The Employment Rights Bill, currently progressing through the House of Lords following its passage through the Commons, contains provisions on zero-hours contracts that represent the most significant change to casual employment law in a generation — and few sectors will feel the impact more acutely than hospitality, where flexible and zero-hours arrangements are structurally embedded across everything from restaurant service teams to event catering.
With Royal Assent expected before the summer recess and implementation scheduled to follow a 12-month transition period, operators now have limited time to understand the changes and assess how their current employment models will need to adapt.
What the Bill actually says
The headline change is the introduction of a right for zero-hours and low-hours workers to request a guaranteed-hours contract reflecting their average working pattern over a 12-week reference period. Crucially, employers will not be required to offer guaranteed hours automatically — but they will be required to respond to a request within a defined timeframe and, if they decline, to provide written reasons.
The Bill also introduces a new right to reasonable notice of shifts, and — most significantly for hospitality — a right to payment for shifts cancelled or curtailed at short notice. The current draft defines "short notice" as less than 48 hours, though this threshold is subject to amendment in the Lords.
The hospitality challenge
The sector's trade bodies have broadly welcomed the principle of improved worker protections while raising serious concerns about operational feasibility. UK Hospitality's submission to the Lords' committee stage argued that the 48-hour cancellation notice requirement, in its current form, would impose significant costs on operators whose trading volumes are inherently unpredictable — weather-dependent outdoor venues, event caterers, and seasonal businesses in particular.
"We support workers having better security," UK Hospitality chief executive Kate Nicholls said in a recent interview. "What we need is a framework that acknowledges the genuine unpredictability of hospitality demand. A sunny Saturday afternoon and a wet one can differ by 40 per cent in covers. That reality has to be part of the conversation."
What operators should do now
Employment lawyers advising hospitality businesses are recommending that operators take the following steps in the coming months:
Audit your current casual workforce. Understand how many of your workers are on zero-hours or low-hours arrangements, what their average weekly hours look like over the past 12 weeks, and which roles are genuinely flexible versus which have become de facto permanent.
Review your rota and scheduling systems. If you are cancelling shifts regularly at less than 48 hours' notice — and many operators are, particularly in response to weather or reservation drop-offs — you will need either to build more buffer into your scheduling or to prepare for cancellation pay obligations.
Take HR and legal advice early. The transition period will pass quickly. Operators who begin modelling the cost impact now will be better placed to absorb it or to restructure their workforce models before implementation.
The Bill is expected to receive Royal Assent in May 2026, with the 12-month implementation period running from that date.