The Government is currently consulting on how new rights around how zero hours and similar type contracts should work in practice, and there’s still time for businesses and workers across the labour supply chain to have their say.
The consultation, “Make Work Pay: ending one-sided flexibility -reforms of zero hours and similar contracts”, opened on 2nd June 2026 and closes at 11.59pm on 25 August 2026. The reforms in question form part of the Employment Rights Act 2025, but the relevant rights have not yet come into effect.
What is being proposed?
The Government’s aim is to tackle what it describes as “one-sided” flexibility and give workers greater security and predictability. The consultation focuses on three key areas:
1. Guaranteed hours
Qualifying workers could have the right to be offered guaranteed hours reflecting the hours they have actually worked over a reference period. The Government’s current preference is for a 12 week reference period and an hours threshold somewhere between 8 and 20 hours per week.
2. Reasonable notice
Employers would have to give qualifying workers reasonable notice of shifts and changes to shifts, with the consultation considering what “reasonable” should mean in practice.
3. Payment for cancelled or changed shifts
Workers could be entitled to compensation where shifts are cancelled, moved or curtailed at short notice.
Who can respond?
The Government is encouraging anyone with a view on the proposed reforms to respond. That includes employers, recruitment agencies, umbrella companies, end clients, workers and anyone else involved in the labour supply chain.
You don’t have to answer every question – the Government specifically encourages respondents to answer those where they have relevant experience or a practical view.
Implementation timeline
The consultation closes on 25th August, after which the Government will consider the responses and develop the final policy and regulations.
The current implementation roadmap places the new guaranteed hours, reasonable notice and short-notice payment rights in 2027, with the exact timing to be confirmed following the consultation.
As with any major area of employment reform, this timetable is subject to change. The final shape and timing could be influenced by the consultation responses, the drafting of secondary legislation and wider political priorities, especially with a newly appointed PM.
Liquid Friday’s view: temporary work is not the same as permanent employment
As a FCSA-accredited member, Liquid Friday took part in an industry roundtable to help inform FCSA’s response to the consultation.
We fully support the Government’s aim of tackling one-sided flexibility and improving security. But we believe the temporary labour market needs to be treated differently from permanent employment.
In our view the proposed guaranteed-hours provisions shouldn’t apply to umbrella company workers. Here’s why:
Umbrella companies employ workers and provide continuity of employment, but they do not create or control assignments. The hours, duration and availability of work are determined by the agency and end client. Applying guaranteed hours requirements based on historic working patterns therefore risks treating temporary employment in the same way as permanent employment, the two are fundamentally different.
It also overlooks the two-way flexibility that temporary work provides, and that many agency workers actively value. It could also have unintended consequences, including shorter assignments, fewer work opportunities and an increase in non-compliant umbrella providers.
Proportionate alternatives
If the Government does apply these provisions to umbrella workers, we are in agreement with the FCSA stance that there need to be more proportionate alternatives.
For example:
- A right to request guaranteed hours: Instead of automatically requiring guaranteed hours, qualifying workers could have a statutory right to request a guaranteed hours contract.
- A 52 week reference period: This would provide a more accurate picture of a temporary worker’s working pattern than the much shorter period being mottled by the Government.
- No reasonable notice requirement for agency workers: Short-notice staffing is a fundamental part of the temporary supply market and workers remain free to accept or decline assignments.
- Cancellation payments paid by the end hirer: Where a shift is cancelled or changed at short notice, responsibility should sit with the end hirer that makes the decision, not the umbrella company, which does not control the assignment.
- Clarity on enforcement: The government has acknowledged that agency work is complex. This must be reflected in the final rules, including how they are to be enforced, and where enforcement will sit.
The overall result should be to protect workers without removing the flexibility that makes temporary work work, for contractors, agencies and businesses alike.
Have your say
Agencies, umbrella companies, end clients and contractors all have valuable real-world experience of how the temporary labour market operates. This is an opportunity to share that experience and highlight the practicalities, and potential unintended consequences of the proposed changes.
The consultation closes at 11.59pm on 25th August 2026. You can respond here.
