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For many employers, headcount is under scrutiny as employment costs have risen and every new role is expected to carry a stronger business case. A hiring freeze is one of the clearest ways to show cost discipline, yet organisations still need the people who keep operations running, deliver change, manage risk, support customers, maintain compliance and provide specialist expertise.
The challenge is deciding where the business can afford to wait, and where leaving a role unfilled creates a different kind of risk. A more cautious environment should lead to better decisions, not automatically fewer of them. Employers need to weigh cost against capability, delivery, retention, legal and reputational risk before deciding whether a vacancy can genuinely remain open.
A hiring freeze rarely means that every organisation has stopped recruiting. More often, approval thresholds have risen and hiring is concentrated around roles with a clear operational or commercial case.
There are signs of that selectivity in the wider labour market. The REC’s September 2026 Report on Jobs found that permanent staff appointments rose in August for the first time since September 2022. Temporary billings also increased for a fifth consecutive month, with growth at the second-fastest rate recorded in more than three years. Separately, 34% of UK employers plan to increase permanent headcount before the end of 2026, while employers were also continuing to invest in contract and project-based hiring.
These figures point to a market where organisations remain cautious but continue to invest where skills are needed.
The immediate benefits of a hiring freeze are easy to see. Keeping roles unfilled can reduce salary and employment costs, while also limiting recruitment fees, advertising spend, onboarding and training costs, employer pension contributions, benefits and other expenses associated with adding headcount. For organisations under pressure to protect margins or manage budgets more tightly, these savings can be significant. The consequences of leaving critical vacancies open, however, are often harder to capture.
Projects still have deadlines. Customers still need support. Regulatory, reporting and governance responsibilities remain. Technology programmes still require expertise. Transformation cannot always be postponed without consequences. When vacancies stay open, that work is often redistributed across existing teams. Over time, the pressure can affect delivery, productivity and retention.
We encourage employers to consider vacancies across six connected areas of risk:
A hiring freeze may reduce one while increasing several others.
The strongest headcount decisions start with capability rather than job titles. Instead of applying the same threshold to every vacancy, employers can assess each role against those six areas of risk. For each vacancy ask:
The answers will look different across organisations. For one employer, a vacant compliance or risk role may create unacceptable exposure. For another, the priority might be a technology specialist needed for a system migration, an HR leader managing organisational change, a programme manager keeping transformation on track or an operations professional protecting service delivery.
The key is to compare the cost of hiring with the cost of the capability gap. If leaving a role vacant materially increases several of these risks, the stronger business case may be to recruit, even where wider headcount remains tightly controlled.
Identifying a capability need does not automatically mean approving permanent headcount.
A more selective market gives employers an opportunity to think carefully about how expertise is accessed. Is the capability needed indefinitely, or is there a defined outcome to deliver? Is the requirement business-as-usual, or linked to a transformation, implementation, peak workload or period of change?
A permanent hire may be right where lasting capability and ownership are required. In other situations, interim, contract or project-based resource can provide specialist expertise without creating a long-term headcount commitment.
That could mean an interim finance director during a transformation, a change specialist for a defined programme, a technology contractor for an implementation or project-based support for a time-limited operational need.
Strategic workforce planning is about making that distinction deliberately rather than defaulting either to permanent recruitment or to a blanket hiring freeze.
Where permanent hiring is justified, greater scrutiny should strengthen the process rather than make it unnecessarily long.
The business case should be agreed before recruitment begins. Stakeholders should be aligned on what the role needs to achieve, which skills are essential and how candidates will be assessed. Structured interviews, appropriate technical assessment and consistent criteria all help employers make more confident decisions.
But caution becomes counterproductive when approvals are repeatedly revisited or interview stages are added without improving the evidence. Scarce candidates still have choices, and a slow process can mean losing the person the organisation has decided it genuinely needs.
The aim should be disciplined hiring: enough scrutiny to reduce the risk of a poor appointment without creating delays that introduce a different risk. Stronger hiring decisions do not necessarily require more stages; scrutiny needs to be applied at the points that matter.
Cost control will always remain an important part of workforce decision-making. But caution should not be confused with inactivity. While the hiring freeze may be starting to loosen, scrutiny is unlikely to disappear. The opportunity now is to move from blanket caution towards more selective, evidence-led strategic workforce planning. That means controlling cost while protecting the people, skills and expertise required to deliver.
For more insight into how employment reform, rising workforce costs and increased scrutiny are reshaping hiring confidence, download Goodman Masson’s full report, The New Hiring Risk: How the Employment Rights Act Is Changing Hiring Confidence and Workforce Strategy.
See why a hiring freeze can create capability risks, and how selective finance hiring helps employers control costs while protecting critical business delivery.
