
Zero hours contracts have long been used by employers who need flexibility, including where demand changes quickly. For example, in farming and rural businesses, casual and variable hours arrangements may be used for seasonal work, harvest, lambing, events, farm shops, tourism, packing, processing or other peaks in demand.
Reform on the horizon
The Government’s employment law reforms do not appear to introduce a complete ban on zero hours contracts. However, they are expected to significantly change how zero hours, ‘low’ hours and variable hours arrangements operate.
The reforms are aimed at ending “one-sided flexibility”. Eligible workers on zero or low hours contracts are expected to gain the right to be offered a guaranteed hours contract reflecting the hours they regularly work over a reference period, currently expected to be 12 weeks. This is expected to be an obligation on the employer to make an offer, rather than simply a right for the worker to ask. The worker would then choose whether to accept or refuse the offer.
The reforms are also expected to introduce rights around reasonable notice of shifts and compensation where shifts are cancelled, moved or cut short at short notice. This could have a significant impact if you rely on short-notice labour or frequent rota changes.
Preparation is key
The key message is not to panic, but to prepare. You may have genuine reasons for needing flexibility. However, you should start reviewing how casual and variable hours arrangements are currently being used.
Practical steps
As part of your review, make sure you:
identify who is engaged on zero hours, casual or variable hours terms;
check whether workers are regularly working similar hours each week;
review contracts and offer letters;
keep accurate records of hours worked;
consider whether some roles should move to minimum hours or fixed-term contracts;
review how shifts are offered, changed or cancelled; and
taking advice (by contacting our team of advisers) before changing existing arrangements.
What not to do
You should also be careful about reducing hours simply to avoid future obligations. Anti-avoidance provisions are expected, meaning workers may be able to bring claims where hours are deliberately limited to avoid triggering the duty to offer guaranteed hours.
Start reviewing now
Although further detail is still awaited, now is a sensible time for you to review your arrangements. This is particularly important for businesses that rely on seasonal workers, casual labour, weekend staff, farm shop employees or workers whose hours vary significantly from week to week.
Our team of Employment advisers are only a phone call away if you want to discuss reviewing any current arrangements or changes, you’re planning to make.
Have your say
The government is seeking views in a consultation paper issued on 2 June 2026 and closing 25 August 2026 on the Regulations needed to implement the zero hours measures in the Employment Rights Act 2025.
GOV.UK | Make Work Pay: ending one-sided flexibility – reforms of zero hours and similar contracts
Remember, if you’re unsure, please feel free to discuss any queries with us on 0370 840 0234.
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