Could proposed zero hours reforms change GP locum work?

By Work Healthcare in Primary Care on September 11th 2026 -

What the Government's proposed employment reforms could mean for GP locums, practices and healthcare recruiters.

GP locum work has long offered doctors flexibility, allowing them to balance clinical commitments with family life, training and other professional interests. But proposed changes to zero-hours and similar contracts could alter how some flexible work is offered and managed.

The reforms are not yet in force, and important details are still being worked out. Even so, GP locums, practices and recruitment agencies should understand the likely direction of travel.

What changes are being proposed?

The Government is consulting on measures set out in the Employment Rights Act 2025, which received Royal Assent in December 2025. The proposals aim to reduce 'one sided flexibility', where an organisation can vary the amount or timing of work while the worker carries most of the financial uncertainty.

The proposed package includes:

A right to guaranteed hours that reflect the hours a qualifying worker has regularly worked.
A right to reasonable notice of shifts.
A right to payment when shifts are cancelled, shortened or moved at short notice.

The detailed rules will determine which workers are covered, how regular working patterns are assessed and how the reforms apply to agency workers. A 12 week initial reference period and an hours threshold of somewhere between 8 and 20 hours a week are among the options the Government has said it favours, though the wider consultation considered thresholds as high as 48 hours. These remain proposals rather than final rules, and implementation is expected in 2027 at the earliest.

Why could this matter to GP locums?

Many GP locums are not employed on traditional zero-hours contracts. They may work through a limited company, a recruitment agency, a staff bank or directly with a practice as self-employed contractors, and their legal position will depend on the specific relationship involved.

Even so, the reforms could still shape the wider market for flexible clinical work. If a locum regularly works a similar number of hours for the same organisation, that organisation may need to consider whether the arrangement should offer greater predictability, or whether a more formal employment relationship would be more appropriate.

For example, a GP who works every Monday and Tuesday at the same practice for several months may sit in a different position from a doctor who picks up occasional shifts across several practices. Where exactly that boundary falls will depend on the final legislation.

Agency workers are explicitly covered by the reforms. Under the Government's proposals, the hirer (in this case, the practice) would by default be responsible for making an offer of guaranteed hours to a qualifying agency worker, and accepting that offer could see the worker move onto a contract directly with the hirer.

Potential benefits for doctors

For some clinicians, the reforms could bring greater security and transparency. Potential benefits may include:

More predictable income for doctors working regular patterns.
Greater notice of shifts, making it easier to plan childcare, travel and other clinical commitments.
Stronger protection when shifts are cancelled or changed at short notice.
A clearer basis for discussing whether a regular locum arrangement has, in practice, become a substantive role.
Greater recognition of the working pattern a locum is already delivering.

These changes could matter most to doctors who have gradually become regular members of a practice team while remaining engaged on a casual or variable-hours basis.

The proposals also recognise that some workers value flexibility. A qualifying worker would generally be free to accept or reject an offer of guaranteed hours, so the intention is not to remove every flexible arrangement outright.

Possible challenges for practices

Practices may need to review how they engage regular locums and how they record shifts, cancellations and hours worked. This could bring additional administrative work, including:

Tracking working patterns over the relevant reference period.
Identifying which clinicians may fall within the final eligibility criteria.
Reviewing agency and direct-engagement arrangements.
Providing clearer information about shift availability and cancellations.
Assessing whether a long-term locum arrangement is still the right model.

There are also concerns about flexibility. General practice demand can shift quickly because of annual leave, sickness, seasonal pressures and fluctuating appointment volumes, and some practices may be reluctant to guarantee hours when future staffing needs are hard to predict.

The Government's own impact assessment acknowledges that the reforms could create costs for organisations relying on variable hours, seasonal demand or unpredictable staffing, and notes that the final effect on employer flexibility and labour demand remains uncertain. Sector bodies have raised similar concerns: the CIPD has warned that overly complex rules could push some employers towards fixed-term contracts or self-employed arrangements instead, while the National Association of Sessional GPs has cautioned that locums could 'bear the brunt' if practices and staff banks respond by reducing how much they use self-employed cover.

What should GP locums do now?

There is no need for doctors to make immediate changes based solely on the proposals. The legislation is not yet fully in force, and the final eligibility rules are still to be confirmed. That said, locums can take sensible steps now to understand their current position:

Review your contracts. Check whether you work as an employee, worker, agency worker or genuinely self-employed contractor.
Keep accurate records. Retain details of shifts worked, cancellations, notice given and the organisations you work for.
Look at your working patterns. Consider whether you regularly work the same days or hours for one practice or provider.
Clarify cancellation arrangements. Make sure you understand what happens if a booked shift is cancelled or shortened.
Follow official updates. The final position may change as the consultation and secondary legislation develop.

Locums should be cautious about assuming a guaranteed-hours right would automatically apply to every GP booking. The outcome will depend on the final regulations, the contractual relationship in place and the facts of the individual arrangement.

What should practices and agencies consider?

Practices and recruitment agencies can start by improving transparency around flexible work. Clearer booking terms, cancellation policies and notice arrangements can benefit clinicians and employers alike, regardless of where the final rules land.

It may also help to identify regular locums who provide recurring cover and consider whether they would welcome a more structured arrangement. For some practices, this could support continuity and retention; for others, a salaried, sessional or fixed-term role may be a better fit.

Agencies should keep a close eye on how the reforms address agency-worker arrangements and make sure practices understand who may hold responsibility for future obligations, since the consultation is specifically looking at how guaranteed-hours offers should work where an agency is involved.

A changing role for locum recruitment

None of this means GP locum work is disappearing. Flexible doctors remain essential to general practice, particularly for short-term cover during annual leave, sickness, vacancies and changing demand.

However, the market may increasingly distinguish between:

Genuine ad hoc locum work.
Regular sessional work.
Long term temporary arrangements.
Roles better suited to salaried, fixed-term or partnership contracts.

For doctors, the challenge will be preserving meaningful flexibility while securing fair notice and predictable arrangements. For practices, it will be maintaining access to flexible cover while planning staffing responsibly and meeting any new requirements.

FAQs

When will the zero hours reforms come into force? The Employment Rights Act 2025 received Royal Assent in December 2025, but the zero hours provisions require secondary legislation. Implementation is expected in 2027, though the exact date has not been confirmed.

Will guaranteed hours apply to self-employed GP locums? It depends on the individual's status and contract. Many GP locums work as genuinely self-employed contractors, which may sit outside the new rights, but those engaged as workers or through agencies could be covered. The final regulations will determine the exact boundaries.

Do the reforms cover agency locums? Yes. The Government's proposals extend the right to guaranteed hours to qualifying agency workers, with the hirer (the practice) responsible by default for making the offer.

What hours threshold is being considered? The Government has indicated a preference for a threshold of between 8 and 20 hours a week, with a 12 week reference period, though a wider range of options was included in the consultation.

Stay informed about GP locum opportunities

The proposed reforms are still developing, but they highlight the importance of understanding the terms behind every clinical engagement. Whether you're looking for occasional sessions, regular practice work or a longer term GP role, clear information can help you make better career decisions.

Explore the latest GP and healthcare vacancies on work.healthcare, where practices and healthcare organisations advertise opportunities for doctors and other clinical professionals.

This article is intended for general information and should not be treated as legal advice. The proposed reforms may change before they come into force. Practices, agencies and doctors should seek professional advice about their individual circumstances.

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