, ISO 37301
    • Industries and sectors: Public sector organizations, legal and criminal justice services, police and government departments, and organizations responsible for managing relevant official records.
    • Status: Active

    The first scheme is a disregard and pardon scheme which applies to individuals convicted of, or cautioned for, an offence of persistently loitering or soliciting in a street or public place for the purposes of prostitution, where the conduct occurred when they were under 18. The second scheme is a pardon and data deletion scheme which applies to women previously convicted of, cautioned for, arrested for or investigated on suspicion of criminal offences related to abortion when acting in relation to their own pregnancies. The amendment will help ensure that the relevant organizations can identify and deal with records consistently when the schemes come into force. The New Schemes were introduced by the Crime and Policing Act 2026 and are not yet in force.

    Legislation: https://www.legislation.gov.uk/uksi/2026/977/contents/made

    The Carbon Border Adjustment Mechanism (Emissions and Verification) Regulations 2026

    • Date: 9 September 2026
    • Country: UK
    • Category: Environment
    • Standards: ISO 14001, ISO 50001, ISO 14064-1
    • Industries and sectors: Manufacturers and importers operating in the aluminum, cement, fertilizer, hydrogen, and iron and steel sectors, particularly organizations importing covered goods into the UK.
    • Status: Active

    Finance Act 2026 (FA 2026) includes provisions that will introduce the Carbon Border Adjustment Mechanism (CBAM) from 1 January 2027. CBAM is a new tax which will ensure that emissions within highly traded, carbon-intensive goods which are imported into the United Kingdom (UK) face a comparable carbon price to that paid by manufacturers producing the same goods in the UK. It will apply to specific goods across the following five industrial sectors: aluminum, cement, fertilizer, hydrogen, and iron and steel.

    Legislation: https://www.legislation.gov.uk/uksi/2026/995/contents/made

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

    • Date: 10 September 2026
    • Country: UK
    • Category: Other
    • Standards: ISO 45001, ISO 22301
    • Industries and sectors: Organizations responsible for premises used for retail, hospitality, leisure, entertainment, events, education, healthcare, transport, religious, sporting and cultural activities.
    • Status: Active

    This instrument introduces regulations under the Terrorism (Protection of Premises) Act 2025 (“the Act”), more commonly known as Martyn’s Law. It clarifies how to determine the “principal use” of premises that are in scope of the requirements of the Act (“qualifying premises”), where those premises have more than one use specified in Schedule 1 to the Act (“Schedule 1 use”). Determining the principal use of qualifying premises will establish the “responsible person” for those premises who must ensure that the requirements of the Act are met.

    Legislation: https://www.legislation.gov.uk/uksi/2026/1005/contents/made

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

    • Date: 11 September 2026
    • Country: UK
    • Category: Finance
    • Standards: ISO 37301
    • Industries and sectors: Organizations across all sectors with UK tax obligations, particularly businesses and professional services organizations with significant tax liabilities.
    • Status: Active

    This instrument increases the potential lost revenue threshold for HMRC to publish a deliberate defaulter’s details to £50,000. This means that when this instrument comes into force, HMRC will only publish details of deliberate defaulters where the potential lost revenue exceeds £50,000.

    Legislation: https://www.legislation.gov.uk/uksi/2026/1000/contents/made

    The Finance Act 2009 (Section 101) (Vaping Products Duty) (Appointed Day) Order 2026

    • Date: 14 September 2026
    • Country: UK
    • Category: Finance
    • Standards: ISO 37301
    • Industries and sectors: Manufacturers, importers, wholesalers, distributors and retailers involved in the sale or supply of vaping products, and businesses with obligations relating to vaping products duty.
    • Status: Active

    This Order appoints 1st October 2026 as the day on which the interest regime set out in section 101 of the Finance Act 2009 (c. 10) on late payment interest comes into force for the purposes of vaping products duty. Section 101 has already been brought into force for other purposes.

    Legislation: https://www.legislation.gov.uk/uksi/2026/1024/contents/made

    The Finance Act 2026 (Scottish and Welsh Property Income Rates) (Appointed Day and Tax Year) Regulations 2026

    • Date: 14 September 2026
    • Country: Scotland & Wales
    • Category: Finance
    • Standards: ISO 37301
    • Industries and sectors: Property owners, landlords, property management and real estate businesses, and organizations or individuals receiving property income in Scotland or Wales.
    • Status: Active

    The Regulations appoint 16th September 2026 as the day on which section 8 of, and Schedule 2 to, the Finance Act 2026 come into force. They also appoint the tax year 2027-28 as the first tax year in relation to which the amendments made by section 8 and Schedule 2 have effect. Those amendments accordingly have effect for the tax year 2027-28 and subsequent tax years.

    Legislation: https://www.legislation.gov.uk/uksi/2026/1023/contents/made

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

    • Date: 22 September 2026
    • Country: UK
    • Category: Business
    • Standards: ISO 9001, ISO 37301
    • Industries and sectors: Consumer-facing organizations, including retailers, e-commerce businesses, technology companies, online marketplaces, and organizations providing digital or consumer services.
    • Status: Active

    These Regulations amend the transitional provisions set out the Digital Markets, Competition and Consumers Act 2024 (Commencement No. 3 and Transitional Provisions) Regulations 2026 (S.I. 2026/284 (C. 21)) to extend the transitional period from 5th October 2026 to 7th January 2027. The Regulations commence on the day after the day on which they are made.

    Legislation: https://www.legislation.gov.uk/uksi/2026/1040/contents/made

    Staying Compliant

    Keeping your legal and regulatory information up to date is an important part of maintaining an effective management system. We recommend reviewing the updates in this month's briefing and assessing whether any changes apply to your organization.

    Where relevant, ensure that changes are reflected in your legal register and compliance documentation, and that any necessary updates to policies, procedures, risk assessments, controls or training are implemented and communicated to those affected.

    Management system standards including ISO 9001, ISO 14001, ISO 45001 and ISO 27001 require organizations to determine applicable legal and other requirements and evaluate compliance with those requirements.

    For support with identifying applicable legislation, maintaining your legal register or assessing compliance, Assent can provide specialist legal and regulatory compliance support.

    About This Update

    This legal update is provided by Assent Risk Management. You can view their full library of legal briefings at assentriskmanagement.co.uk/category/legal-briefing.

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