News · Recruitment & End-Hirers · OPRaaS Platform
Zero-hours contract compliance is moving from a single-employer issue to a shared labour supply chain duty. The government’s zero-hours reforms are expected to give qualifying workers the right to a guaranteed-hours offer, reasonable notice of shifts and payment where shifts are cancelled, moved or cut short at short notice.
For agency workers, that creates a more complicated compliance record. The agency may supply and pay the worker, but the hirer often controls the work pattern, the shift requirement and the decision to cancel, extend or reduce hours. That means the evidence behind zero-hours contract compliance has to work across both organisations.
The trigger is the government’s consultation on reforms of zero hours and similar contracts, published on 2 June 2026 as part of the Make Work Pay programme. Writing in The Global Recruiter, the publication gathered reaction from across the recruitment and HR sector. The direction is broadly understood. The operational detail is where agencies and hirers will feel the pressure.
What the zero-hours reforms are expected to change
The reforms do not simply ban all zero-hours working. They are designed to end one-sided flexibility by giving workers more predictability over hours, shifts and income. The measures sit within the Employment Rights Act 2025, with regulations expected to fill in key detail before implementation.
The main changes are expected to cover three areas:
- A right to be offered guaranteed hours that reflect hours worked over a reference period.
- A right to reasonable notice of shifts and changes to shifts.
- A right to payment where a shift is cancelled, moved or curtailed at short notice.
These duties are not yet fully in force. ACAS states that the new rights for zero-hours and low-hours workers are expected to apply in 2027. The government consultation is now dealing with the operational design, including the reference period and how the rules apply in practice.
For end-hirers and recruitment agencies, the important point is already clear. Zero-hours contract compliance is no longer only a question of whether the contract was drafted correctly at the start. It becomes a rolling record of hours, shifts, notice, cancellations and worker status.
Why agency workers sit at the centre of the reforms
Agency workers sit at the centre of the compliance challenge because the relationship is split. The agency may be the contractual supplier and payroll route, while the hirer controls the day-to-day need for labour. That split matters when the law asks who must offer guaranteed hours, who gave reasonable notice, and who caused a cancellation.
The government has already made clear that the reforms are intended to cover agency workers, so that agency arrangements cannot be used to avoid rights created for zero-hours and low-hours workers. The practical effect is one worker record with two operational owners.
That is what makes zero-hours contract compliance a shared duty. The agency cannot answer every question without the hirer’s shift data. The hirer cannot evidence every obligation without the agency’s worker, contract and pay records. If those records do not reconcile, neither party has a clean answer.
The classification shortcut, and why it carries a bill
There is an obvious shortcut some organisations may consider: move away from zero-hours or agency arrangements and use self-employed contractors, fixed-term contracts or alternative engagement models instead.
That may reduce one type of administrative burden, but it can open another. Moving someone into a different engagement model does not settle their employment status, tax position or off-payroll working risk. It simply creates a new set of tests to evidence.
Worker status, control, personal service, substitution, mutuality of obligation and the reality of the working arrangement still matter. If a worker is treated as self-employed but managed like an employee or worker, the zero-hours contract compliance question has not disappeared. It has been moved into status, tax and contract risk.
Zero-hours contract compliance as a shared, tracked record
The reforms reward organisations that already treat workforce data as live evidence rather than paperwork reconstructed after a dispute. Guaranteed-hours offers depend on hours actually worked over a reference period. Reasonable-notice questions depend on when a shift was offered, changed or cancelled. Short-notice payments depend on who made the change and when.
That turns zero-hours contract compliance into a tracked discipline. Across an agency and its hirers, the record needs to show what happened, when it happened, who controlled it and what the worker was told.
In practice, that means holding, per worker:
- A live count of hours worked over the relevant reference period, reconciled against timesheets, assignment schedules and pay records.
- A dated log of shifts offered, accepted, changed, cancelled or curtailed, including who made the change and what notice was given.
- A current record of employment status, contract type and assignment terms, reviewed when the role, hours, rate, end-client or working pattern changes.
