13 Apr 2026

Menopause actions plans: More a policy than a taboo

What the Employment Rights Act 2025 requires from a menopause action plan and how to build one that holds up.

The Employment Rights Act (ERA) 2025 has shifted the compliance picture for large employers. From April 2026, organisations with 250 or more employees are expected to begin voluntarily publishing menopause action plans, ahead of a mandatory legal requirement in 2027.

For HR and reward leaders, this is the transition year. The question is no longer whether to support menopause. It is whether your organisation can show that support publicly, consistently and credibly.

How a menopause action plan differs from a policy

Most organisations already have a menopause policy. A policy sets out intent. A menopause action plan, as required under the ERA 2025, sets out proof.

The distinction matters legally. Under the Act, large employers must publish an evidence-based plan detailing the specific steps being taken to keep menopausal talent in the workforce. That means named actions, measurable outcomes and demonstrable support - not a document that sits untouched in a shared drive.

A credible menopause action plan typically covers:

What support is available and how employees access it
The reasonable adjustments in place (temperature control, flexible working, clinical access)
How managers are equipped to handle menopause-related conversations consistently
The role of a designated menopause champion
Engagement and utilisation data that shows the plan is working

If your current approach cannot produce evidence against each of those areas, your plan carries real legal and reputational risk.

Why the stakes are higher than they appear

Menopause sits at the intersection of retention, performance management, discrimination law and senior talent loss.

The numbers are hard to ignore:

1 in 10 women have already left the workforce due to unmanaged menopause symptoms
Absenteeism linked to menopause costs UK businesses over £10.5 billion annually
1 in 4 women consider leaving work because of menopause; 1 in 10 do

These are real people, often at the peak of their careers. The ERA 2025 exists, in part, to stop that loss.

For HR leaders, the risk of inaction is now threefold:

There is the legal risk of failing to meet the ERA's transparency requirements.
There is the performance management risk of employees with undiagnosed perimenopause symptoms being managed out on capability grounds.
And there is the reputational risk of publishing a plan that cannot hold up to scrutiny from the Fair Work Agency or employees themselves.

The perimenopause problem most organisations are missing

Perimenopause is where legal exposure tends to be highest, and where most organisations have the least visibility.

Protection under the Equality Act 2010 applies as soon as symptoms begin to affect work. Many people experience perimenopause for years before receiving a diagnosis. During that time, they may face performance concerns, increased absence or difficulty with concentration - all of which can feed into disciplinary or capability processes.

Without adequate menopause support sitting alongside those processes, employers face real exposure to unfair dismissal or disability discrimination claims.

An action plan that only addresses confirmed menopause cases falls short. Support needs to start earlier, at perimenopause, and carry through to post-menopause.

What makes a Menopause Action Plan defensible?

Several things determine whether a plan holds up when it matters.

Specialist access, not generalist signposting: Employee assistance programmes (EAPs) are not built for complex menopause symptom management. Pointing employees toward generic mental health support is unlikely to satisfy the ERA's expectation of reasonable support. A credible plan should include access to practitioners with specific menopause expertise, such as those certified by the British Menopause Society (BMS).
Consistency across the organisation: Inconsistency is one of the highest-risk areas for large employers. One line manager responds well to a menopause-related absence; another dismisses it entirely. The organisation is exposed either way, regardless of what the policy document says. A robust Action Plan needs to show that support is applied equitably across every level and location.
Data that shows the plan is working: Publishing a plan without supporting engagement data leaves a credibility gap. The ERA expects employers to demonstrate impact, not just intent. Utilisation data, symptom improvement metrics and confidence-at-work scores are the kind of evidence that turns a plan into something defensible rather than decorative.
Whole-journey support: Support that only activates once symptoms become severe is reactive by definition. Employers need to show their plan covers the full picture, from perimenopause through to post-menopause, with proactive check-ins and ongoing clinical guidance rather than one-off referrals.

5 steps to a menopause action plan

Whether you are starting from scratch or reviewing an existing policy, this is a useful framework to work from:

Audit what you currently have. Identify the gap between your existing policy and what the ERA actually requires. What can you evidence today? What is missing?
Define your reasonable adjustments. Document the specific workplace adjustments available to employees managing menopause symptoms. These should cover environmental changes, flexible working options and access to clinical support.
Appoint a menopause champion. This person is central to your plan's credibility. They give employees a consistent point of contact and signal genuine organisational commitment at a visible level.
Equip your managers. Managers are often the first point of contact for employees experiencing symptoms. Without clear guidance, they become a liability. Your action plan should set out how managers are supported and what resources they can direct employees toward.
Build in evidence collection from day one. Engagement data, symptom outcomes and feedback mechanisms need to be part of the plan's structure from the start, not added later. This data will underpin your annual ERA disclosures.

April 2026 is the starting point

Voluntary publishing begins this month. Organisations that use 2026 to build a substantive, evidenced plan will be in a much stronger position when mandatory reporting begins in 2027.

Acting early signals that the organisation takes the retention of senior female talent seriously, before regulators or resignations force the issue.

For organisations below the 250-employee threshold, the ERA's reasonable adjustment expectations under existing employment law still apply. The employers building action plans now are the ones who will not be starting from zero when the threshold arrives.

Join Peppy’s live session on 22nd April where government ambassador and TV personality Mariella Frostrup and Peppy's CEO Dr Mridula Pore will guide HR and benefits leaders through what the ERA 2025 requires from large employers and what a credible Menopause Action Plan looks like, including a live Q&A.