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Author: Anna Weeden

Behind the lens of November 2025: UK Film and TV insights

Posted on by Anna Weeden

Synonymous with the recent change in seasons, the UK production industry is currently in a state of transition. Collaboration is on the up with a rise in co-productions, streamers and broadcasters joining forces, and traditional content businesses working alongside content creators and digital-first start-ups.

The third edition of our UK film and TV newsletter covers key industry updates including the Warner Bros. Discovery takeover, Pact/Equity negotiations, AI advancements, UK indie tax credit impacts, Trump’s proposed film tariff, microdramas, the creator economy, children’s TV inquiries, major legal cases, and new data and immigration updates affecting the sector.

HARBOTTLE HIGHLIGHTS

Edinburgh TV Festival 2025

In August, Minty Hamer and Julika Schmidt attended the Edinburgh TV Festival, which brought together leading voices across the television industry through a wide range of events and sessions.

It was a great opportunity to reconnect with clients and meet new faces from across the sector. Some sessions acknowledged the challenges faced by the industry in dealing with the traditional commissioning ecosystem – some even describing it as “medieval” – and proposed ideas for change in the marketplace.

Additionally, the international potential for new shows remained a key focus, however it became clear that the ideas grounded in authentic, local perspectives continue to resonate the most.  

MIPCOM 2025

Broadcast quoted MIPCOM’s director, Lucy Smith, describing this year’s MIPCOM as “the biggest step change in a generation” owing to the creator economy being at the forefront of the event, with YouTube taking up more conference space than ever before.

The chatter in the air reflected the current themes in the market – budgetary constraints, collaboration being necessary between everyone in the industry to get things made, and the industry pivoting into new areas such as microdramas.

Ed and Clare met up with clients and contacts including distributors, production companies, financiers and union representatives. Deals may be slower and harder to come by, but there was certainly still an appetite for business, on-the-ground meetings and networking in Cannes.

CONTENT LONDON

We are looking forward to attending Content London again in December. We will be hosting our ‘Harbottle Happy Hour’ drinks on the evening of 2 December in Kings Cross so please get in touch if you would like to join us.

BAFTA Elevate 2025/6

On 22 September, we hosted another session for the current BAFTA Elevate cohort. Clare McGarry and Amy Bradbury alongside James Jones (director of Antidote) and Dominic Harrison (Channel 4) explored defamation and other legal issues that filmmakers working in documentary need to be aware of to assess and mitigate risk, whilst maintaining their journalistic integrity.

The session sparked insightful discussions and a Q&A that left everyone with plenty to reflect on and take forward in their work.

INDUSTRY UPDATES

WARNER BROS. DISCOVERY’S POTENTIAL TAKEOVER

Warner Bros. Discovery (WBD) has become the centre of a growing acquisition battle, with several major players expressing interest in its assets. Paramount Skydance, led by David Ellison, has made multiple offers – most recently at $24 per share and including a proposed co-CEO role for WBD’s David Zaslav – all of which have been declined. In response, WBD has confirmed it is actively exploring strategic options, including a full or partial sale, as well as a potential separation of its streaming and cable businesses.

Netflix, despite publicly downplaying interest, has reportedly been given access to WBD’s financial data room, suggesting a possible bid focused on WBD’s valuable IP. Paramount and Comcast (who are also busy looking at ITV’s broadcasting business!) are also said to be evaluating opportunities, each with different strategic goals. Paramount’s potential merger with WBD could create a formidable streaming entity, combining HBO Max and Paramount+ with a combined subscriber base of over 200 million.

UPDATE ON PACT EQUITY NEGOTIATIONS

Negotiations between Pact and Equity on the Cinema Films Agreement (CFA) and TV Agreement (TVA) are still ongoing. In July, Equity responded to Pact’s previous counterproposals, with some key points resolved. This includes a minimum three-year term for both agreements, with negotiations starting again after two years. Pact and Equity were also aligned that artists should be given the first opportunity to dub in English, with certain caveats for production needs still being finalised.

Discussions are also ongoing on issues such as rest periods, overtime provisions and health and safety protections. For the TVA, Equity wants 12-hour minimum rest periods for actors, which Pact says it can’t agree to due to concerns from its members. Pact and Equity met in early November to discuss working patterns under the TVA.

Streaming rights and residuals continue to be a focus, whilst AI provisions are being handled separately, with Equity pushing for strong protections around performer consent, data use, and transparency. At the end of October, key terms on Generative AI were tabled by Pact with Equity – we will give you more detail on this in our next round-up. October / early November also saw Pact and Equity meet to discuss terms for residuals.

Regular meetings are scheduled through the end of the year, and Equity members will vote on the final deal and all financial terms once they are agreed.

BROADCASTERS AND STREAMERS TEAM UP

Disney and ITV signed a deal in July billed as a ‘first of its kind’ initiative to share a curated selection of content across their respective streaming services. Disney+ now carries a promotional selection of titles from ITV under the banner ‘Taste of ITVX’ that includes shows such as ‘Mr Bates vs The Post Office’ and ‘Love Island’ whilst ITV now hosts shows such as ‘The Kardashians’ and ‘Lilo and Stitch’. Around 70-100 hours of content from each streamer’s library have been shared since 16 July. Their goal is to drive subscriptions from demographics outside of each platforms’ typical audience. The partnership, along with other similar deals like Channel 4 and UKTV in the UK and Netflix and TF1 in France, suggest this type of content-sharing arrangement may become a broader trend as the streamers continually evolve their businesses and their place in the market.

Valid questions are being raised about whether Netflix and other similar streamers teaming up with traditional channels will scupper the opportunity for shows to benefit from a secondary rights window, and whether this will in turn put traditional financiers off funding shows if this new model interrupts their ability to recoup against secondary distribution income.

AI UPDATE

We keenly track updates in the AI legal landscape so that we can keep you up to date with the latest. So, what’s new?

In July, the Government announced an AI and copyright working group, with representatives including Open AI, Meta, Amazon and Sony Music Entertainment. The group will focus on the impacts and opportunities of AI, whilst trying to find common ground on key issues. This suggests the Government doesn’t want to be too bullish about bringing in new legislation and is treading this sensitive topic cautiously and slowly.

Meanwhile the Copyright Licensing Agency (CLA) has been developing an AI licensing framework to ensure fair compensation for creators. This could help bridge the gap between rightsholders and big tech developers by ensuring that rightsholders are paid if their works are used to train AI models.

