Guaranteed hours are coming, and nobody has to act yet
What the Act actually does about zero-hours contracts, when it is expected to bite, and the one thing worth doing now — which is not signing anything.
Covers · · 5 min read
The Employment Rights Act 2025 became law on 18 December 2025. Since then a steady number of people have tried to sell hospitality operators an urgent solution to it. It is worth being precise about where this actually stands, because the honest answer is duller than the sales pitch.
What it does
It creates a right for workers on zero-hours and low-hours arrangements to be OFFERED guaranteed hours reflecting the hours they actually worked over a reference period. The offer recurs: at the end of each reference period, the employer has to make one. The worker can decline it and stay flexible.
The intent is not to abolish flexible working in hospitality. It is to stop a contract that says zero from describing somebody who has worked thirty hours a week for a year.
When
The guaranteed hours measures are expected in 2027, and the detail — how long a reference period is, what counts as low hours, how the offer has to be made — is being set in regulations that are still the subject of government consultation.
So: it is not in force. Anybody telling you that you are currently in breach is either mistaken or selling something. Equally, anybody telling you it will be watered down to nothing is guessing.
The one useful thing to do now
Find out what your own numbers say. For each person on a zero-hours or low-hours arrangement, what have they actually averaged over the last twelve months?
You will learn two things. Most of your casuals are genuinely casual and the change will barely touch them. And a small number have been doing a permanent job on a flexible contract for a long time — which is the group the Act is aimed at, and the group most likely to leave you for somebody who offered them certainty first. Knowing which is which is useful whatever the regulations eventually say, and it costs one afternoon with the rota.
This is a summary of a moving picture, written in September 2026, and it is not legal advice. Check the current position before you change a contract — the timeline below is the one that gets updated.
Acas is tracking this as it lands: Employment Rights Act 2025