Research and analysis

RPC opinion: right to guaranteed hours

Published 14 August 2026

Lead department: Department for Business, Innovation, Science and Trade

Summary of proposal: to consult on secondary legislation implementing the statutory right to guaranteed hours for eligible workers, including agency workers. The options cover an hours threshold, regularity requirements, calculation of guaranteed hours offers, reference periods, exemptions and agency-worker arrangements.

Submission type: options assessment

Legislation type: secondary legislation

RPC reference: RPC-DBT-26155-OA(2)

Date of issue: 13 July 2026

RPC opinion rating

Fit for purpose:

• the options assessment (OA) provides a sufficient rationale for intervention, identifying one-sided flexibility, income insecurity and unpredictable hours as problems faced by some workers on zero hours and similar contracts
• it identifies a broad range of implementation options for consultation, including thresholds, regularity requirements, offer calculations, reference periods, exemptions and agency-worker arrangements
• the OA would be strengthened by clearer evidence on the scale of worker detriment, more measurable objectives, clearer explanation of how the main parameters interact, and evidence covering both workers who experience detriment and who value current flexible arrangements
• the impact assessment (IA) should provide a fuller comparative appraisal of the final package, reconcile shared costs across the wider zero-hours package, strengthen key assumptions, and set out the final small and micro business mitigation package
• the final IA’s scorecard should assess the wider economic impacts of the policy, including potential effects on employer flexibility, labour demand, productivity and growth

Final impact assessment submission required

Under the Better Regulation Framework (page 40) independent scrutiny of final impact assessments (IAs) is required for measures with very high anticipated impacts to assure ministers and Parliament of the robustness of the analysis for such large measures.

Specifically, final-stage RPC scrutiny is needed for any regulatory provision with an equivalent annual net direct cost to business (EANDCB) of ±£100 million or more and where at least one of the following conditions is met:

a) the RPC opinion of the scorecard elements of the options assessment (OA) received a weak or very weak rating

b) the RPC opinion of the monitoring and evaluation plans in the OA received a weak or very weak rating

c) the measure falls within an exclusion category (apart from the building safety exclusion) and has therefore not previously been subject to OA scrutiny

This OA covers a proposal with an EANDCB of ±£100 million or more and meets condition a). It will therefore require resubmission at final IA stage. This OA is still considered fit for purpose, and the department has provided sufficient quality evidence and analysis in the green-rated areas.

RPC opinion summary

Rationale: Green

The OA sets out a clear problem, supported by evidence on labour market imbalance, income insecurity, worker preferences and wellbeing impacts. The OA also recognises that some workers value flexibility. It would be strengthened by clearer evidence on the scale of worker detriment, more measurable and time-bound objectives, and clearer distinction between correlational and causal evidence, particularly on productivity.

Identification of options: Green

The OA identifies options for thresholds, regularity requirements, offer calculations, reference periods, exemptions and agency-worker arrangements. It would be strengthened by showing more clearly how options were tested against objectives or critical success factors, and how exemptions affect coverage, flexibility, costs and avoidance risk.

Justification for preferred way forward: Green

The OA does not name preferred options for most parameters as the department is consulting on detail of the proposal, but this is reasonable at OA stage. The IA should provide a full comparative appraisal of the selected package, including interactions with the reasonable-notice and short notice payment measures, and show which costs are genuinely incremental. The IA should provide more consideration of potential unintended consequences, particularly including effects on seasonal and temporary work, and on employment generally.

Regulatory scorecard: Weak

The scorecard does not provide a sufficiently balanced assessment of the potential growth and labour market impacts. The final IA should assess the wider economic impacts of the policy, including potential effects on employer flexibility, labour demand, productivity and growth. It would be strengthened by clearer explanation of how negative monetised impacts are weighed against unquantified worker benefits, fuller discussion of distributional and adverse household impacts, and clearer treatment of direct and indirect costs. The OA identifies potentially material non-monetised costs to businesses where demand is seasonal or unpredictable. The department should develop its assessment of the likely magnitude of these costs.