Separately, in September, over 70 signatories, including Sir Paul McCartney and Sir Elton John, accused the Government in an open letter of ignoring copyright violations by AI companies. They claim the use of copyrighted works is undermining the £127bn creative industries and violates creator’s human rights. The Government responded to say that the creative industries’ concerns were being taken “seriously” and a report into the impact of potential changes would be published by the end of March 2026.

Last week, the much-anticipated judgment in the Getty Images v Stability AI case concluded that Stability AI’s model is not an “infringing copy”. However, the ruling left certain questions surrounding the legality of AI training unresolved.    
 
Our AI experts explore the landmark ruling in the summary here.    

STEEP RISE IN UNDER £20M UK FILMS SUBMITTED TO BFI AFTER INDIE TAX CREDIT GREEN LIGHT

The BFI have reported that the number of films with production budgets under £20m applying for BFI certification rose by 27% year-on-year across the first six months of 2025 (417 films vs 328 in 2024). This increase coincides with the introduction of the Independent Film Tax Credit (IFTC) in October 2024 (as part of the new Audio-visual Expenditure Credit regime), which offers enhanced relief for low-budget films. Low-budget films can now benefit from an enhanced credit of 53% (equating to an actual relief of just under 40%, on up to 80% of qualifying expenditure) versus the standard credit rate of 34% (25.5% in actual relief). There have been some voices in the industry calling for an equivalent enhanced tax credit to be applied to TV productions, not just theatrical, but there’s no indication that the Government will be introducing this.

EQUITY VS SPOTLIGHT

The legal dispute between the UK actors’ union, Equity, and prominent talent directory service, Spotlight, concluded in early September with a High Court ruling in favour of Spotlight.

The case focused on Equity’s claim that Spotlight (an organisation providing a service which allows performers to market and advertise their own skills) operates as an “Employment Agency” and therefore should be subject to stricter regulatory requirements, especially in relation to its subscription fees.

The court eventually agreed with Spotlight’s position that it does not actively find work for its subscribers, who either represent themselves or engage agents for that purpose, and so is not an agent. Accordingly, Spotlight is not subject to restrictions on charging work-seekers for their fees.

The ruling highlights the distinctions between platforms that facilitate connections between individuals (i.e. directories), and those that actively provide employment services, setting an important precedent for similar disputes in the future.

WARNER JOINS MIDJOURNEY CASE

In June, Disney and NBC Universal filed a joint lawsuit against generative AI startup, Midjourney, alleging copyright infringement. They claim Midjourney displayed images on its platform that were AI-generated and copied the IP of well-known films such as Star Wars, Shrek, The Simpsons, and Toy Story.

Disney’s Chief Legal Officer, Horacio Gutierrez said: “we are bullish on the promise of AI technology and optimistic about how it can be used responsibly as a tool to further human creativity, but piracy is piracy, and the fact that it’s done by an AI company does not make it any less infringing.”

In September, Warner Bros Discovery also entered the fray, separately suing Midjourney for using iconic characters from the studios’ works to generate images of Batman, Superman and Scooby-Doo, among other characters. They allege that Midjourney have recently “eliminated guardrails that blocked users from creating videos that infringe on its IP”.

As of 5 November 2025, according to a joint stipulation filed by the parties, Warner Bros. Entertainment, Disney and NBC Universal have agreed to consolidate their separate but related lawsuits against Midjourney. The case remains ongoing; no hearings have taken place yet, and no settlements have been reached. However, a Scheduling Conference has been ordered. The studios are seeking a jury trial and a preliminary injunction, while Midjourney has denied any infringement is asserting a fair use defence.

NEW INQUIRY INTO CHILDREN’S TV AND CONTENT

The Culture, Media and Sport Committee launched an inquiry in July asking how future generations of children can continue to have access to high-quality British-made programming. This was in response to children watching less television in favour of online apps and websites, with knock-on effects for those in the creative industries who wish to create original high-quality content aimed at the children’s market. It also focused on concerns for the well-being of the young children consuming this newer content which is not subject to the same level of regulation.

The inquiry closed for submissions at the start of September. While no official publication date for the final report has been announced, the Committee has confirmed that further updates will be provided in due course.

TRUMP REPEATS THREAT TO IMPOSE 100% TARIFF ON FILMS MADE OUTSIDE OF THE UNITED STATES

Donald Trump took to his social media network, Truth Social, to reiterate his view that the American film industry had been stolen by the rise in foreign-made films; “like stealing candy from a baby”. This is the second time that the president has threatened to impose a 100% tariff on films made outside of the United States, having claimed in May that the American film industry was dying “a very fast death”.

As with the initial proclamation, there is a lack of detail how the tariffs might be imposed or when they might come into force, with the industry quietly hoping that this issue disappears into the background of the US government’s broad agenda.

If the tariff ever becomes more than headline-grabbing rhetoric, key questions to answer will include what constitutes an ‘American’ film, particularly in the context of global streamers, and the fact that several major films produced by US studios were shot outside of the US (Wicked and Gladiator II being recent examples). The UK Government is waiting for details of any potential tariff before it decides how to respond. We will keep you updated of any concrete plans to impose these tariffs, but please get in touch if you would like to discuss this further.

IN THE SPOTLIGHT

THE CREATOR ECONOMY IN FILM AND TV

Written by managing associate Clare McGarry.

The television and media landscape is undergoing a profound shift. Where traditional broadcasters and studios once exclusively dominated, now content creators, originating from platforms like YouTube, TikTok and Instagram, are emerging as some of the most powerful forces in entertainment. Their profound influence is being recognised across the UK, highlighted by the recent launch of an all-party parliamentary group (APPG) to represent UK creators and influencers. These online platforms enable creators to cultivate direct relationships with audiences and bypass traditional gatekeepers, retaining complete control over their content.

You can read our full article here.

THE RISE OF THE MICRODRAMA

Microdramas — or “verticals” — are one of many new forms of content reshaping the entertainment landscape. These bite-sized film episodes, designed for mobile viewing, gained popularity in China during the pandemic and have since expanded globally. In 2024, US revenues reportedly reached $819 million, though this pales in comparison to China’s reported $7 billion market during the same period.

The sector has already attracted significant investment and strategic partnerships. Fox Entertainment recently announced an equity investment in Holywater, a Ukrainian tech start-up specialising in vertical video. The deal commits Fox to creating over 200 vertical video titles for Holywater’s My Drama app over the next two years.

