What to expect

The Government has committed to extensive consultation over the coming months. In the short term (to the fourth quarter of 2026), in addition to the ongoing consultation about parental leave and pay, expect consultations on union right-to-inform statements, union access timelines and exclusions, and a Code of Practice on union access, with implementation targeted for October 2026.

In the medium term (to 2027), rules on enhanced dismissal protections for pregnant women and new mothers, and bereavement leave scope and duration. The continuing programme will cover: zero-hours workers calculation mechanics; reasonable notice thresholds and compensation bands; flexible working default mechanics; a fire-and-rehire Code of Practice; SSP calculation and records; Fair Work Agency powers and penalties; day-one and six-month probation framework; electronic balloting; modernised recognition and anti-unfair-practice frameworks; sectoral exemptions (seasonal, hospitality, retail, health and social care, agriculture); and enforcement penalty guidance.

The consultation timeline creates acute pressure for both government and employers. The Government must draft, consult upon, finalise, and lay dozens of statutory instruments across 2025 to 2027, whilst maintaining political momentum and stakeholder confidence. Employers must track multiple parallel consultations, assess impacts, submit representations, and prepare for implementation - all whilst managing existing operations. Multi-jurisdictional employers face additional complexity if devolved administrations adopt different commencement dates or regulatory approaches.

The sequencing risk is particularly acute. If zero-hours workers calculation mechanics are not finalised until the third quarter of 2026, but the primary legislation commences in October 2026, employers face a narrow window to build systems, train staff, and achieve compliance. Late changes to draft regulations may require costly system redesigns.

Finally, the length of time it took for the Government to pass an Act that it famously introduced within the first 100 days of coming into power does not bode well for the speed with which the measures will actually be implemented. Few could have predicted that it would take more than a year to reach this point, and fewer still would have thought that so little progress would have been made in relation to the supporting legislation that was inevitable with a framework Act such as this. The risk is that some of the key provisions of the Act will only come into force shortly before the next election. If Labour fail to win a second term, the incoming administration could repeal parts or all of the Act before it properly takes its first steps.