Monitoring and evaluation: Satisfactory

The OA provides a high-level monitoring and evaluation plan, including a post implementation review commitment, stakeholder engagement and survey options. It would be strengthened by identifying owners, timings, baselines, named data sources and metrics more precisely. The IA should develop this once the final package is selected.

Summary of proposal

The government is proposing a package of measures to tackle one-sided flexibility, ensure that all jobs provide a baseline of security and predictability, and end exploitative zero hours contracts.

The package consists of the following 3 measures, with the highlighted first measure being the subject of this OA:

• a right to guaranteed hours, where the number of hours offered reflects the hours worked by a qualifying worker during a reference period
• a right to reasonable notice of shifts
• a right to payment for shifts cancelled, curtailed, or moved at short notice

This OA’s proposal would implement the right to guaranteed hours created by the Employment Rights Act 2025. Employers would be required to make guaranteed hours offers to qualifying workers after a reference period, where the offer reflects the number of hours worked during that period. Workers would be able to accept or reject the offer. For qualifying agency workers, the end hirer would be responsible by default for making the offer, and acceptance would lead to the agency worker entering into a worker’s contract with the hirer.

The OA accompanies a consultation on detailed parameters to be set in secondary legislation. These include the hours threshold, regularity requirements, how guaranteed hours offers should be calculated, whether there should be an adjustment margin, the period over which guaranteed hours must be provided, the length and timing of initial and subsequent reference periods, exemptions and treatment of agency workers. The OA does not identify preferred options for most parameters, although it identifies a 12-week initial reference period and an hours threshold within the range of 8 to 20 hours per week as government preferences.

The OA estimates an indicative Equivalent Annual Net Direct Cost to Business of £100 million to £450 million and an indicative monetised Net Present Social Value range of -£2.3 billion to -£7.5 billion over a 10-year appraisal period. It does not monetise the main expected worker benefits from greater income security, predictability and wellbeing.

Rationale

Problem under consideration

The OA states that the problem under consideration is one-sided flexibility in employment relationships where employers can vary hours and scheduling while workers bear income and planning risks. It explains that workers on zero hours and similar variable hours contracts may face income volatility, unpredictability and difficulties planning work, caring responsibilities, finances and wider commitments.

The OA draws on evidence that some workers on zero hours contracts report that the arrangement does not suit their circumstances and that many workers with no guaranteed hours would prefer more hours in their contract. It also discusses evidence on underemployment, insecure hours, wellbeing, mental health and labour market attachment. This provides a reasonable qualitative and descriptive account of the problem.

The OA acknowledges that the evidence of the detriment caused by one-sided flexibility is strongest for those with no or few hours and the impacts are expected to be most pronounced for those with no or few hours, relative to workers with higher levels of guaranteed hours.

The OA would be strengthened by a clearer assessment of the scale of the problem the measure is intended to address. In particular, it should distinguish between the number of workers on zero hours or low guaranteed hours contracts, the subset who face detriment from lack of guaranteed hours, and the subset likely to accept a guaranteed hours offer.

The OA partially clarifies that workers with no guaranteed hours want more hours in their contract means formalising hours already worked or increasing total hours worked, using newly available DBT survey evidence that 58% of respondents in insecure work would prefer guaranteed hours that match their usual working patterns. The IA should build on this and explain how directly this evidence supports expected take-up of guaranteed hours offers.

The IA should include evidence covering workers with different preferences for flexibility to support more precise problem diagnosis. The OA recognises that zero hours contracts can provide flexibility for some workers and that workers may decline a guaranteed hours offer. The IA should therefore provide evidence on both the scale of detriment from one-sided flexibility and the scale of valued flexibility among workers who use zero hours or variable-hours contracts to supplement income, manage caring or study commitments, or combine work with other roles. Where possible, this should include quantified evidence on the number and characteristics of affected workers, alongside structured qualitative evidence on why different groups value or experience detriment from current arrangements.