Elsewhere, Night Train Media and Spirit Studios have announced a funded development deal to produce a new vertical microdrama series for worldwide digital distribution by Night Train Digital. Meanwhile, in India, Mumbai-based Balaji Telefilms has partnered with Indian microdrama platform Story TV, aiming to establish microdramas as a mainstream format across the continent. And with Omdia projecting that microdramas will generate $11 billion in global revenues by 2025, this new wave of content evolution is unlikely to slow down soon.

THE DATA ACT 2025

The Data (Use and Access) Act 2025 became law in June 2025, with changes due to come into force over time.

It introduces targeted reforms to the GDPR and other data and privacy law, with the aim to reduce compliance burdens and support smart data access.

Changes include updates to data processing rules and new cookie exemptions, as well as changes to the complaints procedure if an individual believes their data protection rights have been infringed. Previously, the individual could go straight to the Information Commissioner’s Office (ICO), but now they will have to raise their complaint with the data controller, such as their employer, before escalating it to the ICO. There are also new obligations on organisations as to how they should deal with these complaints.

Please get in touch with our data experts if you would like to know more.

IMMIGRATION UPDATE

For production companies bringing overseas personnel to the UK on the Skilled Worker visa scheme, standard sponsored applicants must now earn at least £41,700 per year and work in a role that requires a bachelor’s degree. A number of creative roles will continue to be part of the scheme until the end of 2026, including dancers, set designers and producers, due to being included on the Government’s ‘Temporary List’.

Actors can no longer be sponsored under this route unless they already hold Skilled Worker status. The Creative Worker and Creative Worker concession routes are not affected by these changes and will continue as before.

In summary, this sees a tightening on some of the rules allowing overseas personnel to come into the UK to work on film and TV projects.

Please get in touch with our immigration experts if you would like to know more.

Early conciliation: a process in crisis

Posted on by Anna Weeden

Partner and head of the firm’s employment group, Yvonne Gallagher, has written an article published in The Times on the challenges facing early conciliation – a mandatory pre-tribunal step aimed at resolving employment disputes within six weeks.

In the article, Yvonne explores how rising demand and systemic delays are impacting the effectiveness of this process, to the detriment of employers and employees alike, and highlights potential solutions to alleviate pressure on both Acas and the wider tribunal system.

Read the full article here.

The Creator Economy in film and TV

Posted on by Anna Weeden

The shift in the TV and media landscape

The television and media landscape is undergoing a profound shift. Where traditional broadcasters and studios once exclusively dominated, now content creators, originating from platforms like YouTube, TikTok and Instagram, are emerging as some of the most powerful forces in entertainment. Their profound influence is being recognised across the UK, highlighted by the recent launch of an all-party parliamentary group (APPG) to represent UK creators and influencers. These online platforms enable creators to cultivate direct relationships with audiences and bypass traditional gatekeepers, retaining complete control over their content.

What has caused this shift and how have audiences responded?

The Covid-19 pandemic in 2020 accelerated the global digital transformation, leading to a surge in online content creation. With audiences spending more time online and in isolation, many individuals who faced job losses during the pandemic turned to content creation as a source of income. Simultaneously, established creators were forced to adapt their practices by developing a more innovative, dynamic and home-grown approach to producing content, now that access to traditional studios, large production teams, and elaborate sets was closed off to them.

However, it has now become clear that this was not merely a trend during the pandemic. Rather, this new medium has endured and significantly grown since 2020, as evidenced by a recent impact report by Oxford Economics which revealed that YouTube content creators contributed £2.2bn to the UK economy in 2024 and supported 45,000 jobs. The speed and ease of producing social media content, in contrast to traditional linear television series for example, enables influencers and content creators to publish daily content. This, in turn, helps them maintain their cultural and social relevance, audience engagement, and visibility on the constantly changing and elusive algorithm.  

The resulting content is concise, impactful, and high-quality; catering to modern preferences (particularly among Gen-Z viewers) for short, easily digestible, and more personal viewing experiences with real-time audience engagement. Digital platforms democratise content by breaking down barriers, enabling direct interaction between creators and audiences rather than the traditional one-way broadcast model, and reaching a global viewership.

Bridging the gap between content creators and traditional media

As content creators continue to build their vast platforms and fanbases, traditional broadcasters are recognising the value of collaborating with these influencers and engaging them directly to produce, host, or star in more conventional TV and media formats. Content creators bring fresh, dynamic new voices and concepts and large (typically young) viewership. Paired with the resources, studios, personnel, equipment and budgets of streamers or other platforms, the result is exciting new content that appeals to a new audience – many of whom may not typically engage with traditional media.

Examples include:

  • MrBeast: Beast Games, hosted by YouTuber MrBeast (real name Jimmy Donaldson), is a high-budget reality competition series on Amazon Prime Video. Released in 2024, the show featured over 1,000 contestants competing for a $5 million prize. Produced by Amazon MGM Studios, Insider Entertainment, and Blink49 Studios, the series amassed 50 million viewers within 25 days of its debut and has been renewed for two more seasons.
  • Amelia Dimoldenberg: Known for her YouTube series Chicken Shop Date, Amelia has transitioned into traditional media, hosting Channel 4 documentaries such as Celebrity Rebrand and Meet the Markles. She has also worked with the BBC and hosted major events like the BRIT and NME Awards.
  • Charli and Dixie D’Amelio: The D’Amelio sisters rose to fame on TikTok, with Charli becoming the platform’s first creator to surpass 100 million followers. They starred in Hulu’s The D’Amelio Show (2021–2023) and have since expanded into mainstream projects, including Charli’s roles in Apple TV+’s The Studio and the upcoming thriller Hurry Up Tomorrow.

Commercial considerations for content creators and production companies

As content creators become ever-more prominent in the TV world, their business operations also become more sophisticated and complex. Content creators are:

  • Establishing their own production companies and studios to scale their content, including hiring teams of writers, producers, directors and crew.
  • Developing their own YouTube channels.
  • Branching out into ancillary media avenues like podcasting and vodcasting.
  • Collaborating with traditional broadcasters and streamers, both on traditional platforms and on newer digital platforms.
  • Monetising and protecting their IP.
  • Generating income through securing brand deals, sharing sponsored posts, brand collaboration posts and product reviews, offering exclusive content to paying subscribers and even marketing and selling their own product lines.

Meanwhile, independent production companies are also wanting in on the action. We’re seeing a real uptick in interest from traditional production companies in creator-driven business, from traditional players making investments in new YouTube channels to pairing up with content creators to access brands to fund shows and have been advising production companies on how to structure such deals with content creators.

What legal issues does this present?

