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Particular attention should be given to workers whose pay sits close to the relevant minimum wage, especially where they participate in salary sacrifice schemes or have deductions taken from pay.

Payroll teams should check that:

Working-time data is complete and reaches payroll on time
Deductions and benefits are assessed correctly
Records can be produced promptly during an inspection
Historic errors are investigated and corrected early

The Fair Work Agency’s enforcement statement doesn’t rewrite the rules in these areas. It does, however, show how they’ll be enforced through a single agency with extensive powers.

The safest approach is to identify and correct issues before the agency does.

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FWA enforcement update

What does the Fair Work Agency (FWA) cover?

The FWA’s current remit includes:

National Minimum Wage and National Living Wage enforcement
Employment agency and employment business standards
Gangmaster licensing in regulated sectors
Serious labour abuse and exploitation
Financial penalties for unpaid Employment Tribunal awards and Acas settlements
Future remits include holiday pay and statutory payments

The Secretary of State can expand this remit through future regulations. Holiday pay is absent from the current enforcement

statement, but employers shouldn’t take that as a reason to move it down the compliance agenda.

Minimum wage remains a major focus

National Minimum Wage and National Living Wage compliance will sit at the heart of the agency’s work.

HMRC officers will continue to carry out minimum wage enforcement, but they're expected to become Fair Work Agency enforcement officers from 2027 onwards.

Almost all workers are covered, including hourly paid employees, salaried workers, agency workers and many casual or piece-rate workers.

Where someone has been underpaid, the employer must repay the arrears. If the minimum wage has increased since the

The Fair Work Agency has been in operation since April 2026, bringing several existing labour market enforcement functions together under one body.

Its enforcement policy statement explains the rights it oversees, how investigations will work and what can happen when businesses fall short.

Many of the underlying rules will already be familiar for payroll teams. The difference is that enforcement is now more coordinated, with one agency able to draw on a broad range of investigatory and enforcement powers.

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underpayment occurred, the amount owed may need to be recalculated using the current rate.

Compliance also goes further than checking the hourly rate entered into payroll. Employers need to consider:

All working time that should be paid
Deductions for uniforms, tools or training
Salary sacrifice arrangements
Accommodation charges and offsets
Whether workers are in the correct category
Whether payroll and time records support the amounts paid

An employer can still be non-compliant where an underpayment was accidental,

or the contractual rate appeared to be above minimum wage.

How will the agency investigate and enforce?

Potential non-compliance may be identified through worker complaints, referrals from public bodies, shared intelligence or the agency’s own risk-based analysis.

Enforcement officers can require payroll records, contracts, working-time information and other documents.

They can also interview workers and business representatives or visit business premises, including through unannounced inspections where necessary.

Employers must cooperate with reasonable requests. Providing false documents or intentionally obstructing an officer can be a criminal offence.

Where non-compliance is found, the agency’s options include:

Advice or guidance
Warning letters
Notices of Underpayment
Civil penalties and public naming
Labour market enforcement undertakings
Licensing action
Civil proceedings
Criminal investigation or prosecution

Where minimum wage arrears remain outstanding at the start of an investigation, the agency will generally issue a Notice of Underpayment. This may still happen where the mistake was accidental or the workers are repaid after the investigation begins.

In some circumstances, employers that identify and correct an error before an investigation starts may avoid a formal notice. However, this remains at the enforcement officer’s discretion.

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What are the financial consequences?

A minimum wage penalty is normally calculated at 200% of the total underpayment.

The minimum penalty is £100 and the maximum is £20,000 for each affected worker. It can be reduced by 50% when the unpaid wages and reduced penalty are paid in full within 14 days.

This is separate from the requirement to repay workers. Employers may also be publicly named, adding reputational damage to the financial cost.

The agency can also act where an employer fails to pay an Employment Tribunal award or Acas settlement. Following an application from the person owed money, it can impose a penalty equal to 50% of the unpaid amount, subject to a minimum of £100 and maximum of £5,000. This must be paid in addition to the original sum owed.

What does Annex B mean for salary sacrifice?

Annex B deals with certain minimum wage underpayments caused by salary sacrifice arrangements, savings schemes or deductions for goods and services.

It doesn’t change the rule that these arrangements can reduce a worker’s pay for minimum wage purposes.

