Redundancy procedure: online HR1 submission mandatory from December 2025 for large scale redundancies

When an employer is proposing to make large scale redundancies (of 20 or more employees at one establishment, within a period of 90 days), it must comply with stringent statutory collective consultation rules. These include a requirement to notify the Secretary of State (via the Redundancy Payments Service) of the proposed redundancies in advance, on an “HR1” form. Failure to do so can result in unlimited fines and criminal liability (for both the company and its directors), and disqualification of directors.

From 1 December 2025, employers wishing to submit an HR1 form will need to do so using the new digital version.

The beta version of the form is currently available to use, and employers wishing to notify the Secretary of State between now and 30 November 2025 can decide whether to submit the downloadable “paper” form or use the new digital form. However, from 1 December 2025, the new digital form will be the only way to notify the Secretary of State of proposed redundancies.

We have set out the key changes to the HR1 form below, as well as some practical points to bear in mind when using the form, the timing of submission, and the risks associated with failing to notify the Secretary of State appropriately.

What has changed in the new HR1 form?

The HR1 form has been updated with the following changes:

• A new redundancy reason option has been added – “Change in supply chain/loss of supply chain contract”.
• Future consultation start dates will not be accepted.
• There is no longer a requirement to provide breakdowns of affected employees by occupational groups.
• Employers may upload up to four attachments at the end of the form; if these are needed.

Practical points for employers to be aware of:

• It is not possible to save information until the form is submitted at the end; if the page is closed or left for longer than 90 minutes, employers will need to start again.
• It will not be possible to save or retrieve a copy of the form once it has been submitted. It will therefore be important for employers to save or print the final summary page before submitting; not only for their records, but also in order for them to comply with their collective consultation duty to share a copy of the form with the appropriate representatives.
• The timing for the submission of the form will depend on how many employees an employer is proposing to dismiss. This will be either: (a) 30 days when 20 to 99 redundancies are proposed; or (b) 45 days when 100 or more redundancies are proposed, before the first dismissal is to take effect.
• As a reminder, a failure to notify the Secretary of State is a criminal offence and the employer could be liable on summary conviction to an unlimited fine. A director, manager, secretary or other similar officer (or any person purporting to act in any such capacity) could also be liable if the offence by a company is due to their consent or neglect, and in addition could be disqualified as a director.
• Separately, a breach of the collective consultation rules can give rise to liability for a protective award of up to 90 days’ gross pay for each affected employee. This will become even more significant if the Labour government’s proposal to double the maximum protective award (i.e. up to 180 days’ pay) comes into force in April 2026 (as currently proposed).
• Currently, the Government is also exploring proposals to change the collective consultation rules, including a potential change to the threshold number which triggers the duty to collectively consult, but further detail (and consultation) is awaited.

For further information about the new HR1 form, the Insolvency Service has produced guidance, with Q&As about the new form, which can be accessed here.

If you’d like to discuss the above, or collective consultation more generally, please get in touch and our team of experienced Employment lawyers would be happy to help.

The material in this article is provided for guidance and general information only and is not intended to constitute legal or other professional advice upon which you should rely. In particular, the information should not be used as a substitute for a full and proper consultation with a suitably qualified professional. Please do contact the Bates Wells team if you require further information.