As with any industry disruptor, as content creators, indies and broadcasters lean into the opportunities presented by the new TV landscape, so too do the legal complexities grow. Some of the legal issues being grappled with are:

  • IP and rights management: protecting ownership of IP in the content being created and negotiating licensing terms with third parties who want to use it.
  • Production and talent contracts: as content creators increasingly act as producers, they are looking to engage third parties, or vice versa where the content creator is engaged by a streamer or studio. Negotiation of production and talent contracts is key.
  • Co-Production deals and contracts: where a content creator teams up with a larger, established production company in order to create a show.
  • Clearance issues: risks arise when content creators feature copyright protected or controversial material in their content.
  • Corporate structuring: many content creators are establishing their own production companies.
  • Corporate investment: content creators and traditional production companies, broadcasters and streamers are joining up and navigating commercial or equity partnerships and investments.
  • Employment: as content creators expand their businesses and begin hiring employees, they need to ensure they comply with employment laws, minimum wage and working hour regulations, as well as having workplace policies in place.
  • Advertising: content creators have no excuse for not complying with advertising standards, including the UK’s Advertising Standards Authority’s rules which affect transparency in marketing activities and other promotional content.
  • Compliance with regulations: content creators need to understand their obligations under the Online Safety Act 2023, which requires influencers to take greater responsibility for their content to prevent any harm to viewers, and under the Digital Markets, Competition and Consumers Act 2024, which prohibits fake reviews and mandates transparency in endorsements.
  • Reputation management: this relates to protecting content creators’ online presence and public persona, personal and confidential material and privacy, as well as managing reputational risks and managing defamation claims and paparazzi intrusion.

What does the future hold?

The dominance of content creators in the modern entertainment landscape is undoubtedly here to stay. However, this doesn’t spell the end for traditional film and TV. By adapting to these shifts and seeking opportunities to collaborate with creators, traditional production companies and broadcasters can capitalise on the success of content creator-driven media. In fact, aligning themselves with the burgeoning ‘creator economy’ could not only help them stay relevant but also enhance their profitability.

Conversely, content creators aiming to maintain their loyal and dedicated audiences might find value in partnering with established industry players. Such collaborations help creators broaden their reach and also reinforce trust with their audience.

For more information or for advice on any of the above topics, please reach out to managing associate Clare McGarry.

Consultation on reforms to the UK designs framework

Posted on by Anna Weeden

The UK Intellectual Property Office (UKIPO) has launched a consultation on reforms to the UK designs system.

Acknowledging the UK’s design sector as leading force in creativity and innovation, the aim is to create a designs regime that is simple, effective and capable of adapting to the challenges of the digital future. The IPO is inviting responses by 27 November 2025.

For businesses involved in design, the outcome of the consultation could have far reaching consequences.

Key points covered in the consultation

  • Whether registered designs should be subject to searching and substantive examination. The government’s preferred option is a two-stage system under which designs would first receive partial registration, with full registration and enforceable rights only granted following a search.
  • Whether the current unregistered design regime is too complex, including the overlap with copyright. While the government’s stated preference is to retain the existing multiplicity of rights to protect both aesthetic and functional designs, it is also canvassing views on the potential consolidation of these rights into a single system and reconsidering the duration of protection.
  • Whether copyright protection for works of artistic craftsmanship should be abolished, with the government’s preference being to retain this protection, ensuring genuinely artistic and handcrafted works remain safeguarded.
  • How to clarify the registered designs system so that it covers animated designs and graphical interfaces more effectively, perhaps by allowing video files to be included in application.
  • With the rise of AI generated designs in mind, whether the existing protection for computer generated designs remains suitable, and how it interfaces with the requirement for originality.
  • Whether UK disclosure rules for unregistered designs should be adjusted to address the lack of mutual recognition with the EU and reduce complexity for businesses seeking protection in both territories.
  • Whether criminal sanctions for design infringement should be introduced.

The outcome of the consultation could have very significant implications for design-led businesses, especially as some of the proposed options could strip away valuable design protections which offer flexibility as enforcement tools.

Equity vs Spotlight: ruling in landmark case exposes a gap in legal protection

Posted on by Anna Weeden

After this week’s ruling in the landmark case between Equity and Spotlight, partner and head of our employment practice, Yvonne Gallagher, has shared her insights in an article published by The Stage in which she provides an overview of the dispute and comments on its likely impact on the performing arts industry.

One key feature of the case was the High Court ruling that Spotlight is not an employment agency under the legislation and there is therefore no restriction on the fees it charges. This serves to highlight a gap in protection when it comes to businesses operating platforms of this nature.

The full article can be accessed here.*

Founded in 1880, The Stage is a weekly newspaper and online publication with the latest news, reviews, interviews, in-depth features and advice on working within the performing arts industry.

*Please note that a subscription is needed to view this content.

Protecting cancer patients at work: Howard Hymanson’s article published in The Times

Posted on by Anna Weeden

Partner Howard Hymanson has written an article published in The Times on how protecting cancer patients at work would give peace of mind to employees following a diagnosis.

Howard notes that many employers are compassionate in light of a recent diagnosis and provide enhanced benefits (e.g. pay and sick leave) but issues often start to emerge in the long term.

Read the full article here.

Learn more about our expertise in this area here.

Harbottle & Lewis advises on the management buyout of The Chinese Room from Sumo Digital

Posted on by Anna Weeden

We have advised the management team of British indie games studio The Chinese Room on their buyout from Sumo Digital.

The studio is known for first-person narrative-centric games such as Dear Esther, Everybody’s Gone to the Rapture, and recent BAFTA-award-winning Still Wakes the Deep.

Our team was led by corporate partner Ed Lane, supported by senior associate Alex Gays and associate Elizabeth Compton. Partner Mark Phillips advised on commercial games matters, senior associate Mark Primrose on employment matters, partner Shireen Peermohamed on IP matters and associate Lauren Probert on real estate matters.

On working with Harbottle & Lewis, studio director at The Chinese Room, Ed Daly commented: “Ed Lane and the team at Harbottle & Lewis were a great help throughout the process. It was important to find advisors with an understanding of the game development business and I look forward to our continuing to work together in this next exciting phase for the studio.”

Ed Lane added: “We are delighted to have been able to support Ed and the whole team at The Chinese Room on their journey towards independence – we can’t wait to see what they do next! Against the backdrop of a challenging few years for independent games developers, this is a massive ‘good news story’ and we are proud to have played a small part – indies are a key part of what we do.”

New UK immigration rules now in force: key takeaways

Posted on by Anna Weeden

Today marks another significant change to the UK immigration rules. On 1 July 2025, the government released a ‘Statement of Changes’ to the immigration rules that take effect today, 22 July 2025.