Instead, it sets out limited circumstances in which an employer may avoid a financial penalty and public naming. Broadly, this may apply where:

The arrangement was the only cause of the underpayment
The worker agreed to it
The worker received the relevant benefit, goods, services or savings

The deduction wasn’t for employment-related expenses or accommodation
The employer doesn’t have a history of serious or repeated non-compliance

Even where these conditions are met, the minimum wage arrears must still be repaid. The direction only affects the penalty and naming consequences.

This distinction shouldn’t be ignored. A salary sacrifice arrangement will benefit the worker and still create a technical minimum wage underpayment.

What should employers do now?

Employers should review minimum wage compliance across the full payroll process rather than relying solely on contractual salaries or hourly rates.

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ROI Week 53 PAYE reviews

When does Week 53 apply?

Week 53 can arise when the payroll calendar creates an additional pay period during the year. It most commonly affects weekly payrolls, although equivalent situations can occur with Week 54 or Fortnight 27.

The additional period can affect how an employee’s tax credits and rate bands are allocated.

Revenue may then review the employee’s PAYE position at the end of the year to identify any overpayment or underpayment of tax.

What has changed?

Revenue has updated the examples in Tax and Duty Manual Part 42-04-07 so they reflect the tax credits and standard rate cut-off points that applied in 2025.

For employers and payroll teams, the key points are:

Updated examples: The calculations used in Revenue’s guidance now reflect the relevant 2025 tax values.
Week 53 treatment remains the same: The update doesn’t introduce a new calculation method or change how additional pay periods should be processed.
Year-end reviews remain important: PAYE reviews can identify any tax differences arising from the way credits and rate bands were applied during the additional period.

Revenue has updated its guidance on PAYE reviews where an additional payroll period, commonly known as Week 53, falls within the tax year.

Revenue eBrief No. 100/26 confirms that the examples in the relevant Tax and Duty Manual have been refreshed using the 2025 tax credits and standard rate cut-off points.

The update doesn’t change the underlying PAYE rules. However, it provides payroll teams with current examples to support accurate calculations and year-end reviews.

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What should employers check?

Most employers won’t need to change their payroll processes or systems as a result of this update.

However, payroll teams should make sure that:

Payroll software can identify and process additional pay periods correctly.
The correct tax credits and rate bands are being used for the relevant tax year.
Internal guidance and training materials don’t rely on outdated Revenue examples.
Any differences identified through an end-of-year PAYE review are handled correctly.

The update will be particularly relevant to payroll software, technical and compliance teams responsible for keeping calculation logic aligned with Revenue guidance.

What does this mean for payroll?

The Revenue eBrief is primarily a technical update rather than a change to PAYE policy.

It provides payroll professionals with clearer, up-to-date examples when reviewing employees affected by Week 53 or another additional pay period.

Employers should use it as an opportunity to confirm that their systems, calculations and internal materials remain current.

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ROI pension contribution standards

What are the minimum contribution standards?

The standards are intended to make sure employees covered by an existing pension scheme receive contributions that are at least comparable with the introductory MyFutureFund rates.

For defined contribution schemes and PRSAs, the following minimums apply:

Employer contribution: At least 1.5% of the employee’s Revenue gross pay, capped at €1,200 per year
Total contribution: At least 3.5% of Revenue gross pay, capped at €2,800 per year

The employer must contribute at least 1.5%, or up to €1,200. The remaining contribution needed to reach the 3.5% total can be paid by the employee, the employer or shared between them.

For example, an employer could contribute 1.5% and the employee 2%. Alternatively, the employer could fund more than the minimum amount.

For a defined benefit scheme to qualify, the employee must be accruing a long-service benefit based on continued employment. Further standards may be introduced as MyFutureFund’s own contribution rates increase.

Does pension membership still provide an exemption?

An employee won’t be enrolled in MyFutureFund for an employment where qualifying pension contributions are already being made through payroll.

However, the pension arrangement must now meet the minimum standards. Membership of a workplace pension scheme alone doesn’t necessarily provide an exemption.

Ireland’s new auto-enrolment retirement savings scheme, MyFutureFund, came into effect on 1 January 2026.

Alongside its introduction, new minimum contribution standards were established for existing workplace pension schemes. These standards determine whether an employment can remain exempt from auto-enrolment.

