Tania Bowers, Global Public Policy Director at APSCo UK and OutSource commented:
“The updated timeline is of interest to recruitment companies and workforce solution providers. The Department for Business and Trade (DBT) has indicated that there should be more news on further ERA consultations by 6th February. This news may shed light on the fact that ZHC measures are still scheduled for 2027, but the latest implementation timeline omits the words “applying ZHC measures to agency workers”.
“APSCo UK and OutSource wrote to the Minister for Employment Rights and Consumer Protection Kate Dearden MP in mid-January highlighting that the Government is flying blind in terms of impact on the economy of applying the ZHC measures to agency workers. The extension to agency workers was not referenced in the Government’s latest economic impact analysis (published 7th January) with the analysis suggesting ZHC would apply to few employers and low paying sectors would be most heavily impacted. The analysis optimistically reduced likely impact overall of the ERA to £1 billion from an earlier £5 billion estimate.”
“APSCo UK stressed that contract market resilience was evidenced throughout the second half of 2025, highlighting the critical role contract work plays during economic uncertainty. Given the Government’s renewed push for growth in 2026, we hope that it is finally looking to push back on provisions that will reduce flexibility, and damage job creation, particularly for young people and disabled workers. Cohorts that the economic analysis made clear are more likely to work on zero-hour contracts, and our members know these are an important route into permanent work.”
“The revised timeline also highlights that the introduction of the “fire and rehire” changes are pushed back from October 2026 to January 2027 as the government has published a new consultation, open until 1st April, seeking feedback on how the changes should impact contractual terms on expenses, benefits, and changes to shift patterns.”
“Recognition of businesses’ need to adapt is welcome. However, to improve productivity and growth across the private and public sectors, organisations need bandwidth and budget to invest in infrastructure, digital automation and delivering good jobs. From now on this must be front of mind for the Government, to build upon the flexibility that drives UK competitiveness.”