This has given little time for individuals and companies to not only understand the changes, but to also ensure that they submit the relevant applications required prior to the changes being implemented. These changes are extremely significant for sponsored employees and companies that maintain a Sponsor Licence or intend to obtain a Sponsor Licence to employ future migrant employees.

Skilled Worker

The ‘Skilled Worker route’ allows employers to sponsor individuals that are from overseas to work in the UK, provided they meet certain requirements. Over the past few years, the government has continued to make changes to this route, particularly to the salary thresholds and the skills threshold. Given these changes, the rules have become needlessly complex and difficult to comprehend, and today’s changes have not helped the situation.

The general salary threshold for those that are applying for leave to enter the UK as a Skilled Worker or for ‘Leave to Remain’ in the UK have increased. A summary of the difference in threshold pre 22 July 2025 to present can be seen below:

Please note that if applying for settlement in the UK, the general threshold for Options A-D have also been increased to the new general threshold post 22 July 2025.

Changes to Skilled threshold

In order to assess if an individual’s role is eligible for sponsorship by an employer, the employer is required to review the role against a list of occupation codes that are provided by the Home Office as a guideline. This list is accessible and known as the Appendix Skilled Occupation List. Currently, this list incorporates RQF level 3-6 roles. However, as of today (22 July 2025), 180 occupation codes will be removed from this list, including those that are RQF level 3-5, and only RQF level 6 roles will remain. There is, however, an Immigration Salary List that provides a list of jobs where a reduced salary threshold applies to Skilled Worker visa applications. This list will remain until 31 December 2026 and will include RQF level 3-5 roles. There will also be a new list that will be known as the ‘Temporary Shortage List’ which will be reviewed regularly by the government and will only be in place until 31 December 2026. Roles listed here will be within RQF level 3-5 but can be removed at any time.

There are transitional arrangements for individuals that are already in the UK with leave as a Skilled Worker or who have applied to this route with a Certificate of Sponsorship (CoS) before 22 July 2025. Those that are in an occupation code that no longer forms part of the new ‘RQF Level 6 Occupation List’, but are performing roles that are in RQF level 3-5 roles, can remain employed in the UK, with the option to switch or change employers. There are, however, certain roles that are RQF level 3-5 whereby the individual must continue to work for the same sponsor.

6135 Care Workers and home carers and 6136 Senior Care Workers

Sponsored employers can no longer sponsor such individuals from overseas. Transitional provisions apply to those already in the UK under these occupation codes.

Dependants

As of today, those that are being sponsored within an RQF level 3-5 role will not be able to bring their dependant partner or child to the UK. However, if you are already in the UK with permission as a Skilled Worker within the RWF level 3-5, you can continue to extend your dependants leave or apply for ‘Indefinite Leave to Remain’. Note that there are some exceptions that apply to children.

Other working routes

The Global Business Mobility Routes (GBM) and ‘Scale Up route’ will also see changes to the minimum salary threshold:

  • for a senior or specialist worker from £48,500 per year to £52,500
  • for a graduate trainee from £25,410 per year to £27,300
  • for a UK expansion worker from £48,500 to £52,500
  • ‘Scale Up route’ from £36,300 to £39,100

How do these changes affect the creative industries?

The theatre industry will be significantly impacted by these changes, particularly theatre companies who sponsor actors, writers, musicians and dancers.

Starting today, employers intending to sponsor a dancer as a Skilled Worker can only do so temporarily until 31 December 2026. This applies to skilled classical ballet dancers or skilled contemporary dancers who meet the standards required by internationally recognised UK ballet or contemporary dance companies.

Therefore, post 31 December 2026, such individuals will be required to be sponsored under the ‘Creative Worker route’. This creates restrictions on theatre companies that may require the individual to be in the UK on a long-term basis due to the Creative Worker Visa only allowing someone to be sponsored for two years at a time, meaning the visa will continually need to be renewed.

Interestingly, actors, entertainers and presenters have been removed from the occupation list completely, and those already in the UK as a skilled worker under this code will only be eligible to extend their leave in the UK. Individuals from overseas will no longer be eligible to apply under the ‘Skilled Worker route’.

Further proposed changes

If the above is not enough to get your teeth stuck into, we should say that this is not the end of the proposed changes to UK immigration rules. The government are set to provide an update regarding the following:

  • Earned settlement and citizenship: The government is proposing to extend eligibility to settlement from five years to 10 years for more work routes. Exemptions may apply to those that are able to demonstrate contributions to the UK economy.
  • Study routes and graduate routes: Reforms are set to tighten the student and graduate routes aiming to prevent these pathways from being used as a means to settle in the UK. While changes to the graduate route are still under review, the proposed reforms include reducing the duration of stay under the graduate route from two years to 18 months, with the possibility of additional restrictions being implemented.

If you have any questions in relation to any of the above, please get in touch with our immigration lawyers.

Employment Rights Bill: The latest for July 2025

Posted on by Anna Weeden

After a quiet few months on the journey of the Employment Rights Bill, the last couple of weeks have seen a flurry of employment law updates. There has been a lot to unpack, so we’ve summarised the latest timeframes and changes in an update of the ‘need-to-knows’ for right now.

What’s the current status?

The Bill has been making its way through the parliamentary journey to becoming law over recent months. The Bill is now in the ‘report stage’ in the House of Lords, after which it will return for a third reading and further consideration of the proposed amendments. The latest amended version of the 318-page Bill was published on 24 June 2025.

What’s the timeframe?

On 1 July 2025 the government published its UK employment law roadmap for the delivery of changes, so we now have more certainty on implementation dates. The key takeaway is, with the phased implementation, that most changes are going to take longer than expected to become law.

Although a handful of changes will take effect shortly after the Bill receives Royal Assent, most will be implemented during a lengthy phased delivery plan. Some of the most significant are:

  • April 2026: ‘day one’ rights to paternity leave and parental leave; ‘day one’ right to statutory sick pay and removal of earnings threshold for this; enhancement of whistleblower protection; trade union recognition and balloting changes.
  • October 2026: enhanced duty to take ‘all’ reasonable steps to prevent harassment; changes to the law on fire and rehire; further expansion of trade union rights.
  • 2027: introduction of ‘day one’ protection from unfair dismissal; changes to the law on zero-hour contracts; enhanced rights for pregnant workers; statutory bereavement leave; umbrella company regulation.

