Government plans for guaranteed hours is a ‘substantial threat to good jobs’

Four trade bodies have sent a joint letter to the government raising concerns over plans for guaranteed hours – a part of the Employment Rights Act.

The bodies – British Retail Consortium, Food and Drink Federation, Recruitment and Employment Confederation and UK Hospitality – warn that the measure is a ‘substantial threat to good jobs’.

Employment Rights Act

First announced in October 2024, the Employment Rights Bill received Royal Assent on the 18^th of December 2025 and is now the Employment Rights Act 2025, which will be rolled out in phases.

Most key changes started in April 2026, but will be followed by further provisions in October and 2027 and include things like:

• Changing the qualifying period to claim unfair dismissal from two years to six months.
• A strengthened right to request flexible working arrangements from day one in a role.
• Zero hour and agency workers will gain the right to request guaranteed hours based on a 12-week average.
• It will be more difficult for employers to use ‘fire and rehire’ tactics for contract changes (except in insolvency).
• The three-day waiting period for Statutory Sick Pay (SSP) will be eliminated.
• Enhanced rights for time off work for bereavement.
• Better access to paternity and parental leave from day one.

Joint letter to the Secretary of State for Business and Trade

In the letter dated 24th April 2026, the four trade bodies suggest changes to the policy that will avoid ‘the double whammy of increasing unemployment and fewer young people entering the labour market’.

An extract from the letter says:

‘With demand already weakened, poorly designed guaranteed hours measures could become a tipping point, pushing employers to reduce hiring, limit hours or withdraw flexible roles altogether, denying work to those who need it most, or moving to less secure, more casual models of engagement.’

In the letter, they call on the government to:

• Set the reference period assessing regular hours to be an absolute minimum of six months, with a 12-month period most accurately reflecting genuine regularity.
• Acknowledge that temporary agencies already operate within robust regulatory frameworks, and so to avoid a drive to false self-employment, any additional hours should be determined by agencies rather than end-hirers. The Low Pay Commission noted that other systems – like Ireland – treated agency and temporary cover differently.
• Set the low hours threshold at eight hours so the change remains targeted on those without predictable hours rather than sweeping up workers who don’t need low hours protections and giving workers a right to demand more work where that may not be available.
• Engage in immediate discussion with business groups about the suggested changes to the government’s proposals.

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