This means that simply having an occupational pension or Personal Retirement Savings Account (PRSA) in place may no longer be enough. Employers need to check whether contributions to their existing schemes meet the required level.

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Where the relevant contributions fall below the required level, the employment may no longer be treated as exempt. This could result in the employee being enrolled into MyFutureFund while already participating in the employer’s existing scheme.

Employers should therefore review each scheme and the contributions made for individual employees, rather than assuming the whole workforce is automatically excluded.

How will NAERSA check compliance?

MyFutureFund is administered by the National Automatic Enrolment Retirement Savings Authority, known as NAERSA.

NAERSA uses information reported through payroll to determine whether employees have existing pension coverage and whether the required contribution standards are being met.

The first three months of 2026 provide an initial reference period for assessing contributions.

Using a period of several months allows NAERSA to account for fluctuations in pay, including overtime, bonuses and seasonal working patterns.

Where its data indicates that the standard may not have been met, NAERSA may contact the employer and ask it to review the contributions made for its pension members.

If the employer identifies the issue and makes the necessary correction, NAERSA should be able to see this through subsequent payroll submissions.

Where no corrective action is taken, NAERSA may issue an Automatic Enrolment Payroll Notification, or AEPN, instructing the employer to enrol the affected employee into MyFutureFund.

Revenue gross pay could create a compliance gap

One of the most important points for employers is the definition of pay used to assess contributions.

Many company pension schemes calculate contributions using pensionable pay. Depending on the scheme rules, this may be limited to basic pay and exclude additional earnings such as overtime, bonuses, shares or benefits in kind.

NAERSA’s assessment is based on the gross pay information reported to Revenue through payroll.

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This can include:

Notional pay
Share-based remuneration
Variable earnings such as overtime or bonuses
Pay before pension contributions or salary sacrifice deductions

Anything included in the gross pay field of the payroll submission may be taken into account.

As a result, an employer may believe that it meets the standard when contributions are measured against pensionable pay, while NAERSA identifies a shortfall when the same contributions are compared with Revenue gross pay.

This risk is particularly relevant for employees whose basic salary makes up only part of their overall earnings.

What should employers do now?

Employers should review contributions to their existing pension schemes using Revenue gross pay rather than relying only on the pensionable pay definition contained in the scheme rules.

They should check:

Whether employer contributions reach the 1.5% minimum
Whether combined contributions reach 3.5%
Whether variable and non-cash pay creates a contribution shortfall

Whether contribution levels remain compliant across different pay periods
Whether corrections are reflected accurately through payroll

Where a scheme falls short, employers may need to increase contribution rates or consider widening the definition of pensionable pay.

Changes of this kind may affect employment contracts or the scheme’s governing rules, so employers should involve their pension provider and seek appropriate advice before making amendments.

With NAERSA now using live payroll information to assess pension coverage, employers need to make sure the contributions reported through payroll support the exemption they expect to apply.

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Previously, some of these benefits were only exempt when the employer provided them directly. In other cases, employers had to use voucher schemes or risk the reimbursement being treated as taxable.

The April changes are designed to align the tax treatment, so that reimbursing the employee can be treated in the same way as arranging the benefit directly.

What does this mean for employers?

Where an employee buys a qualifying item, the employer can reimburse the cost without creating an Income Tax or National Insurance charge, as long as the conditions are met.

The same tax treatment applies whether the employer:

Pays the provider directly
Issues a voucher
Reimburses the employee

HMRC says the exemption applies automatically where the legislative conditions are met. Employers do not need to submit claims, seek approval or change their payroll or reporting processes.

What should employers check?

Employers should review how they handle homeworking costs and reimbursed workplace benefits, particularly where hybrid or home-based workers buy items themselves and claim the cost back.

It’s worth checking:

Which expenses employees are allowed to claim
Whether those expenses meet HMRC’s qualifying conditions
How reimbursements are recorded

Whether expenses before and after 6 April 2026 are being treated correctly
Whether managers and employees understand the difference between employee tax relief claims and employer reimbursements

HMRC says eye tests or flu vaccinations provided or reimbursed before 6 April 2026 should be treated under the previous rules. From 6 April 2026, qualifying costs can be reimbursed without PAYE or National Insurance being operated, provided the expenditure meets the relevant conditions.