What can be seen immediately is that it will take longer than expected for some of the biggest changes to become law, with key measures such as ‘day one’ unfair dismissal rights being pushed into 2027. This means more planning and preparation time for businesses to determine how best to navigate the changes in their organisation. Consultations about the proposed changes will commence shortly and we expect those to continue into 2026.

What’s new or changed recently?

On 7 July 2025, a number of proposed changes were detailed for the Bill, with some attracting considerable press attention over the last few days. We’ve outlined the most significant updates from the latest draft below, as a summary of the recent amendments. (Not all measures are mentioned in this briefing; we have focussed on what has changed in the latest version of the Bill).

For all of the categories below, it is important to emphasise that these are proposals only. They may not make it into the final Bill and are subject to change.

For those who want some further topical reading, press coverage and commentary can be viewed here.

Update: Bereavement leave for families who face pregnancy loss

A statutory right to bereavement leave has been part of the proposals from the early stages, but the latest amendments confirm that bereavement leave will be extended to a stillbirth or loss of a child in the first 24 weeks of pregnancy. This has been referred to as ‘miscarriage leave’ in some press coverage and has been welcomed by many charities and campaigners.

This means that employers may see the right to bereavement leave taken up more than initially expected, given the estimated statistic that more than one in five pregnancies sadly end in miscarriage. Companies will need to update policy and practice accordingly when the time comes.

Update: A ban on NDAs (including in settlement agreements) which cover harassment and discrimination

This is a significant amend for employers to note; non-disclosure agreements and similar deals (including settlement agreement terms) will be void if they prohibit an individual disclosing details of discrimination or harassment. Confidentiality clauses may still be permissible, at the request of the employee only, although the detail of this is yet to come. What’s clear is that this change aims to make ‘cover up culture’ a thing of the past.

Of course, some clients are ahead of the curve on this, and already have a ‘no-gagging’ policy for any settlement or exit terms where there has been a complaint or claim of discrimination or harassment. For others, this will be a real step change. All employers will need to start thinking about their commitment to culture, good training and transparency in preparation for this change.

Update: Changes to whistleblowing laws

The amendments include significant changes to the protected disclosure or ‘whistleblowing’ laws, if they are passed and included in the final bill. In brief, these include changes to what qualifies as a ‘protected disclosure’, a tightening of the public interest requirement, a new offence of intentionally or recklessly subjecting a whistleblower to a detriment and a proactive duty on larger employers to take reasonable steps to investigate any protected disclosure.

This is one to watch and the finer detail of the proposed enhanced whistleblower protection, currently scheduled to become law in April 2026, still seems ‘up in the air’ at this time.

Update: The fire and rehire ‘ban’

The ban on ‘fire and rehire’ (the practice of dismissing an employee for refusing to agree to a variation of their contract and rehiring on the employer’s preferred terms) has attracted criticism that it would make it difficult for employers to make routine organisational changes where needed.

The latest proposals seek to temper the ban, in particular with a proposal that it will only prohibit ‘restricted variations’ to include pay, pension, hours and holiday. There are also proposed changes as to how the proof of financial distress (where fire and rehire is permitted) will be assessed and the consequences of unlawful dismissals in this situation, with this no longer being automatically unfair, but assessed by a reasonableness test.

The amendments importantly allow for variation clauses in employment contracts. Employers could consider checking their contract terms; if their standard templates don’t include a right to vary terms and conditions, it would be advisable to think about updating those now.

Update: New proposed rules on zero hour worker contracts

Changes to what the Government term ‘exploitative’ zero hour contracts have been a headline change in the Bill. These are casual employment contracts which do not guarantee any minimum working hours. The  latest amendments water down an originally proposed ban on these contracts, so that employees can request guaranteed hours, but there is no duty on the employer to offer them. Again these are proposed amends only which may not be backed by the Government, so we could yet see a return to the more far reaching reforms for zero hour contracts as originally outlined in Bill.

The review of the parental leave system

Separately from the changes in the Bill, on 1 July the Government also launched a full review of parental leave and pay. The review will look at the whole family friendly leave system, including maternity and paternity leave, shared parental leave; adoption leave and others, and will also review the statutory pay system. We will keep clients updated as the review progresses.

We will continue to track the developments of the Employment Rights Bill and will issue further updates as the Bill gets to the final consideration stage and we have more detail on final proposals and implementation.

Behind the lens of July 2025: UK Film and TV insights

Posted on by Anna Weeden

The UK production industry is showing cautious optimism, with increased investment into the country, despite challenges like tight budgets and Channel 4’s shift to in-house production. AI dominates discussions, with legal disputes and policy changes signalling its transformative impact.

The second edition of our UK film and TV newsletter covers key industry updates including production trends, AI developments, and further updates to the Employment Rights Bill.

HARBOTTLE HIGHLIGHTS

South by Southwest London (SXSW)

We attended SXSW London, their debut festival in London, and were proud to partner with them as their official legal services supplier. Our lawyers were there throughout the week, attending and chairing insightful panels and talks.

Cannes Film Festival

In May, Sarah Lazarides, Peter Armstrong, Abigail Payne, Clare McGarry and Emma Riggs attended Cannes Film Festival. We caught up with clients and other contacts from around the world, attending numerous events around the Croisette, including those generously hosted by Coutts, Sargent Disc, Fintage House and Saffery. Some reports mention the bars and restaurants being less packed than usual, and of there being a feeling of frugality reflective of the industry as a whole, but we found there to be a good buzz in the air and the festival felt “in action” after a few quiet years in the post-Covid wake.

National Film and Television School

On 3 June, Clare McGarry, Octavia Henderson-Cleland and Julika Schmidt ran a negotiation workshop for talented students from the National Film and Television School. It was a lively and engaging session, on key topics which producers at all stages of their careers need to know about.

On 24 June, Ed Lane hosted a further session for students with serial TV entrepreneur Paul Sandler covering investment readiness and how an investment process works. We ended with a mock negotiation of a term sheet which included some excellent role playing from all concerned.

Indielab TV Accelerator 2025

We have been proud sponsors of the Indielab TV Accelerator for almost a decade, and the 2025 edition came to a close on 11 June.

The day began with Ed Lane, together with Tom Manwaring and Alex Reed-Brewer from Helion Partners, offering insights into the current investment landscape and how to attract investors. Ed was later joined by Harbottle & Lewis associates Katerina Capras and Minty Hamer, who covered investment readiness and the investment process.

In the afternoon, Abigail Payne and Octavia Henderson-Cleland shared their expertise on co-production and distribution agreements.

We then all attended the closing drinks at Barclays to celebrate this year’s cohort.

