Despite growing recognition of English as a Lingua Franca (ELF) in international tourism, a persistent gap remains between how English is used in hospitality workplaces and how English for Specific Purposes (ESP) is conceptualised in tourism education. ESP instruction often prioritises standardised language forms and predefined service scripts, offering limited preparation for multilingual, interactionally dynamic service environments. This article proposes an interaction-oriented, ELF-informed model of ESP needs analysis for hospitality education. Drawing on ELF research, intercultural pragmatics, and service encounter studies, it reconceptualises communicative needs as interactionally emergent and context-sensitive rather than as fixed inventories of linguistic forms or task lists. The model foregrounds intelligibility, adaptability, interactional repair, and relational management as central dimensions of professional competence. Pedagogically, the article links needs analysis to curriculum design, teacher mediation, and programme-level alignment, arguing that ESP courses should reflect multilingual communicative realities rather than native-speaker norms. By reframing needs analysis as a bridge between workplace communication and educational practice, the study provides a conceptual foundation for future empirical research and curriculum development in hospitality ESP.