Already in force — action required now
These changes are already law. If you have not addressed them, you are non-compliant today.
February–April 2026 Overdue if not done
Update your SSP process. SSP starts from day one of sickness for all qualifying workers — no waiting days, no earnings threshold. Every manager who takes sick calls must know this. Payroll must reflect it.
Brief your supervisors on the new SSP rules. A supervisor who tells a casual worker they do not qualify for SSP is creating a tribunal risk. Brief every person who handles sick calls.
Start keeping holiday pay records for all workers. This is a statutory requirement since 6 April 2026. Record when leave is taken and what was paid, for every worker including zero-hours and casuals.
Review your holiday pay calculation method. From 1 January 2024, rolled-up holiday pay at 12.07% per payslip is explicitly lawful for genuine irregular hours and zero-hours workers. The 52-week average is also permitted. If you have permanent part-year workers, take advice on which method applies to your specific arrangements.
Confirm agency shift notice compliance. Since February 2026, you and your agency jointly must give agency workers reasonable notice of shifts and changes. Review your booking practices with your agency.
Check your payroll against the new NMW rates. NMW is £12.71 for 21+ workers from 1 April 2026. Any underpayment is an immediate liability.
Prepare now — for 2027 obligations
These changes take effect in 2027 but require data and process changes that start now.
Start immediately — data builds over time Prepare now
Record actual hours per worker per shift. The guaranteed hours right uses actual hours worked over a 12-week reference period. You need real clock-in and clock-out data, per worker, every shift — not just scheduled hours.
Identify workers likely to qualify for guaranteed hours. Which of your zero-hours or casual workers work consistent patterns? Map them now so you know who will be affected when the obligation lands.
Review long-standing zero-hours arrangements. Workers who have been doing consistent hours for a year or more are candidates for a conversation about their contract before 2027 forces one. It is better to manage this proactively.
Update your disciplinary and performance process. Unfair dismissal protection reduces to six months from January 2027. Workers with six months' service need a fair process. Make sure your managers know this.
Review your agency worker arrangements. If the same workers come to your site regularly, start mapping their patterns. The guaranteed hours right is expected to extend to agency workers in 2027.
The 12-week reference period is backwards-looking. When the guaranteed hours obligation comes into force, the calculation draws on data that should already exist. If you start recording actual hours today, you have 12 months of clean reference period data before the first potential obligation falls due. If you wait until 2027 to start, you will not have the data you need.
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