For employers, the main takeaway is that employee claims for non-reimbursed homeworking expenses have been removed, but employer reimbursements remain possible where the costs qualify. 2026 should be treated under the previous rules.

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Homeworking expense changes

What's changed?

Employees can no longer make a claim directly to HMRC for additional household costs they incur because they’re required to work from home.

Previously, eligible employees could claim based on actual expenditure, with evidence, or at a flat rate of £6 per week without receipts.

However, this doesn’t stop employers reimbursing eligible homeworking costs tax and NIC-free.

HMRC has confirmed that the existing rules allowing employers to reimburse qualifying homeworking costs without deducting Income Tax or National Insurance contributions still apply.

What else changed?

Since 6 April 2026, new Income Tax and National Insurance exemptions also apply where employers reimburse employees for certain work-related costs.

This covers reimbursement for:

Eye tests required for Display Screen Equipment users
Glasses required specifically for Visual Display Unit use
Seasonal flu vaccinations
Certain items used in employment duties, including equipment employees need to work effectively from home

Since 6 April 2026, employees can no longer claim Income Tax relief from HMRC for non-reimbursed homeworking expenses.

That means employees can no longer make a claim directly to HMRC for additional household costs they incur because they’re required to work from home, such as increased utility costs or business telephone calls.

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6. Review your P11D process

With phase 2 benefits still sitting outside mandatory payrolling (for now), many employers will need to run parallel reporting processes.

Now is a good time to review:

How P11Ds will be managed
Where processes can be simplified
Whether systems are fit for a dual approach

The key thing to remember

While the phased rollout reduces immediate pressure, this is still a significant shift in how benefits are reported and taxed.

Employers who start preparing now, rather than waiting for final guidance, will be in a much stronger position to manage the transition smoothly.

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Mandatory payrolling of benefits update

What's changed?

Mandatory real-time reporting of benefits, including Income Tax and Class 1A National Insurance will be introduced as follows:

Phase 1 (from 6 April 2027):
Company cars, car fuel, vans, van fuel and employer-provided medical benefits
Phase 2 (from 6 April 2028):
All remaining benefits previously identified

For now, loans and accommodation remain out of scope.

HMRC also confirmed they’re continuing to work through outstanding technical issues with stakeholders and may introduce voluntary Class 1A real-time reporting for non-mandated benefits.

It’s still unclear whether previously planned voluntary reporting for loans and accommodation (expected from November 2026) will also be delayed.

At the time of writing, detailed technical guidance is still limited. HMRC has indicated that:

Interim guidance will be updated by July 2026
Final phase 1 guidance is expected alongside the Autumn Budget 2026

What should employers do now?

Although full details are still to come, this update gives employers a clearer direction of travel. The phased approach offers more breathing space, but organisations should still use this time to get ahead, particularly if they’re not already payrolling benefits.

On 15 June 2026, HMRC announced an important update to the rollout of mandatory payrolling of benefits.

Originally expected to be introduced in full at once, the change will now be phased in, giving employers more time to prepare.

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1. Keep a close eye on HMRC guidance

This is still evolving. Make sure you regularly review updates so you can respond quickly as more technical detail becomes available over the coming months.

2. Decide your implementation approach

If you’re not already voluntarily payrolling benefits, you’ll need to decide whether to:

Phase your approach in line with HMRC’s timeline, or
Move earlier to full payrolling (excluding loans and accommodation)

This is especially important if you’ll be running a mixed approach during the transition.

3. Prepare for tax code changes from April 2027

From April 2027, HMRC will remove phase 1 benefits from employees’ tax codes.

That means:

You’ll need to payroll those benefits from that point, and
If you want to payroll additional benefits voluntarily, you must register by 5 April 2027

4. Plan your employee communications

This change could be confusing for employees, particularly if some benefits are payrolled and others still reported via P11Ds.

Clear communication will be essential to help employees understand:

What’s changing
When it’s happening
How it affects their pay

5. Involve finance teams early

The shift to real-time reporting may impact cashflow and forecasting so it’s important that finance teams are involved from the outset.

A joined-up approach between payroll, finance and reward teams will help avoid issues later on.