BAFTA Elevate 2025/6

As part of our support for BAFTA’s Elevate programme, Ed Lane chaired a panel of indies and investors at BAFTA on 17 June.

On the panel were Nischal Randev (BBC Studios), Caroline Percy (Channel 4 Indie Growth Fund), Derren Lawford (DARE Pictures) and Ed Kellie (ScreenDog Productions).

It was a lively and insightful discussion on starting an indie and the investment journey, with some excellent questions from the floor.

INDUSTRY UPDATES

HOT OFF THE PRESS! GOVERNMENT RESPONDS TO CMC REPORT ON THE HETV AND FILM INDUSTRY

In our last edition, we reported on the CMC’s report into the state of the industry, which included recommendations of a 5% levy for streamers, a new HETV tax credit for independent TV, terms of trade for streamers, and scrapping the government’s plans to include a “data mining exemption” for copyright infringement. The government has now responded. The response dovetails with the government’s new Creative Industries Sector Plan (see article below). In short, most of the headline grabbers from the CMC report have not been agreed. Some key takeaways:

  • The government supports the sentiment of the CMC report and appreciates the challenges faced by the industry, acknowledging the “need to ensure the resilience of our domestic sector”.
  • The government has not committed to introducing terms of trade or the 5% levy on streamers, saying: “we want a healthy, mixed film and TV ecology and we welcome inward investment, including from SVoD services. One of the benefits of a mixed ecology is that producers can strike deals both with streamers, which typically involve higher upfront fees, and with PSBs, whose terms of trade mean that secondary rights normally remain with the producer”.
  • The DCMS will appoint a “creative freelance champion” to advocate for the sector’s freelancers within government.
  • Short courses in England will be introduced, funded through the Growth and Skills Levy, in areas like digital, artificial intelligence and engineering.
  • VAT relief on cultural activities, which would include cinema entry, has not been agreed.
  • The government has committed to providing its response to its consultation on copyright and AI in the coming months. They reminded readers that the Data (Use and Access) Act 2025 contains a number of updates and a report on the use of copyright material for AI training will be coming within nine months of Royal Assent.
  • No commitment has been made to analyse the benefit of an uplifted HETV Audio-Visual Expenditure Credit for domestic productions with budgets of £1 million to £3 million per hour.

£75m funding for film and TV sectors: creative industries sector plan

In June, the government revealed its £75m “Screen Growth Package” for the film and TV industry, part of its Creative Industries Sector Plan.

  • The UK Global Screen Fund will be increased to £18m yearly to develop international business capabilities, enable co-productions and showcase independent UK screen content worldwide.
  • £10m will be put towards the National Film and Television School’s facilities and training programmes, unlocking £11m in investment from industry and private supporters, including from the Walt Disney Company, the Dana and Albert R. Broccoli Foundation and Sky.
  • Funds are being made available to a “significantly expanded” BFI Film Academy, to open the industry to people from underrepresented backgrounds, with opportunities for filmmaking work experience and training.
  • £25m is going to companies in the augmented reality and motion capture technology space, to fund research and development labs, and showcase spaces.

As well as the Screen Growth Package, £150m will be given to Mayoral Strategic Authorities, to support the creation of regional screen agencies and production funds.

The true impact of the investment remains to be seen and will become clearer over time.

AI, AI, AI…

It’s been an especially turbulent quarter in the world of AI. In case you missed it:

1. Trade Unions call for an independent AI regulator. The Trades Union Congress (TUC), which represents Pact and Bectu, wants an independent regulator to be set up to manage how AI is integrated into society. The aim: a new creative industry AI taskforce to bring together creative workers, unions and technologists, transparency on AI training data, consent-based use of creative work, fair pay when creative content is used to train AI models and stronger protections against deepfakes.

The TUC has voiced strong opposition to the government’s plans to include an exemption in the law allowing AI developers to train their systems on copyrighted protected materials without permission, unless creators explicitly opt out.

2. The Data (Use and Access) Bill passes. This was passed on 11 June after much “ping ponging” between the House of Commons and House of Lords. The House of Lords tried to introduce a change forcing AI companies to declare their use of copyright protected materials for the training of AI models, including transparency regarding scraping. This was rejected by the House of Commons, who said this was not the appropriate place to deal with these issues, in particular because (a) they are running a separate consultation on AI and the creative industries (the results of which we are eagerly awaiting) and (b) a specific AI bill is in the works. Sceptics might say this shows the government siding with AI companies over creatives and displaying their fear of getting left behind if the UK stifles any technological advancements of AI.

3. Major players flex their litigation muscles.

Two major cases to be aware of:

Disney and Universal sue Midjourney:

  • The first US majors to sue an AI company.
  • They allege that Midjourney has not ceased its ‘calculated and wilful’ unauthorised infringements, despite requests to stop and adopt technological measures to prevent the practice.
  • Subscribers to Midjourney can create images from text that are reproduced and made available for download. The studios referenced pictures of Yoda and other characters from franchises being generated through the AI tool.
  • An excerpt from the complaint called Midjourney “the quintessential copyright free-rider and a bottomless pit of plagiarism”.
  • The studios are seeking maximum statutory damages and injunctive relief.

Getty goes to court: Getty Images’ landmark case against Stability AI officially began in June. Getty accuses Stability AI of using its copyrighted images to train Stable Diffusion, Stability AI’s system which generates images from inputs. Getty says Stability AI illegally scraped millions of images from its website. However, Getty dropped its primary copyright claim on 26 June as a “pragmatic” move, leaving the trade mark, passing off and secondary copyright infringement claims still on the table.

PACT resists changes to terms of trade

Ofcom is considering revising its guidance for PSBs set out in the Commissioning Codes of Practice, commonly referred to as the “Terms of Trade”. Their plans include allowing PSBs to seek ‘matching rights’ as well as changes regarding negotiation practices with indie producers.

Pact believes that this change would impact the balance of power between producers and PSBs, particularly within the indies sector. The union has urged its members to write to their MP to highlight what they see as a move that would hinder the ability of producers to retain and exploit their IP.

