Zero-hours and casual arrangements are woven into security, events, hospitality and care. A relief officer who covers absences, a door team booked venue by venue, a bank of stewards for match days: all of it typically runs on contracts with no guaranteed hours. The Employment Rights Act 2025, which became law on 18 December 2025, does not ban that model. It does end what the government calls "one-sided flexibility", and it changes what an employer, and a hirer of agency staff, must offer. Here is what the official sources actually say.
The numbers, from the ONS
The Department for Business and Trade's factsheet on the reforms adds that the sectors relying most on zero-hours contracts are hospitality, transport, arts and other services, health and social care, and retail and wholesale; that people on these contracts are more likely to be young (16 to 24), female or in full-time education; and that around 900,000 people worked in temporary agency jobs in March 2024, about 140,000 of whom also identified as being on a zero-hours contract.
Three new rights
The Act contains three measures aimed at zero-hours and "similar" contracts. In the government's own words, they are: a right to guaranteed hours, where the number of hours offered reflects the hours worked by a qualifying worker during a reference period; a right to reasonable notice of shifts; and a right to payment for shifts cancelled, curtailed or moved at short notice.
1. Guaranteed hours
After the end of each reference period an employer must make a guaranteed hours offer to every qualifying worker. The offer must reflect the hours the worker actually worked in that period. The length of the reference period will be set in regulations. A worker can reject the offer and stay on their current arrangement; the government is explicit that students and people with caring responsibilities who value flexibility will keep it.
Enforcement is through the employment tribunal: a worker who qualifies but never receives an offer can bring a claim.
2. Reasonable notice of shifts
Employers must give eligible workers reasonable notice of shifts and of changes to shifts. Regulations will state how much notice is presumed reasonable as a starting point, plus the factors a tribunal should weigh. Two points matter for rota managers: the right applies to employer-initiated changes only, so two workers swapping a shift between themselves at short notice creates no liability; and the government has said that in some circumstances "even very short notice could count as reasonable". Where notice was not reasonable and the dispute cannot be settled, a tribunal may award compensation for the loss suffered.
3. Payment for shifts cancelled, curtailed or moved at short notice
Employers must pay workers when they cancel, reschedule or cut short a shift at short notice. The amount and the definition of "short notice" will be set in regulations, with some limited exceptions possible. No payment is due where the worker initiated the change: a worker who calls in at short notice to say they cannot work, does not turn up, or voluntarily gives up a shift in a swap is not owed a short notice payment.
Agency workers: the hirer is on the hook
The Act extends all three measures to agency workers, specifically so that agency work cannot become a loophole. For guaranteed hours, the hirer is responsible by default for making the offer, which must reflect the hours the agency worker worked under the hirer's direction and supervision during the reference period. A worker who accepts takes up a worker's contract with the hirer; one who declines stays on their existing arrangement. For short notice payments, the agency pays so the worker is not kept waiting, and the agency can recoup the payment from the hirer. Reasonable notice is owed by agency and hirer alike. Regulations may place the guaranteed hours obligation on the agency instead in certain scenarios.
When it starts
The government's timeline update of 25 September 2026 places the introduction of the right to guaranteed hours and the right to reasonable notice and short notice payments in 2027, adding that "timings will be updated after consultation". That consultation, on the detail of the reforms, ran from 2 June to 25 August 2026 and is now being analysed. Acas states plainly that the government has not announced when in 2027 most of these changes will happen. Several other measures that affect zero-hours workers are already in force or dated:
| Date | Measure (GOV.UK timeline, 25 September 2026) |
|---|---|
| 6 April 2026 | Statutory Sick Pay: Lower Earnings Limit and waiting days removed, so low-hours workers qualify from day one of sickness |
| 7 April 2026 | Fair Work Agency established (enforcement of the National Minimum Wage, agency rules and, later, holiday pay) |
| 1 October 2026 | Employment Tribunal claim time limit increased from 3 to 6 months |
| January 2027 | Unfair dismissal qualifying period cut from two years to six months; compensatory award cap removed |
| 2027 | Guaranteed hours, reasonable notice and short notice payments; umbrella companies brought within agency regulation |
What zero-hours workers are already entitled to
None of the new rights changes the existing floor, which Acas and GOV.UK set out clearly. Depending on employment status, zero-hours workers are entitled to the National Minimum Wage and National Living Wage, paid holiday, rest breaks, payslips and protection from discrimination and from detriment for asserting their rights. Exclusivity clauses, which stop a worker taking other work, cannot be enforced in zero-hours contracts and a worker cannot be dismissed for working elsewhere. GOV.UK's employer guidance says zero-hours arrangements are unsuitable "where work is regular and predictable over a continuous period of time", that employers "should give as much notice as possible when offering work" and "should not cancel work at the last minute". Acas asks employers to "have a clear policy on cancelling work, including the notice they will give and details of any compensation". Employees who are laid off can claim statutory guarantee pay of up to £41 a day for 5 days in any 3 month period.