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UK–Isle of Man NIC agreement

In most cases, contributions will be due where the work is physically carried out. However, exceptions may apply for temporary assignments and certain mobile workers where a certificate of coverage is obtained.

The agreement will take effect once it has been formally approved by both jurisdictions.

Where will contributions be paid?

The general rule is that National Insurance contributions will be payable in the territory where the employee performs the work.

This applies regardless of:

Where the employee lives
Where the employer is based

For example, an employee working in the Isle of Man would usually fall within the Isle of Man social security system, even where they live in the UK or work for a UK employer.

This location-based approach should make it easier for employers to identify which system applies while reducing the risk of contributions being due in both territories.

When can an exception apply?

The agreement allows some workers to remain covered by their home territory’s social security system while working in the other jurisdiction.

This will usually require a certificate of coverage confirming where contributions should continue to be paid.

The UK and the Isle of Man agreed a new social security arrangement on 18 May 2026, replacing rules that have been in place since 1977.

The updated agreement is designed to clarify where National Insurance contributions should be paid when someone works across the two jurisdictions.

Its central principle is that employers and workers should only pay contributions in one territory at a time.

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A certificate may be available for:

Employees temporarily posted to the other territory for up to three years
Self-employed people temporarily working in the other territory for up to three years
Individuals who regularly work in both the UK and the Isle of Man
Seafarers, where factors such as residency and the vessel’s flag may determine liability
Flight and cabin crew whose home base is in a different territory from where they live
Government employees working across both territories for the same government

These exceptions are intended to support temporary assignments and more complex working arrangements without disrupting an individual’s contribution record.

When will the agreement take effect?

The agreement won’t come into force until both the UK and the Isle of Man have completed their approval processes.

It is then expected to apply from the beginning of the next relevant UK tax year.

Employers with affected workers should therefore monitor further government announcements confirming the final implementation date.

What should payroll teams consider?

1. Confirm where the work is carried out

Payroll teams will need to establish where employees are physically performing their duties, as this will usually determine which contribution system applies.

This may require closer communication between payroll, HR and mobility teams, particularly where employees move between jurisdictions or work remotely.

2. Identify when a certificate is needed

Where an employee may qualify for an exception, employers should:

Check whether the arrangement meets the certificate requirements
Apply before the assignment begins where possible
Keep the certificate and supporting information on file
Make sure payroll applies the correct contribution treatment

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Without a valid certificate, contributions may become due where the work is carried out, even where deductions have already been made in the employee’s home territory.

3. Monitor temporary assignments

Employers should keep track of:

The start and end date of each assignment
Whether it remains within the three-year limit
Changes to the employee’s duties or working location
Any extension to the original arrangement

A change in circumstances could affect which territory has responsibility for contributions.

4. Review multi-territory workers carefully

Employees who work regularly in both jurisdictions may require a more detailed assessment.

Special rules may also apply to aviation, maritime and government workers, so employers shouldn’t assume that the general place-of-work rule will always determine liability.

5. Update policies and procedures

Organisations should review any materials covering cross-border working, including:

Global mobility policies
Payroll operating procedures
Assignment documentation
Employee guidance
Record-keeping processes

Processes should clearly set out who is responsible for assessing liability, applying for certificates and notifying payroll of any changes.

6. Check system readiness

Payroll systems and reporting processes should be able to:

Apply the correct contribution regime
Record certificate of coverage arrangements
Track assignment dates and working locations
Maintain a clear audit trail supporting the treatment used

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What does this mean for employers?

The new agreement should provide greater clarity for employers and workers moving between the UK and the Isle of Man.

For most employees, contributions will be due where they carry out their work. However, temporary assignments and mobile working arrangements will need closer review to determine whether an exception applies.

Employers should begin identifying affected workers and reviewing their existing payroll and mobility processes before the agreement comes into force.

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Data will show where patterns exist, but employee insight can help explain why. Employers should also consider feedback from:

Employee surveys
Staff networks
Exit interviews
Consultation exercises
Menopause-related feedback or support requests

Together this should help employers identify the root causes of inequality, rather than simply confirming that a gender pay gap exists.

2. Choose targeted actions

Actions should be based on the issues identified in the data. For example, if women are under-represented in senior roles, the plan should explain how the organisation will improve progression or remove barriers to promotion.