Argument for intervention

The OA identifies several rationales for intervention, including employer market power, negative externalities and moral hazard. It argues that some employers can transfer demand risk to workers, while workers may have limited bargaining power or limited ability to move to alternative employment. It also argues that the social costs of insecure hours, including possible health, wellbeing and welfare impacts, are not fully reflected in employer-worker decisions.

This provides a reasonable case for intervention, and the OA acknowledges that this case varies with the number of guaranteed hours workers have prior to intervention. The OA also explains why a request-based model may be less effective than an employer obligation, because a request-based approach would place the burden on workers and could be refused by employers.

The OA would be strengthened by explaining more clearly the conditions under which employers are able to transfer risk to workers without losing staff, including how this varies by sector, local labour market conditions, worker bargaining power, firm size and the availability of alternative employment. This would help demonstrate where employer market power is likely to be material and where the case for intervention rests more on equity or distributional considerations.

The OA would be strengthened by setting out more directly how the detailed policy parameters address the identified market failure while avoiding disproportionate impacts on employers and on workers who value flexibility. The OA should also explain more clearly what is additional to this measure, relative to the reasonable notice and short-notice cancellation-payment reforms.

The OA would be strengthened by distinguishing more clearly between evidence of association and evidence of causation, particularly where it links insecure work, wellbeing and productivity. It should avoid implying that productivity gains from the right to guaranteed hours are established unless the evidence supports that causal link. Where the evidence is correlational, the OA should present this transparently and explain the strength of the evidence underpinning each claimed impact.

The OA would also be strengthened by explaining why employers do not already adopt more secure contractual arrangements where these would improve productivity or retention. Where variable hours arrangements persist because their operational flexibility benefits outweigh productivity losses for employers, the OA should present expected productivity gains as uncertain and secondary to the main worker-security rationale.

The OA would be strengthened by fuller use of international evidence where available, including evidence on the design and effects of comparable restrictions on zero hours or variable-hours contracts. The IA should revisit this evidence where it is relevant to the selected hours threshold, regularity requirements and reference period design.

Objectives and theory of change

The OA sets out broad objectives to establish a baseline of security and stability, including improving employment and financial security; rebalance labour market flexibility, including promoting genuine two-sided flexibility; and support sustained economic growth with the measures targeted towards workers lacking security and predictability. It also identifies objectives to increase the proportion of workers whose contracts accurately reflect their working hours and increase workers’ ability to choose whether to work on a zero hours contract.

These objectives are relevant to the problem, but they should be made more specific, measurable and time-bound. The OA should define the baseline, expected direction of change and timeframe for key outcomes more clearly. Where it is difficult to specify final outcomes at this stage, the OA could include input- or output-based indicators. These could include the number or proportion of workers receiving guaranteed hours offers, the acceptance rate of offers, the number of workers moving onto contracts that better reflect their regular hours, and the proportion of employers brought into compliance over and above those already voluntarily compliant.

The OA includes a theory of change covering inputs, activities, outputs, outcomes and impacts. This provides a useful structure, but should identify key risks, including higher unemployment that are downstream of the potential reduction of flexibility for employers. The OA would be strengthened by developing this into a fuller theory of change, setting out the assumptions and supporting evidence for each causal step, identifying which links are well evidenced and which are more uncertain, and making the intended outputs, outcomes and impacts, and risks assessable for monitoring and evaluation.

Identification of options

Identification of the ‘longlist’ of options

The OA explains that the Employment Rights Act 2025 has already established the broad regulatory framework and that the remaining policy choices concern how secondary legislation should implement the right. It therefore longlists options for the hours threshold, regularity requirements, calculation of guaranteed hours offers, adjustment margins, reference periods and enforcement. The OA also refers to the potential for some limited circumstance-based exemptions and agency-worker arrangements for the guaranteed hours threshold, with both decided after consultation.

The OA considers a broad range of implementation choices. For the hours threshold, it carries forward options of 8 to 48 hours per week in 4-hour increments and “other”, while stating the government’s preference for within 8 to 20 hours. For regularity, it considers a weekly distribution test and a possible additional test based on hours worked above contracted hours. For the initial and subsequent reference periods, it considers 12, 26 and 52 weeks and “other”, with 12-weeks the preference for the initial reference period. This provides a reasonable basis for consultation.

