Zero-Hours Contracts: What UK Employers Need to Do Ahead of the 2027 Reforms

The Employment Rights Act will introduce new requirements around guaranteed hours for eligible workers, with implementation expected in 2027. While that may seem some way off, employers who rely on zero-hours or low-hour contracts should start preparing now.

Understanding the reforms early will help businesses review their workforce arrangements, assess potential impacts and put plans in place well before the new obligations take effect.

Zero-hours contract changes are coming. Is your business ready?

For many UK employers, zero-hours contracts have provided a practical way to manage fluctuating demand, seasonal peaks and variable workloads. They offer flexibility for organisations and, in many cases, for workers too. 

However, reforms introduced through the Employment Rights Act 2025 are set to change how businesses engage and manage zero-hours and low-hours workers. While the legislation does not prohibit flexible working arrangements, it does introduce new employer responsibilities that could affect workforce planning, contracts and compliance processes. 

For business leaders, the question is no longer whether change is coming or not, but instead, how best to prepare your organisation for the changes. 

What are the new zero-hours contract rules?

Under the reforms, workers who regularly work consistent hours may become entitled to receive an offer of a contract that reflects those working patterns. 

In simple terms, where a worker’s actual hours have become predictable over time, employers may need to offer a contract with guaranteed hours that better reflects those hours. 

Importantly: 

• Zero-hours contracts are not being banned. 

• Workers will still be able to choose flexibility where it suits them. 

• Employers will be responsible for identifying when a qualifying working pattern exists and making an appropriate offer. 

• New enforcement powers are being introduced to support compliance. 

Although we await final details following the closure of consultation, the direction of travel is clear: businesses will need greater visibility of working patterns and stronger workforce management processes.

Which employers will be most affected?

Any organisation that relies on flexible staffing arrangements should be reviewing the impact of these changes now. 

This is particularly relevant for sectors such as: 

Hospitality and Leisure 

Businesses often rely on flexible staffing to manage peaks in demand, events and seasonal trading periods. However, many workers may already be working regular shifts week after week. 

Retail 

Part-time and flexible workers frequently develop consistent working patterns that could trigger new obligations under the legislation. 

Care and Healthcare 

Regular rotas or visiting patterns often result in workers providing similar hours over extended periods. 

Construction 

Variable labour requirements can create complex employment arrangements that may need reviewing as the legislation develops. 

Education and Training 

Sessional tutors, trainers and support staff may work more predictable schedules than their contracts currently reflect. 

Crucially, the reforms are not limited to large employers. SMEs using even a small number of zero-hours or low-hours workers could be affected. 

Why workforce visibility will matter more than ever

One of the biggest challenges arising from the reforms is likely to be identifying when a working pattern becomes sufficiently regular to meet the obligation. 

Many organisations currently lack a clear picture of: 

• How many workers are engaged on zero-hours contracts. 

• The hours those individuals actually work. 

• Whether temporary arrangements have evolved into long-term patterns. 

• Which managers are responsible for allocating shifts and recording hours. 

Without reliable workforce data, compliance could become significantly more difficult. 

Businesses that establish clear monitoring processes now will be in a stronger position when the reforms take effect.

Three steps employers should take before 2027

1. Audit Your Flexible Workforce 

Start by identifying all workers engaged on zero-hours or low-hours arrangements. 

Look beyond the contract itself and examine actual working patterns. Are there individuals who consistently work the same hours or days each week? Have temporary arrangements become permanent in practice? 

A workforce audit will help highlight potential areas of exposure before the new requirements come into force. 

2. Review Employment Contracts and Policies 

Many contracts currently in use were drafted long before these reforms were proposed. 

Now is the ideal time to review: 

• Zero-hours contract wording. 

• Casual worker agreements. 

• Shift allocation procedures. 

• Workforce planning policies. 

• Record-keeping processes. 

Updating documentation proactively is often far less disruptive than making rushed changes under legislative deadlines. 

3. Strengthen Workforce Planning Processes 

The most future-ready employers are focusing on process as much as policy. 

Consider: 

• How working hours are recorded. 

• How regular patterns are identified. 

• Who will be responsible for reviewing eligibility. 

• How offers of guaranteed hours will be managed and documented. 

HR systems and softwares, workforce management and regular compliance reviews can all play an important role in supporting these requirements. 

What does “offering a guaranteed hours contract” mean in reality?

This is where the practical challenges begin, and where many employers are likely to need expert guidance. 

Understanding how your employees are working in reality is key.  

The proposed reforms rely on a reference period, which will be used to assess whether a worker’s hours have become sufficiently regular to justify an offer of guaranteed hours. While the Government is yet to confirm the final parameters, the underlying principle is straightforward: where a consistent working pattern has developed over time, employers may be required to offer a contract that better reflects those actual hours. 

A compliant offer is expected to: 

• Reflect the worker’s established working pattern and average hours. 

• Be issued within the required timeframe following the assessment period. 

• Allow the worker to make an informed choice about whether to accept or decline the offer. 

Employers that fail to put appropriate processes in place could face increased legal and compliance risks. Claims relating to guaranteed hours and zero-hours contract reforms will form part of the new employment rights framework, and with the Fair Work Agency now active, the scrutiny on employer compliance has increased.

The Bigger Employment Law Picture

The BThe guaranteed hours reforms sit within a much wider package of employment law changes introduced through the Employment Rights Act 2025. 

Alongside zero-hours contract reforms, employers are also navigating developments relating to: 

• Unfair dismissal rights. 

• Fire and rehire restrictions. 

• Flexible working. 

• Enhanced worker protections. 

• Employment tribunal reforms. 

Taken together, these changes represent one of the most significant shifts in UK employment law in decades. 

Businesses that take a strategic approach now will be better positioned to manage compliance, protect productivity and maintain positive employee relations.

Looking beyond compliance

While many organisations will naturally focus on legal obligations, the reforms also present an opportunity to review workforce strategy more broadly. 

Employers who understand their workforce needs, improve planning and create greater clarity around working arrangements are often better placed to: 

• Improve employee engagement. 

• Reduce turnover. 

• Strengthen recruitment efforts. 

• Enhance operational efficiency. 

• Minimise employment law risks. 

The organisations that gain the most value from these changes are unlikely to be those that simply meet the minimum requirements. They will be the businesses that use this period to build more sustainable workforce models.

Preparing for 2027 starts now 

The 2027 implementation may feel some way off, but employment law changes of this scale require planning, process reviews and leadership buy-in. 

The sooner businesses understand how the reforms apply to their workforce, the more time they have to assess risk, update contracts and build robust compliance processes. 

For many employers, the most valuable first step is simply understanding where flexible working arrangements exist today, and whether those arrangements reflect the reality of how work is being carried out. 

If you’re unsure how these changes could affect your organisation, Omny Group’s HR Support and Employment Law experts can help you review your workforce arrangements, assess any compliance gaps and prepare for the new requirements with confidence.