Six things to put in place now
- Map the workforce. List everyone on zero-hours or low-hours terms, directly employed or through an agency, and how many hours each actually works. The reference period test will be applied to real hours, not contract wording.
- Fix the hours records. Guaranteed hours offers must reflect hours worked; agency offers must reflect hours worked under your direction. Timesheets, sign-in data and rota systems need to agree.
- Write the shift notice and cancellation policy today. Acas already expects one. Set the notice you give, how cancellations are communicated, and what you pay now. When regulations define "reasonable" and "short notice", you adjust a policy rather than invent one.
- Review agency and labour provider contracts. Who makes guaranteed hours offers, how short notice payments are recouped, and how hours are reported to you. This is where BS 10119 on the provision of labour earns its keep.
- Stop using zero-hours where the work is regular. GOV.UK's guidance has said this for years; from 2027 the guaranteed hours offer will make it a legal duty in practice.
- Brief the people who write the rota. Supervisors and controllers decide notice and cancellations every day. They need to know the difference between an employer-initiated change and a worker swap, and to record which is which.
Learn it properly, and prove it
If you supply or hire labour into the security or events sector, the BS 10119 for Managers course covers the British Standard for providing labour, including the workforce, agency and contract arrangements these reforms land on, with a final assessment and a verifiable certificate. Completion is recorded on your training matrix, so when a client or auditor asks who understands the new duties, the answer is a link, not a filing cabinet.
References
Every fact and figure above is taken from the following official sources. Verify them directly:
- Department for Business and Trade, Factsheet: Reforms of zero hours and similar contracts (Employment Rights Act 2025 collection, GOV.UK). assets.publishing.service.gov.uk/media/6a1d6024c7335e2ca6daad8c/zero-hours-contracts.pdf
- Department for Business and Trade, Factsheet: Employment Rights Act 2025, Overview (GOV.UK). assets.publishing.service.gov.uk/media/696fabb3c0f4afaa9536a0f2/employment-rights-act-2025-overview-factsheet.pdf
- GOV.UK, Plan to Make Work Pay and Employment Rights Act: timeline update, updated 25 September 2026. gov.uk/government/publications/implementing-the-plan-to-make-work-pay-and-employment-rights-act/...timeline-update
- GOV.UK, Make Work Pay: ending one-sided flexibility, reforms of zero hours and similar contracts (consultation, 2 June to 25 August 2026). gov.uk/government/consultations/make-work-pay-ending-one-sided-flexibility-reforms-of-zero-hours-and-similar-contracts
- GOV.UK, Zero hours contracts: guidance for employers. gov.uk/guidance/zero-hours-contracts-guidance-for-employers
- Acas, Employment Rights Act 2025. acas.org.uk/employment-rights-act-2025
- Acas, Zero-hours contracts. acas.org.uk/zero-hours-contracts
- Acas, Lay-offs and short-time working (statutory guarantee pay). acas.org.uk/lay-offs-and-short-time-working
- Office for National Statistics, EMP17: People in employment on zero hours contracts, Labour Force Survey, released 18 August 2026 (Table 1, April to June 2026). ons.gov.uk/.../emp17peopleinemploymentonzerohourscontracts
- Employment Rights Act 2025, c. 36 (legislation.gov.uk). legislation.gov.uk/ukpga/2025/36
This briefing is general information, current at 28 September 2026, and is not legal advice. The detail of the reference period, hours threshold, presumed reasonable notice and short notice payments will be fixed by regulations that had not been made at the time of writing.