Employers should choose actions that are realistic, evidence-informed and measurable.

Government guidance is expected to provide recommended actions, but employers should avoid simply picking generic commitments that don’t reflect their own workforce.

Each action will need to be categorised as either:

New or in progress, meaning the employer is starting the action or building on existing work
Embedded, meaning the action is already part of normal working practice

Employers must choose at least two actions that are new or in progress.

3. Write a clear supporting narrative

The action plan should include a narrative explaining what the data shows, what issues have been identified and why the chosen actions have been selected.

This is where employers can show that their plan is purposeful. The narrative should connect the evidence to the action, explaining how each step is expected to make a difference.

The language should be clear and accessible. Employees and members of the public should be able to understand the plan without specialist knowledge.

4. Submit and communicate the plan

Employers should submit their action plan through the online reporting service alongside their annual gender pay gap figures.

Each action will need to be categorised as either:

New or in progress, meaning the employer is starting the action or building on existing work
Embedded, meaning the action is already part of normal working practice

Employers must choose at least two actions that are new or in progress.

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Before submission, the plan should have appropriate internal sign-off, usually from senior leadership. This helps demonstrate that the plan has organisational ownership and isn’t simply a reporting exercise.

Employers should also consider how they communicate the plan internally. Sharing the plan with employees can help build trust and show that the organisation is taking action beyond words.

5. Track progress

Once published, employers should monitor whether actions are being delivered, whether milestones are being met and whether the actions are having the intended impact. This could include reviewing changes in:

Recruitment
Progression and retention
Pay equity
Menopause support

Tracking outcomes helps employers understand what’s working, what needs refining and where further action may be needed.

6. Review the plan

Action plans should be treated as living documents. Employers will be expected to review them regularly and update them where actions are completed, priorities change or new evidence becomes available.

Subject to legislation, employers are expected to review mandatory action plans annually. Current expectations suggest interim progress reviews after years one and two, with a more detailed review in year three.

What should employers do now?

Mandatory action plans aren’t yet in force, but employers should use this time to get their evidence in order. The key next steps are to:

Review your latest gender pay gap data
Gather wider workforce insight
Check existing equality and menopause support initiatives
Identify at least two actions that could be new or in progress
Agree who will own, monitor and review the plan
Prepare for annual review requirements if the proposals become law

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Gender pay gap action plans

What is an action plan?

An action plan is a public document that explains the steps an employer is taking to reduce its gender pay gap and support employees experiencing menopause.

It sits alongside gender pay gap reporting, giving context to the figures and explaining the actions being taken to improve equality across the organisation.

A strong action plan should be evidence-based, transparent and capable of being reviewed over time. We've outlined what a good plan looks like here.

1. Understand the issues

Before choosing actions, employers need to understand what is driving their gender pay gap and where menopause support may be falling short.

Start by reviewing your gender pay gap data, including:

Mean and median pay gaps
Mean and median bonus gaps
The proportion of men and women in each pay quartile

Then look at the wider workforce data behind the figures. This may include:

Recruitment outcomes
Starting salaries
Promotion rates
Part-time working patterns
Performance scores
Flexible working uptake
Retention rates
The representation of men and women at different levels of the organisation

Gender pay gap reporting tells employers where pay inequality exists. An action plan goes one step further by setting out what the organisation's doing about it.

For now, action plans are voluntary for employers with 250 or more employees. However, subject to legislation, they’re expected to become mandatory from spring 2027.

That means employers should start thinking now about how they will develop, publish, monitor and review a meaningful plan.

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Employment rights reform in Northern Ireland

In 2024, a consultation was launched on a new Employment Rights Bill designed to promote ‘good jobs’ across Northern Ireland.

Responses came from a wide range of employers, unions and other stakeholders, and the Department for the Economy has now confirmed the areas it plans to take forward. The proposals will go before the Northern Ireland Executive, with the aim of introducing a bill to the Assembly in early 2026. If approved, new measures will be rolled out on a phased basis, with the first changes expected from April 2027.

1. Fairer contracts

Banded hours contracts for zero-hours workers who regularly exceed their contracted hours.
Compensation where shifts are cancelled at short notice.
A ban on exclusivity clauses in contracts that don’t guarantee income above the Lower Earnings Limit.