The OA would be strengthened by presenting more systematically how the main parameters interact. The IA should then show how the final choices have been assessed against the objectives and critical success factors.

Consideration of alternatives to regulation

The OA states that non-regulatory options were considered earlier in policy development and discarded in favour of legislation in the Employment Rights Act 2025. It explains that this OA is concerned with implementation of that legislation and that non-regulatory options would not achieve the intended outcomes. This is reasonable at this stage. The OA would be improved by briefly summarising the non regulatory or less regulatory alternatives previously considered and the explanations for why these alternatives would not sufficiently address the identified problem.

The OA would be strengthened by fuller use of international evidence where available, including evidence on the design and effects of comparable restrictions on zero hours or variable hours contracts. Evidence on the effects of regulatory interventions relative to non-regulatory alternatives would be a beneficial component of this. The IA should revisit this evidence where it is relevant to the selected hours threshold, regularity requirements and reference-period design.

Justification for the shortlisted options

The OA explains why several options were discarded, including limiting scope only to zero hours contracts, having no regularity requirements, reference periods below 12 weeks, and calculating guaranteed hours only from weeks in which work was provided. These explanations are generally reasonable.

The OA would, however, be strengthened by a more structured longlist-to-shortlist assessment. It should show how the shortlisted options perform against the objectives and critical success factors, including targeting workers facing one-sided flexibility, preserving valued flexibility, administrative simplicity, legal clarity, avoidance risks, impacts on small and micro businesses, and agency-worker impacts.

The OA should explain how temporary need, exemptions and exclusions have been considered as part of the options appraisal, rather than only as consultation questions. It should set out how these design choices affect worker coverage, employer flexibility, administrative burden, avoidance risk and expected costs and benefits.

The OA would also be strengthened by explaining more clearly how the shortlisted combinations of hours threshold, regularity requirements and reference-period design form proportionate packages. In particular, it should assess the combined effect of parameter choices on worker coverage, employer flexibility, administrative burden and avoidance risk.

Small and micro business assessment and medium-sized business assessment

The OA includes an assessment of small and micro business impacts. It states that small and micro businesses are likely to be disproportionately affected because they may lack dedicated HR capacity, may rely more on variable hours contracts, and may have weaker financial resilience. The OA also provides evidence on the number of affected employee jobs by business size and the prevalence of variable hours contracts among employers.

The department explains why exempting small and micro businesses would significantly undermine the objectives. It notes that a significant proportion of workers within the hours thresholds work in small and micro businesses, and that an exemption could create a two-tier labour market, distort competition, encourage avoidance through subcontracting and create a disincentive for smaller firms to grow.

This is a reasonable explanation for not applying an exemption. However, the OA would be strengthened by a clearer provisional estimate of the share of total business costs expected to fall on small and micro businesses and the policy benefits, or affected workers, that would be lost under a full exemption.

The OA identifies mitigations including consultation, early engagement, familiarisation time, guidance and clear communication ahead of commencement. These are useful but high level. The IA should set out the final mitigation package for small and micro businesses and explain why any residual disproportionate burden is justified by the policy objectives.

The OA would also be improved by distinguishing more clearly between small and micro businesses and medium-sized businesses, and by explaining whether medium-sized businesses face similar or different proportional impacts and mitigation needs.

Justification for preferred way forward

Appraisal of the shortlisted options

The OA does not identify a single preferred option for most parameters because the department is consulting. It provides a range-based assessment of impacts across the options being considered. This is appropriate at OA stage, given that secondary legislation will determine the final scope and operation of the right.

The OA estimates an indicative EANDCB range of £100 million to £450 million. It estimates an indicative monetised NPSV range of -£2.3 billion to -£7.5 billion. The main quantified costs are familiarisation, implementation, tracking hours, formalising guaranteed hours offers and workforce planning.