PACT/Equity negotiations

The contract negotiations between Pact and Equity for both the Cinema Films Agreement (CFA) and the TV Agreement (TVA) are ongoing. Pact sent the TVA counterproposal to Equity on 4 April and the CFA counterproposal to Equity on 25 April. Here are some highlights:

  • Pact is pushing back on all changes to working hours and turnaround requirements following industry feedback.
  • Pact and Equity are aligned that all artists should be given the first opportunity to dub in English, however, Pact has proposed some language in its response that is broad enough to allow for production exigencies.
  • In respect of calls from Equity to curtail customary option/exclusivity terms from series regular cast deals (which Equity believes keep actors off the market), Pact has requested that Equity provide the wording they wish to include in the TVA so they can consider this issue further.
  • Pact has told Equity that it would not be realistic to ban “on or about” dates from TV performer deals, but has instead proposed including block-by-block engagements within the TVA and making it clear that artists are not on first call until dates are nominated.

Equity provided initial responses to Pact’s counterclaim on 23 May and Pact was due to meet with Equity w/c 9 June to discuss the CFA counterproposal. A further meeting will be arranged for Pact and Equity to discuss AI, Special Stipulations and exclusivity clauses.

On AI, Pact has sent to Equity questions relating to Equity’s open letter on AI training and GDPR. Pact hopes that the responses to these questions will enable it to understand the basis of Equity’s AI claim and build on this to aid negotiations.

For further details regarding Pact’s counterproposals under the CFA and/or the TVA, please get in touch directly.

PACT/Equity & PACT/Bectu rates increase

Pact/Equity

  • From 6 April, Pact and Equity agreed a 3% interim minimum rate increase under the CFA.
  • These rates will remain in place until the new CFA (currently being re-negotiated – see above) is signed or for a period of six months (i.e. until Sunday 5th October), whichever comes first.
  • With respect to the TVA, Pact and Equity had already agreed to the minimum rates being increased by 3.5% with effect from 1 January and then by a further 3% with effect from 1 January 2026.
  • Rate increases for stunt personnel under the CFA and TVA remain subject to the broader ongoing negotiations between Pact and Equity.

Pact/Bectu

New rates under the Construction Crew Agreement between Pact and Bectu also came into effect from 1 April, which have been adjusted to reflect the rise in the Consumer Price Index from 2.5% to 2.6%. The Construction Crew Agreement only applies to major motion pictures (theatrical and SVOD) with production budgets in excess of £30 million.

Directors and producers: guidelines

Pact, Directors UK, BBC Studios and ITV Studios (the Directors and Producers Forum) have published Engagement Guidelines for Ways of Working Between Producers and Directors, which sets out how production companies should work with directors across all genres of production.

There are nine key principles providing a baseline of good practice for how directors and producers can work together, including “the director having a right to consultation” and “the director having a right to the appropriate credit”. The Directors and Producers Forum say that the guidelines can act as a reference point to ensure the director’s role is clear and respected.

IN THE SPOTLIGHT

Channel 4: Key change or sea change?

Written by partner Ed Lane.

It’s chocks away for Channel 4! The news that Channel 4 plans to create a standalone in-house production business has been met with strong opinions from many quarters of the indie sector. But how significant is this shift really?

The reaction is not surprising given Channel 4’s founding mission to support the independent production sector, which it has done for over 40 years via a focus on commissioning shows from indies and allowing indies to retain all rights (i.e. it has not been interested in developing or acquiring IP).

Alongside that, Channel 4 has (to date) been prohibited from holding more than a minority equity stake in indies. Through its Indie Growth Fund (launched in 2014) it has funded and supported a host of indies, including Warp Films (Adolescence). In supporting these indies, Channel 4 was effectively acting as a venture capital fund, looking to fund at an early stage and then exit (ideally with a decent return). It has indeed exited a number of those investments, most recently Eagle Eye who were acquired by ITV Studios in late 2024.

The minority stake ‘venture capital’-style approach allowed indies to take on early stage investment and then look to sell to a wide range of potential buyers. This gave flexibility, and potentially, with enough competitive tension, a higher valuation for the business. On the flipside, often where a trade investor (like BBC Studios or Banijay) are making early stage investments, there will be a path to majority ownership built in to the deal. This deprives the indie of options later down the line.

With Channel 4’s shifting approach, the industry may have lost something pretty rare – an investor well-versed in the industry but comfortable with the founders retaining strategic control and focused on supporting indies to exit rather than looking to take full ownership or build an in-house production arm.

Only time will tell how this new, unbridled Channel 4 will operate. Will its new inhouse production arm truly be separate to commissioning, with no preferential arrangements (we hear that both teams will be in the same office space – commissions at the water cooler, anyone)? Or will its increased indie quota (up to 35% from 25%) soften the blow enough for a sector still reeling from the commissioning slowdown?

‘Sex’ in the Equality Act: impact on Film & TV

In April, the Supreme Court gave a judgment on the meaning of “sex” in the Equality Act 2010. Widely reported in the mainstream press, and generating considerable debate, we explain the judgment and how it relates to practices in the workplace.

The case of For Women Scotland v The Scottish Ministers concerned the meaning of the terms “man”, “woman” and “sex” in the Equality Act 2010 (EqA) in light of the Gender Recognition Act 2004. It decided that these terms refer to biological sex. This means that if someone identifies as trans, they do not change sex for the purposes of the EqA, even if they have a Gender Recognition Certificate.

The decision is an important development in the entrenched conflict between those on either side of the trans rights and gender critical debate. Unless future legislation changes the position, the judgment puts the meaning of sex in the EqA in unequivocal terms. Sex = biological sex.

So what does this mean for UK film and TV companies, who are employers or engage freelance cast and crew on productions? We’ve identified some key areas where this judgment will have an on the ground impact for clients.

Click here to read the full article by senior associate, Lucy Burrows.

Employment Rights Bill: Update

The long-awaited Employment Rights Bill is now set for phased implementation, with consultations beginning in summer and autumn 2025. As part of the government’s “Plan to Make Work Pay,” the Bill’s landmark reforms will be rolled out gradually over the coming years. Whilst delays in parliamentary approval have slowed its progress, the Bill is now seemingly moving forward.

For the film and TV industry, the most significant changes are as follows:

  • Reforms to expand Statutory Sick Pay to include the lowest-paid workers. Expected date of implementation (EDI): April 2026.
  • Granting workers day-one protection against unfair dismissal (which had been expected to take effect in October 2025). EDI: 2027 (date to be confirmed).
  • Banning ‘exploitative’ zero-hour contracts. EDI: 2027 (date to be confirmed).
  • Introducing enhanced flexible working rights. EDI: 2027 (date to be confirmed).

Employers can be reassured that the changes will not take immediate effect, with many of the reforms now expected to come into force later than originally anticipated. Further details on these policies, along with the exact timeline for implementation, will be provided once the consultations have concluded.

You can read more on our coverage of the Bill and its impact on the film and TV industry on our website.