



Flexible by Design, Pressured by Reform
Between October and December 2024, the Government held a formal consultation on how the zero-hour contract reforms should apply specifically to agency workers. This was part of the plan to “end exploitative zero-hour contracts” under the forthcoming Employment Rights Bill. The IPM’s formal consultation response drew on industry feedback to caution against a one-size-fits-all approach. Alongside other key sector bodies, the IPM submitted evidence drawn from surveys, interviews, and member feedback. This reflected a clear and consistent message from across the promotional marketing industry: while the ambition to protect workers is broadly supported, a blanket approach risks serious unintended consequences for flexible workforces.

Speaking Up for the Sector
Lord Black, President of the IPM, has emphasised the need for industry voices to be heard during this consultation. “The promotional marketing sector plays a vital role in the UK’s creative economy, yet the proposed restrictions on zero-hour contracts risk undermining its ability to function effectively,” he stated. “It is imperative that policymakers consider the realities of our industry and engage with expert feedback to ensure a balanced approach.”
The promotional marketing industry requires flexibility to enable agencies to respond to tight turnarounds, seasonal surges, and last-minute activations. From sampling campaigns to major experiential rollouts, zero-hour staffing allows for responsive, tailored delivery. According to research shared with the IPM by Agency by Agency, the experiential industry supports over 12,800 jobs and contributes upwards of £840 million in GVA to the UK economy. Many of these agencies rely on zero-hour contracts to manage fluctuating client demands, seasonal peaks, and short-term campaign work.
Crucially, this flexibility isn’t just a benefit to employers—it’s a preference for many workers. A recent IPM member survey found that 97% of promotional workers actively choose zero-hour contracts for the freedom they offer. These individuals include students, freelancers, parents, and creative professionals seeking work that fits around their lives.

Key Developments from the Consultation
Following this consultation, the Government confirmed that protections will extend to agency workers, with several sector-specific adjustments. The obligation to offer guaranteed-hours contracts will rest with the end client (not the agency), acknowledging that the client controls the workflow. There will also be shared liability for providing reasonable shift notice, with tribunals empowered to apportion responsibility between agency and client. Compensation for cancelled shifts will be paid by the agency, but agencies may recover costs from clients who cause cancellations.
Further amendments introduced on 4 March 2025 clarified that if a worker accepts a guaranteed-hours offer, this does not automatically end their contract with the agency—allowing workers to continue taking on other assignments if they choose. The Bill also acknowledges the seasonal, campaign-based nature of much agency work by allowing for the use of limited-term contracts, with additional consultation on these provisions expected as the legislation develops.
These adjustments reflect some recognition of the realities of agency staffing, but concerns remain about how these measures will work in practice. The promotional marketing industry continues to call for careful implementation that protects choice and avoids undermining operational flexibility.
Agency Work in Focus
While Deputy Labour Leader Angela Rayner has argued that tighter restrictions on zero-hour contracts will help drive economic growth, data from within the promotional marketing sector tells a different story. The very areas most impacted by these proposals—experiential marketing, brand activations, and live events—achieved record-breaking 23.1% growth in Q1 2024, according to Bellwether data. Live experiences and sales promotions continued to be among the strongest contributors to marketing budget growth throughout the year. Rather than supporting this momentum, mandated guaranteed hours and rigid scheduling requirements risk imposing unsustainable financial and administrative pressures on agencies and their clients.
What’s Next?
The Employment Rights Bill remains under scrutiny at committee stage, where MPs are examining the details clause by clause. The findings from the agency worker consultation will feed into the development of secondary legislation and technical guidance, expected to follow later this year.
Full implementation is not anticipated before 2026, allowing time for further dialogue and refinement. As this legislation progresses, the voice of the industry remains vital. The IPM will continue engaging directly with the government, providing data, insight, and expertise to help shape a fair and workable path ahead—one that protects both people and the creative economy they help power.
Flexible by Design, Pressured by Reform
Between October and December 2024, the Government held a formal consultation on how the zero-hour contract reforms should apply specifically to agency workers. This was part of the plan to “end exploitative zero-hour contracts” under the forthcoming Employment Rights Bill. The IPM’s formal consultation response drew on industry feedback to caution against a one-size-fits-all approach. Alongside other key sector bodies, the IPM submitted evidence drawn from surveys, interviews, and member feedback. This reflected a clear and consistent message from across the promotional marketing industry: while the ambition to protect workers is broadly supported, a blanket approach risks serious unintended consequences for flexible workforces.