The department provides an assumptions log, including robustness and sensitivity ratings, accompanied by rating explanations and potential risks. These are helpful and have been improved in the OA. The OA would be strengthened by clearer evidence for assumptions with high sensitivity, including the number of workers in scope, the number of employers affected, regularity eligibility, offer acceptance rates, attrition and workforce-planning costs. The IA should explain how consultation evidence and commissioned research have been used to refine the key assumptions and reduce uncertainty.

The OA defines the counterfactual as the status quo in which there is no right to guaranteed hours. It also assumes that the related rights to reasonable notice of shifts and payment for short-notice cancellation, curtailment or movement of shifts are not implemented under the do-nothing scenario. This baseline is clear for assessing this measure in isolation. However, the OA also notes that some costs, including system, tracking and workforce-planning costs, overlap with the related zero-hours reforms and may be subject to double counting. The IA should reconcile these shared costs across the wider package and show which costs are genuinely incremental to the right to guaranteed hours.

The OA would be improved by explaining, at least qualitatively, how estimated impacts might change if the related reasonable-notice and short-notice cancellation payment measures are assumed to be in place. This should include whether those measures would reduce the number of workers in scope, reduce or increase employer behaviour change, or alter the marginal benefits of guaranteed hours. The IA should quantify or otherwise assess these interactions once the final package is selected.

The OA draws on Annual Survey of Hours and Earnings (ASHE), Labour Force Survey, Chartered Institute of Personnel and Development, Living Wage Foundation, Resolution Foundation, Recruitment and Employment Confederation, DBT’s Agency Worker Survey and academic evidence. It explains why ASHE is used as an employer-reported proxy for basic hours, while recognising that basic hours are not necessarily guaranteed hours.

The OA is transparent about important evidence limitations, including the absence of a single robust data source on guaranteed hours, the difficulty of isolating agency-worker contractual hours, and reliance on proxies for several assumptions. The OA should explain the generalisability of the evidence used to support the 12-week initial reference period, including the sector and workforce model of the employer studied, the extent to which it uses zero hours or low guaranteed hours contracts, and how representative it is of sectors most affected by the policy. The IA should explain how consultation evidence has been used to refine the key assumptions and reduce uncertainty.

The OA explains that the principal non-monetised benefits are expected to fall to workers through greater income security, predictability, reduced stress and improved ability to plan work and personal commitments. Because these benefits are central to the case for intervention and the monetised NPSV is negative, the OA would be strengthened by a more structured assessment of their likely scale and uncertainty. The IA should monetise worker benefits where proportionate, including wellbeing, mental health, job security and job quality impacts where suitable values or precedents are available. Where robust monetisation is not feasible, the IA should include break-even or scenario analysis showing the average worker benefit required for the policy to be net positive.

The IA should distinguish clearly between impacts that can be monetised, impacts that can be quantified but not monetised, and impacts that can only be assessed qualitatively. Where benefits or risks remain qualitative, the IA should explain the evidence supporting the judgement and distinguish between structured qualitative evidence and more descriptive or uncertain claims.

The OA would be strengthened by a fuller appraisal of distributional impacts by sector and business model. This should go beyond business size and include sectors and business models where demand is volatile, current use of variable hours contracts is high, timeliness is important and margins are tight. It should also explain, where possible, where employers are already voluntarily providing more secure contractual arrangements and where current practice is furthest from the intended regime.

Selection of the preferred option

The OA does not select preferred options for most parameters because the department is consulting on detail of the proposal. It explains that stakeholder evidence, commissioned research and consultation responses will inform the final IA. This is reasonable at OA stage, given that the key choices concern marginal trade offs between different secondary-legislation parameters.

The IA should provide a full comparative appraisal of the selected parameters against the alternatives. It should explain the trade-offs between worker security and employer flexibility, including why the selected hours threshold, regularity requirements, calculation method and reference-period design are proportionate. The IA should also test how the selected parameters affect employer flexibility, labour demand, employment composition and productivity, and be explicit about the expected impact on growth.

The IA should show how the selected package has been tested against objectives and critical success factors. It should explain how the package balances the aim of targeting workers facing one-sided flexibility with the need to preserve valued flexibility, maintain administrative simplicity, reduce avoidance risk and limit disproportionate burdens on employers.