- A clear split of responsibility between agency and hirer, so guaranteed-hours, notice and cancellation-payment questions can be answered from evidence rather than assumption.
Where contract terms are checked in the OPRaaS LSCA course
This is the territory the OPRaaS Labour Supply Chain Assurance Self-Certification Course covers in Module 9, on contract compliance for temporary workers.
The module treats contract terms as live controls. Employment status, contract type, zero-hours arrangements, fixed-term provisions and assignment terms are not optional detail. They define how the worker is engaged, how the relationship is managed and what evidence the organisation must keep.
Zero-hours contract compliance therefore lives in the contract record as well as the shift record. If the worker’s actual pattern changes but the contract, written statement or assignment documentation does not, the evidence starts to drift. The reforms simply raise the cost of allowing that drift to continue.
The self-assessment question is straightforward: are contracts reviewed and updated to reflect changes in UK employment law, and does the written statement of particulars still match the contract and the working reality? The OPRaaS methodology treats that review as a standing control, not an annual tidy-up.
How the OPRaaS Virtual Compliance Director supports agencies and hirers
The OPRaaS Virtual Compliance Director (OPRaaS VCD) platform embeds senior governance leadership into a recruitment agency or end-hirer without the cost of a full-time director. It builds audit-ready controls across right to work, IR35, CIS, GLAA, modern slavery and HMRC’s wider labour supply chain expectations, and keeps them current as engagements and the law change.
For zero-hours contract compliance, that means treating hours, status, contracts and supplier records as connected evidence. Right to work, identity, worker status and contract terms are captured at onboarding and re-checked on a risk-based cadence, with changes written into the worker’s evidence record.
Supplier risk is also monitored across the wider chain. Umbrella companies and sub-agencies can be tracked against Companies House for director and ownership changes, and against credit-risk indicators such as county court judgments and financial-strength downgrades.
OPRaaS, On-Pay-Roll-as-a-Service, is a systemised governance and workforce management partner for organisations that rely on temporary, contractor and contingent labour, from recruitment agencies and end-hirers to umbrella companies, managed service providers and public sector buyers. It is approved on UK Government Commercial Agency frameworks including RM6310 Audit & Assurance Services Lots 2 & 4, RM6219 and RM6237 Learning & Training Services DPS.
Why zero-hours contract compliance belongs on the board’s agenda
The reason this is a board matter, not just an HR or payroll matter, is that the duty is shared and the evidence is dated. A business that uses or supplies flexible labour may own only part of the record, but it can still be asked to answer for the whole engagement.
Public sector buyers feel this sharply. NHS trusts, councils, housing providers and multi-academy trusts often rely on agency, bank, casual and zero-hours labour to manage fluctuating demand. Where the hirer controls the work pattern, it cannot assume the agency’s contract file is enough. Where the agency manages the worker relationship, it cannot assume the hirer’s rota data tells the whole story.
The exposure appears when a guaranteed-hours offer is challenged, a shift cancellation payment is disputed, or a worker’s status is questioned. At that point, the organisation needs the record on the day, not after a manual rebuild across payroll, HR, procurement, timesheets and supplier emails.
The practical answer is not to make flexible labour impossible. It is to make the evidence current. Zero-hours contract compliance is, at heart, a matter of keeping the contract, the hours record and the working reality aligned across the agency and hirer.
The reforms split the duty across the agency and the hirer. The evidence has to be shared just as cleanly, or neither party can answer for it.
Compliance is your asset. Evidenced daily.
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“Own your compliance as an asset.”
Drawing on The Global Recruiter, published on 4 June 2026; the Department for Business and Trade consultation on reforms of zero hours and similar contracts; the Employment Rights Act 2025; Make UK’s Employment Rights Act spotlight on agency workers; Office for National Statistics data on zero-hours contracts; and the OPRaaS LSCA Self-Certification Course Module 9.
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This article is editorial commentary by OPRaaS Limited (On-Pay-Roll-as-a-Service), drawing on published industry reporting. It is general information, not legal, tax, employment or compliance advice. Obligations vary by organisation and engagement. Speak to a qualified professional before acting on any specific position.