13 April 2026
CBI Northern Ireland and over 20 other business groups have written a joint letter to Dr Caoimhe Archibald MLA, Minister for the Economy, in which they raise concerns about the NI Employment Rights Bill.
Dear Minister Archibald
Industry concerns around the Employment Rights Bill
We, the undersigned representatives of over 20 business groups write collectively to follow up on previous correspondence from CBI Northern Ireland, FSB Northern Ireland, the Institute of Directors, Northern Ireland Chamber of Commerce and Industry, and Manufacturing NI. Since then, through wider engagement within the business community, concerns have grown and consensus has developed across industries and sectors.
We do so recognising the deeply challenging economic environment now facing employers. Since the outbreak of the war in Ukraine in 2022, cumulative UK inflation has risen by approximately 20%. Businesses continue to face sustained increases in energy prices and wider inflationary pressures linked to global instability. This represents a four‑year cost‑of‑doing‑business crisis which has reduced resilience and narrowed margins across all sectors. We are increasingly concerned about the heightened risk of a significant economic shock arising from the ongoing conflict in the Middle East, particularly given its potential implications for energy markets, supply chains, and wider global stability and the impact that this will have on local business.
We want to acknowledge and welcome areas where you have listened to the concerns raised by business, particularly the decision not to proceed with a full ban on zero‑hours contracts, whilst we reserve our right to form a view on the proposed revisions presented in the bill, and the proposed reduction in the balloting notice period. These are constructive steps. However, we must also be unequivocal: very serious concerns remain.
First, we remain deeply alarmed by the voice and representation proposals. In particular, the proposal to lower the threshold for union representation from 21 to 10, as well as the union access measures. Employers, especially SMEs, fear that these changes will add significant administrative complexity at a time when complexity invariably equals cost. Our members continue to believe that the proposals fail to achieve the proper balance or acknowledge the variety of business models present, such as family-owned companies and international employers based here.
Second, the implications for deepening the role of the Labour Relations Agency (LRA) remain insufficiently clear. As you will be aware, the LRA currently faces a considerable backlog of holiday pay–related claims. Any additional statutory responsibilities placed on the Agency within this Bill must be assessed in the context of extremely limited fiscal headroom and significant operational pressure.
Third, we are increasingly concerned by the breadth and pace of the Bill itself. The previous Assembly mandate demonstrated the risks of legislating under acute time pressure: between January 2020 and March 2022, 56 Bills were introduced and 46 Acts passed within an extremely compressed legislative window. The Speaker at that time explicitly warned Members of the difficulty of scrutinising a very large volume of legislation in too short a period. That experience must not be repeated, not least because of the challenging environment we all find ourselves in, fiscally and economically.
We are therefore concerned that proceeding with such a wide‑ranging, all‑encompassing Bill within the limited time remaining in this mandate risks poor law‑making that is in the interests of no one, or the reputation of Northern Ireland as a place to do business. We had previously advised that the business view was that the proposals should be broken into a series of smaller, more manageable Bills - an approach that we believe would have enabled proper scrutiny, targeted reform, and better outcomes for workers and employers alike. Regrettably, this approach was not taken.
Given the cumulative pressures now facing Northern Ireland - including the ongoing cost‑of‑doing‑business crisis, the Executive’s budgetary constraints, continued global instability, and heightened geopolitical uncertainty - we believe that this is a moment requiring genuine partnership with employers and measured decision‑making.
Accordingly, we urge you and the wider Executive not to rush this legislation in the current mandate. We are increasingly concerned that we are running out of time to ensure that full and proper scrutiny can be given to the Bill, or indeed, any potential amendments. The risk of unintended consequences is now so significant that full consideration should be given to deferring the Bill to the next mandate. The stakes for workers, employers, and wider economic recovery are simply too high.
We remain committed to continued partnership working and stand ready to meet with you, and the Department, to discuss workable and proportionate approaches to improving employment rights while safeguarding competitiveness and economic stability.
Yours sincerely
CBI Northern Ireland
ADS Northern Ireland
Causeway Chamber of Commerce
Construction Employers Federation Northern Ireland
Dairy Council for Northern Ireland
Employers Federation Northern Ireland
FSB Northern Ireland
Horticultural Trades Association
Hospitality Ulster
IoD Northern Ireland
Logistics UK
Londonderry Chamber of Commerce
Manufacturing NI
MEGA Mid Ulster
Mineral Products Association Northern Ireland
Northern Ireland Chamber of Commerce
Northern Ireland Food and Drink Association Ltd
Northern Ireland Grain Trade Association
Retail NI Road Haulage Association
The National Franchised Dealers Association
Northern Ireland Ulster Farmers’ Union