ACS chief executive James Lowman presented evidence to the annual Low Pay Commission investigation this week showing that shop owners had already cut back on staff hours and plans for expansion in 2011.
Shop owners had also reported "a negative impact on pay structures" and becoming less competitive, he said, citing evidence from a survey of 600 store owners, responsible for about 9,000 employees.
"Our survey provides further evidence that when costs go up retailers scale back," said Lowman. "At a time when we need to focus on growth, the best thing the LPC can do is freeze the minimum wage until at least 2014."
BRC director general Stephen Robertson said the ACS was right to raise the issue. "I am a big supporter of the NMW, but if we allow it to inflate too high then we will reduce the opportunity to employ people. I am not sure a freeze is the right answer, but restraint is called for."
The LPC will deliver its recommendation to ministers in the spring of 2012.