2. Stronger protections

Safeguards against dismissal through ‘Fire and Rehire’ practices, unless employers can prove genuine financial necessity.
Personal liability for employers who fail to notify the department of large-scale redundancies.
Written terms of employment provided to all workers on or before day one.

3. Agency worker rights

Abolition of ‘pay between assignment’ contracts.
A requirement for agencies to provide Key Information Documents to workers.

4. Pay and benefits

Itemised payslips extended to all workers, not just employees.
Holiday pay calculations aligned with Great Britain, moving to a 52-week reference period.
Transparent distribution of tips, with statutory record-keeping and a new Code of Practice.
Support for real living wage adoption through accreditation schemes and a new statutory ‘right to disconnect’ code of practice.

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5. Work–life balance

Flexible working becomes a day-one right, with employees able to make two requests in 12 months.
New entitlements to carer’s leave, neonatal care leave, and enhanced paternity leave.
Extended redundancy protections for pregnant employees and new parents, lasting up to 18 months after birth or adoption.

6. Trade union access and representation

Lower thresholds for workplace recognition requests (from 21 members to 10).
Digital access rights for union representatives and electronic balloting for industrial action.

Greater promotion of collective bargaining, in line with EU minimum wage directives.
Removal of the 12-week limit on protections against dismissal for official strike action.

7. Transparency and consultation

Lower thresholds for Information and Consultation of Employees (ICE) agreements, with requests possible from as few as 10 workers or 2% of staff.
New reporting obligations for whistleblowing bodies (‘prescribed persons’).

What employers need to know

If passed, these reforms will bring employment law in Northern Ireland much closer in line with recent and upcoming changes in Great Britain.

Policies, contracts, and payroll systems will need reviewing and updating well ahead of implementation. While the exact timetable is still subject to Assembly approval, the first changes could take effect in 2027.

If you’d like to learn more about these reforms and what they could mean for employers, you can read the full article here.

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Changes to zero hour contracts

Zero hours contracts have always offered flexibility. But without the right safeguards, they can often leave workers carrying too much of the risk.

That’s why the government is introducing new rights to make work more predictable, fair and secure. The goal is to end ‘one-sided flexibility’. That means giving workers more security over:

The hours they work
The notice they receive for shifts
What happens if shifts are cancelled

These new rights won’t remove flexibility altogether. In fact, workers can choose to stay on a zero hours contract if that suits them, but the default will be shifting towards more predictability. Here's what's changing.

Right to request guaranteed hours

Eligible workers will have to be offered a guaranteed hours contract that reflects the average hours worked over a legislatively defined period.

This is currently expected to be the previous 12 weeks of work. Employers must offer this, but workers can decline and remain on their current arrangement if they prefer.

Right to reasonable notice of shifts

Employers will need to give workers reasonable notice of upcoming shifts. If notice is too short, workers will be able to raise a tribunal claim.

The government will set out what counts as ‘reasonable’, but each case will be considered based on its circumstances.

Right to compensation for cancelled or changed shifts

If a shift is cancelled, shortened or moved at short notice, workers must be compensated.

Again, the exact definitions of ‘short notice’ will be set in upcoming regulations, but the sentiment is that financial risk shouldn’t fall on the worker.

What about agency workers?

The rules will apply slightly differently for agency staff, but key protections will still stand:

Either the agency or the hirer must offer guaranteed hours, the hirer will be obliged by default, but there will be flexibility in certain scenarios
Both are responsible for giving reasonable notice of shifts.

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If shifts are cancelled at short notice, the agency will have to follow the same rules as the employer and compensate the employee.
The Government will consult further on how this works in practice.

Will zero hours contracts still be allowed?

Zero hours contracts aren’t going anywhere. It remains an attractive option for many, especially for those who value flexibility, such as students or carers. Workers can still opt to remain on a zero hours contract.

These reforms are about creating a fairer baseline, not removing flexibility altogether.

What’s next?

The Government will now consult on how to implement these measures. Final regulations will confirm:

What counts as ‘reasonable’ notice.
What compensation looks like for cancelled shifts.
How rights apply across different industries.

The changes are part of the new Employment Rights Bill, but they won’t come into effect until late 2027 according to the governments recently published Employment Rights Bill roadmap.

We’ll keep you updated as things progress and let you know when you need to take action.