Employment Rights Act 2025: The Dates UK Recruitment Agencies Need in the Diary

The Employment Rights Act 2025 is the biggest change to UK employment law in a generation, and most of the commentary is written for employers. Recruitment agencies sit in a different position: several of the new rules apply to the workers you supply, some fall on you directly, and the timing is staggered across 2026 and 2027. This is the agency-specific diary, based on the government's Employment Rights Act implementation timeline.

Already in Force: April 2026

The Fair Work Agency launched on 6 April 2026 as the single enforcement body for labour-market law, taking over the work of the Employment Agency Standards Inspectorate among others. For agencies that means one regulator with a wider remit and, according to its own remit, more appetite for enforcement. Statutory Sick Pay expanded on the same date to cover lower earners from day one, which affects the cost base of every temp assignment.

October 2026: Union Access and Harassment Duties

From October 2026 the duty to inform workers of their right to join a trade union takes effect, alongside expanded union access rights and a stronger duty on employers to prevent sexual harassment, including by third parties. For agencies, the practical questions are who issues the written statement to a temp, and how an agency evidences that it took reasonable steps to protect a worker on a client site. Both need a documented process before October, not after the first complaint.

2027: Zero-Hours Rules Extend to Agency Workers

This is the one that reshapes temp desks. Following consultation, the guaranteed-hours, reasonable-notice and shift-cancellation provisions will apply to agency workers, with the government roadmap pointing to 2027. The consultation confirmed the split: the end hirer offers guaranteed hours based on a reference period, both agency and hirer are responsible for reasonable notice of shifts, and cancellation or curtailment payments fall to the agency, recoverable from the hirer only if the contract says so.

Every temp contract you hold with a client will need revisiting before this lands. Agencies that do not renegotiate recovery terms will be paying cancellation compensation out of margin.

Where the Admin Load Lands

• Written statements and union-rights notices for every new temp.
• Reference-period tracking per worker for guaranteed-hours offers.
• Shift-notice logs and cancellation records, with recovery invoicing to clients.
• Harassment-prevention evidence per client site.

All of this is process work that has to be done accurately, at volume, every week. It sits naturally with administrative support or a dedicated recruitment virtual assistant, and it overlaps with the umbrella-company checks we cover in our guide to joint and several liability. The same team can own both files.

High-volume temp markets such as Manchester and Leeds, where the REC data shows the strongest temp growth, will feel the 2027 change first. Use 2026 to build the records; the agencies that wait for the commencement order will be rebuilding their contracts under time pressure.