The IA should explain how the selected package applies to seasonal peaks and temporary demand, including Christmas, summer and other predictable busy periods. It should assess whether employers may reduce overtime, change the timing of overtime, use limited-term contracts, or avoid offering additional hours if those hours could affect future guaranteed hours obligations.

Where the regulations allow discretion over the duration or form of guaranteed hours commitments, the IA should explain how this affects employer risk, worker security and proportionality, including whether varied commitment lengths could mitigate impacts in sectors with seasonal or temporary demand. The department should use the consultation to gather evidence on any unintended consequences.

The final IA should monetise these impacts where proportionate, provide quantified but not monetised evidence where monetisation is not feasible, and present qualitative evidence in a structured way where impacts cannot be quantified, so that these issues can be fully accounted for in selecting a preferred option.

The IA should also assess how agency-worker and hirer arrangements affect incentives, including whether the measure could create avoidance or substitution risks between directly engaged workers, agency workers, fixed-term contracts and subcontracting.

Regulatory scorecard

Part A

The scorecard is weak because the OA does not provide a sufficiently balanced assessment of the potential growth and labour market impacts. The quantified costs capture only administration and planning burdens, while leaving the substantive economic cost of reduced scheduling and workforce flexibility largely unassessed. The final IA should assess how the selected parameters may affect employer flexibility, labour demand, employment composition, productivity and wider growth. It should distinguish administrative burdens from substantive compliance costs and set out how the evidence base has tested these risks.

The final IA should also set out how the costs of the measure have been classified for the purposes of the 25% administrative cost target, including which costs are administrative burdens and which are substantive compliance costs.

Total impacts including non-monetised and distributional impacts

The scorecard describes the overall impact on total welfare as uncertain because the measure transfers risk from workers on variable-hours contracts to employers. It reports an indicative NPSV range of -£2.3 billion to -£7.5 billion for scenarios based on the government’s identified preferences, driven by monetised business administration and workforce-planning costs, while worker benefits remain unquantified. The OA notes that some of the estimates underpinning this are subject to uncertain assumptions and that the department will strengthen the evidence base through the consultation.

This is a reasonable summary, however the OA would be strengthened by explaining more clearly how the department has weighed the negative monetised impacts against the unquantified worker benefits, and how robust the overall welfare judgement is. The OA would also be strengthened by a clearer account of the scale of benefits. The IA should revisit this once the final package is selected, including through partial monetisation, break-even or scenario analysis where full monetisation is not feasible.

The OA identifies the potential loss of flexibility as a non-monetised impact on employers who rely on in-scope contract types due to seasonal or unpredictable demand. The department should assess the likely magnitude of this impact and explain how it varies with the selected parameters.

The OA would also be strengthened by going beyond business size and providing a fuller distributional assessment by sector and business model. This should include sectors and business models where demand is volatile, current use of variable hours contracts is high, timeliness is important and margins are tight. It should also explain, where possible, where employers are already voluntarily providing more secure contractual arrangements and where current practice is furthest from the intended regime.

Impacts on business, including non-monetised and distributional impacts

The scorecard describes business impacts as negative overall. It reports an EANDCB range of £100 million to £450 million for scenarios based on the government’s identified preferences, including one-off familiarisation and implementation costs and ongoing costs associated with tracking hours and making guaranteed hours offers. It also identifies workforce-planning costs, which the OA treats separately from direct compliance costs.

The scorecard identifies particular sectors that are more likely to be significantly impacted, due to their more common use of contracts within the government’s preferred threshold range of 8 to 20 hours or variable product demand.

The OA should set out more clearly which impacts are direct and indirect, and why. It should also explain the extent to which costs may be passed through to workers, consumers or other firms, and how impacts differ by sector, business size and use of agency workers.

Impacts on households, individuals or consumers, including non-monetised and distributional impacts

The scorecard describes household impacts as positive because workers are expected to benefit from improved security and predictability.