Speaking Up for the Sector
Lord Black, President of the IPM, has emphasised the need for industry voices to be heard during this consultation. “The promotional marketing sector plays a vital role in the UK’s creative economy, yet the proposed restrictions on zero-hour contracts risk undermining its ability to function effectively,” he stated. “It is imperative that policymakers consider the realities of our industry and engage with expert feedback to ensure a balanced approach.”
The promotional marketing industry requires flexibility to enable agencies to respond to tight turnarounds, seasonal surges, and last-minute activations. From sampling campaigns to major experiential rollouts, zero-hour staffing allows for responsive, tailored delivery. According to research shared with the IPM by Agency by Agency, the experiential industry supports over 12,800 jobs and contributes upwards of £840 million in GVA to the UK economy. Many of these agencies rely on zero-hour contracts to manage fluctuating client demands, seasonal peaks, and short-term campaign work.
Crucially, this flexibility isn’t just a benefit to employers—it’s a preference for many workers. A recent IPM member survey found that 97% of promotional workers actively choose zero-hour contracts for the freedom they offer. These individuals include students, freelancers, parents, and creative professionals seeking work that fits around their lives.
Key Developments from the Consultation
Following this consultation, the Government confirmed that protections will extend to agency workers, with several sector-specific adjustments. The obligation to offer guaranteed-hours contracts will rest with the end client (not the agency), acknowledging that the client controls the workflow. There will also be shared liability for providing reasonable shift notice, with tribunals empowered to apportion responsibility between agency and client. Compensation for cancelled shifts will be paid by the agency, but agencies may recover costs from clients who cause cancellations.
Further amendments introduced on 4 March 2025 clarified that if a worker accepts a guaranteed-hours offer, this does not automatically end their contract with the agency—allowing workers to continue taking on other assignments if they choose. The Bill also acknowledges the seasonal, campaign-based nature of much agency work by allowing for the use of limited-term contracts, with additional consultation on these provisions expected as the legislation develops.
These adjustments reflect some recognition of the realities of agency staffing, but concerns remain about how these measures will work in practice. The promotional marketing industry continues to call for careful implementation that protects choice and avoids undermining operational flexibility.

Agency Work in Focus
While Deputy Labour Leader Angela Rayner has argued that tighter restrictions on zero-hour contracts will help drive economic growth, data from within the promotional marketing sector tells a different story. The very areas most impacted by these proposals—experiential marketing, brand activations, and live events—achieved record-breaking 23.1% growth in Q1 2024, according to Bellwether data. Live experiences and sales promotions continued to be among the strongest contributors to marketing budget growth throughout the year. Rather than supporting this momentum, mandated guaranteed hours and rigid scheduling requirements risk imposing unsustainable financial and administrative pressures on agencies and their clients.
What’s Next?
The Employment Rights Bill remains under scrutiny at committee stage, where MPs are examining the details clause by clause. The findings from the agency worker consultation will feed into the development of secondary legislation and technical guidance, expected to follow later this year. Full implementation is not anticipated before 2026, allowing time for further dialogue and refinement. As this legislation progresses, the voice of the industry remains vital. The IPM will continue engaging directly with the government, providing data, insight, and expertise to help shape a fair and workable path ahead—one that protects both people and the creative economy they help power.
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As debate around zero-hour contracts continues, the Employment Rights Bill moves one step closer to becoming law.
IPM Awards 2025 Entries Now Open!
Do you have an outstanding campaign capable of winning a coveted IPM Award? Showcase your creativity, innovation, and results by entering the 2025 IPM Awards.
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