The manager's guide to guaranteed hours and shift notice rights
The rules on zero-hours contracts are changing, but much of the detail is not yet settled.
This guide sets out the legal position for zero-hours and low-hours workers today, what the Employment Rights Act 2025 introduces on guaranteed hours, reasonable notice of shifts and payment for cancelled shifts, and what is confirmed against what remains part of a live government consultation due to close in August 2026. It also sets out practical steps you can take now to prepare.
Zero-hours and low-hours workers today
- There is currently no statutory right to a minimum number of guaranteed hours for zero-hours or low-hours workers.
- There is currently no statutory right to advance notice of a shift, or to compensation if a shift is cancelled, moved or cut short.
- Zero-hours workers who qualify as a worker or employee still have National Minimum Wage or National Living Wage, paid holiday and rest break entitlements.
- Employers cannot use an exclusivity clause to stop a zero-hours worker taking work elsewhere, or dismiss or penalise them for doing so.
- ACAS guidance says a responsible employer should have a clear policy on cancelling shifts, including notice and any compensation, even though this is not currently a legal requirement.
The right to guaranteed hours
- Sections 1 to 4 of the Employment Rights Act 2025 introduce a right to guaranteed hours, a right to reasonable notice of shifts, a right to payment for cancelled or curtailed shifts, and rights for agency workers.
- A qualifying worker is someone on a zero-hours or low guaranteed-hours contract who works a specified pattern of hours over a reference period.
- The employer must then offer terms that reflect the hours actually worked during that reference period.
- A worker can decline a guaranteed hours offer and stay on their existing zero-hours or low-hours terms if they prefer.
The reference period: not yet confirmed
- The Act itself leaves the length of the initial reference period, and any subsequent reference period, to regulations made by the Secretary of State.
- The government's ongoing consultation states a preference for an initial reference period of 12 weeks.
- Reference periods of 26 or 52 weeks are also being considered, for the initial period, subsequent periods, or both.
- The consultation is also considering how much gap to leave between reference periods, to avoid reassessing hours too frequently.
Who is likely to qualify
- The consultation proposes a range of eight to 48 hours a week for the threshold that would define a qualifying low-hours contract.
- Within that range, the government has stated a preference for a threshold of between eight and 20 hours a week.
- The consultation is also considering whether qualification should depend on a minimum number of weeks worked, a minimum number of hours, or both.
- Both zero-hours workers and low guaranteed-hours workers are within scope of the right, not only those with no guaranteed hours at all.
Reasonable notice of shifts
- Workers will be able to bring an employment tribunal claim if they are not given reasonable notice of a shift or a change to it.
- For directly engaged workers, the consultation proposes a presumed-reasonable notice period of between one and four weeks, which an employer could depart from if it can justify doing so.
- The consultation is also considering different notice arrangements for agency workers, reflecting the extra party involved.
- Tribunals would be able to look at all the circumstances in deciding whether notice given was reasonable, not only a single fixed period.
Payment for cancelled or curtailed shifts
- The right applies when an employer cancels a shift, moves it to a different date, or curtails it once it has started, within a 'short notice' window that is still to be defined.
- The consultation proposes several options for how many days count as short notice, including one, two, three, five or seven days.
- The consultation proposes basing compensation on a percentage of the worker's expected earnings for the shift, or on earnings calculated using the National Minimum Wage or National Living Wage rate.
- The exact percentage or amount of compensation has not been set and remains part of the consultation.
Agency workers
- The default position is that the hirer, not the agency, is responsible for making a guaranteed hours offer, although this can be reassigned to the agency or another intermediary.
- Both the agency and the hirer are expected to have responsibilities around giving reasonable notice of shifts.
- The consultation proposes that the agency would generally make any short-notice cancellation payment, with the ability to recover the cost from the hirer.
- Detail on how these duties apply where umbrella companies are involved is also part of the consultation.
The consultation and what happens next
- The consultation, 'Make Work Pay: ending one-sided flexibility - reforms of zero hours and similar contracts', opened on 2 June 2026.
- It closes at 11:59am on 25 August 2026.
- As at July 2026, the consultation remains open and the government has not published its response or final regulations.
- The reforms are expected to come into force in 2027, but no exact commencement date has yet been confirmed.
Preparing your business now
- Review your current zero-hours and low-hours worker arrangements, including how shifts are offered, recorded and cancelled.
- Set up a way to record the hours each zero-hours or low-hours worker actually works, since a future guaranteed hours offer will be calculated from hours worked over a reference period.
- Keep those records accurate and up to date, so you are ready to calculate an offer as soon as the reference period is confirmed.
- Review how shifts are scheduled and cancelled today, so you can see what would need to change once notice and compensation rules take effect.
- Assign someone to monitor the consultation outcome and the resulting regulations, so your business is not caught out when the detail is confirmed.
Getting ready for guaranteed hours: the essentials
- There is no current legal right to guaranteed hours, shift notice or cancellation pay, though other protections already apply.
- The Employment Rights Act 2025 creates these rights in principle, in sections 1 to 4, but they are not yet in force.
- The consultation on the detail closes on 25 August 2026, and the reforms are expected in 2027, with no exact date yet confirmed.
- Reference period length, the qualifying hours threshold, notice periods and compensation rates are all still to be settled.
- Agency workers are covered in principle, with duties expected to be split between the hirer and the agency.
- Review your current arrangements and start keeping accurate hours-worked records now, ahead of the final regulations.
How Jamie HR helps
- Hours worked records kept accurately for every zero-hours and casual worker, ready to support a guaranteed hours calculation once the reference period is confirmed.
- Contracts and written statements generated and stored, so terms can be updated quickly if a guaranteed hours offer becomes due.
- Policy library for zero-hours and casual worker arrangements, kept up to date as the law changes.
- Reminders and alerts so key dates are not missed once the reference period and offer rules are confirmed.