The OA would be strengthened by a more balanced assessment of overall household impacts, including how these may vary between workers. The final IA should assess potential benefits for workers who use highly flexible arrangements to supplement income, manage caring or study commitments, combine work with other roles, gain entry-level experience or access work that might otherwise not be available.

It should also assess potential adverse indirect impacts, including reduced overtime, fewer opportunities for seasonal or casual work, reduced hiring of workers weakly attached to the labour market, or changes in contract models that reduce flexibility valued by some workers.

The scorecard notes that affected workers are more likely to be low paid, young, female and disabled, and so could benefit disproportionately from the wellbeing impacts of the proposals. It also notes potential downside risks to labour demand, affecting employment and hours offered to workers under the hours threshold, though these are only mentioned in the distributional impacts section and should be assessed in more detail.

Part B

Business environment

The OA assesses the business environment impact as potentially working against ease of doing business because the measure may reduce employer flexibility and increase labour costs, particularly in sectors with variable demand. It also recognises potential offsetting benefits, including fairer competition for employers already providing secure work and possible productivity gains from better workforce planning.

The OA would be strengthened by a more proposal-specific assessment of possible impacts on competition, innovation and market structure. This should include whether the measure may affect entry and expansion for smaller firms, incentives to substitute towards other labour models or automation, or market concentration in sectors with volatile demand.

The final IA should provide an assessment of the measure’s growth impacts, rather than relying on general productivity arguments, and explain productivity effects, reduced flexibility, labour demand and changes in employment composition.

Trade and investment

The OA assesses international considerations as neutral, noting that the affected sectors are largely non-traded and that the impact on export and import competitiveness is expected to be negligible. This is a reasonable initial assessment.

Natural capital and decarbonisation

The OA states that the measure is not expected to have environmental impacts. This provides sufficient justification for a neutral rating on natural capital and decarbonisation.

Monitoring and evaluation

The OA commits to a post-implementation review within 5 years of the secondary legislation coming into effect. It identifies accountability, learning and informing policy decisions as the purposes of monitoring and evaluation.

The OA provides a reasonable high-level monitoring and evaluation plan. It would be strengthened by identifying baselines, named datasets, reporting cadence, governance, owners and decision points more precisely. The IA should develop this into a fuller monitoring and evaluation plan once the final package is selected.

The IA should structure the evaluation framework around the Magenta Book’s process, impact and value-for-money evaluation strands, set out a credible approach to causal attribution, and commit to an early interim assessment of administrative and familiarisation costs to test delivery assumptions and inform progress against wider regulatory burden reduction objectives.

The plan should explain how the department will test key assumptions in the appraisal, including the number of workers in scope, eligibility under regularity requirements, offer acceptance rates, employer behavioural responses, agency worker impacts, impacts on small and micro businesses and employment tribunal demand. The IA should also explain how the enforcement route is expected to work for the workers targeted by the measure, including whether tribunal capacity, access to redress or delays could affect take-up, compliance and realised benefits.

Data collection

The OA identifies potential evidence sources and approaches, including regular stakeholder engagement, surveys of individuals and employers, possible focus groups, ONS data on zero hours and temporary contracts, ASHE and relevant think tank or business surveys. This is a useful starting point.

The OA would be strengthened by setting out an initial set of monitoring indicators and data sources linked to the objectives and theory of change. These could include the number or proportion of workers receiving guaranteed hours offers, offer acceptance rates, changes in the prevalence of zero hours and low guaranteed hours contracts, changes in worker-reported predictability and income security, and changes in employer use of overtime, agency workers, fixed-term contracts or subcontracting.

Post-implementation review

The post implementation review (PIR) should assess whether the measure remains necessary and proportionate, whether the objectives have been met, whether actual impacts were in line with those estimated in the OA, and whether the regulation should be retained, amended or removed.

The OA would be strengthened by setting out the expected timing, scope, ownership and key review questions for the PIR. It should also identify whether there are triggers for earlier review, for example if evidence suggests significant unintended consequences, material impacts on small and micro businesses, or substantial changes in employer behaviour.