What the Employment Rights Act 2025 Means for Menopause at Work
Until now, menopause support in the workplace has been optional.
Some organisations acted. Many didn’t.
That has changed.
The Employment Rights Act 2025 places menopause on the legislative agenda for the first time - not by creating new rights, but by requiring organisations to show what they are actually doing.
This is not new protection for employees. It’s new accountability for employers.Until now, menopause support in the workplace has been a matter of good practice - something progressive organisations chose to do, largely voluntarily, in response to pressure from employees, advocates, and the occasional tribunal decision.
For HR teams and senior leaders, that distinction matters enormously.
What the Act actually requires
The Employment Rights Act 2025 creates a statutory duty for employers with 250 or more employees to publish Equality Action Plans. These plans must set out the measures employers are taking in two prescribed areas:
Reducing the gender pay gap
Supporting employees experiencing menopause - specifically including perimenopause and post-menopause
Plans must include at least one action in each area. The Government encourages employers to go further than the minimum where possible, and has published a framework of 18 evidence-informed recommended actions to support implementation.
Plans must be signed off by senior leadership - a requirement equivalent to that already in place for gender pay gap reporting, signalling that this is a board-level accountability matter, not solely an HR function.
Plans will be submitted via the existing gender pay gap reporting portal, placing menopause accountability squarely within the established gender equality reporting infrastructure.
The timeline: what happens when
The implementation is phased, giving organisations time to develop genuine capability rather than rushing into compliance.
6 April 2026 - Voluntary period begins From this date, employers with 250 or more employees can voluntarily publish their Equality Action Plans, including menopause actions. The Government is actively encouraging early adoption. Voluntary publication signals commitment to employees, investors, and customers, and gives organisations valuable time to test their approach before it becomes mandatory.
Spring 2027 - Mandatory publication begins For the 2027/2028 reporting year, publication of Equality Action Plans becomes mandatory for employers with 250 or more relevant employees as of the snapshot date of 5 April 2027.
April 2028 - First compulsory action plans due The first compulsory plans - covering the 2027/2028 reporting year, based on 2026/2027 gender pay gap data - must be published by 4 April 2028.
Note: Secondary legislation is still required to bring the mandatory requirement into full effect. Additional Government guidance specifically for action plan development is expected in April 2026. Employers should monitor ACAS and the Government Equalities Office for updates as regulations are confirmed.
What an action plan must contain
At minimum, a Equality Action Plan must include at least one concrete, practical action relating to menopause support. In practice, any plan that contains only the bare minimum will attract scrutiny - from employees, trade unions and the public audience that gender pay gap reports already reach.
The Government has published a framework of 18 recommended evidence-informed actions, grouped around five areas: recruiting staff, developing and promoting staff, building diversity into the organisation, increasing transparency and health-related support.
For the menopause element specifically, the guidance identifies the following types of action as appropriate for inclusion:
Policy and procedure
A written menopause policy in plain language, accessible to all employees
Clear processes for employees to request adjustments without excessive bureaucracy
Separate recording of menopause-related absence from general sick leave
Manager capability
Training for line managers that focuses on practical, compassionate responses - not just legal compliance
Designated menopause champions or peer support facilitators
Regular check-ins built into existing wellbeing conversations
Workplace environment
Environmental risk assessments that account for temperature regulation, ventilation and rest areas
Flexible working options that are genuinely available in practice, not just permitted in policy
Access to occupational health support
Culture and transparency
Menopause awareness sessions for all staff to reduce stigma and normalise conversation
Visible leadership support at senior level
Feedback mechanisms so employees can report whether support is working
The five-step process the Government recommends for developing a plan:
Understand the issues - audit existing measures and gather workforce data
Select actions - choose from the evidence-informed framework, prioritised for your organisation
Submit the plan - via the gender pay gap portal
Monitor progress - track whether actions are delivering intended outcomes
Review annually - update the plan based on what is and isn't working
The shift from passive reporting to active accountability
This is the structural change that matters most for HR leaders and senior teams to understand.
For the nine years since mandatory gender pay gap reporting was introduced in 2017, the requirement has been to report - to publish a set of statistics. What those statistics revealed, and what organisations did in response, was left largely to voluntary action. Most organisations published their gap. Fewer did anything meaningful to close it.
The Equality Action Plan requirement changes that architecture. It moves from transparency to accountability. Employers are now required to state publicly - in writing, signed by senior leadership - what they are going to do, by when, and on what evidence. That commitment creates a basis for scrutiny, for challenge, and eventually for enforcement.
The Government has been explicit about the intent: this is a material shift from passive reporting to active communication about proactive steps. Employee groups, trade unions, and industry bodies are expected to scrutinise commitments and hold employers accountable for whether those commitments are followed through.
For organisations that have taken menopause support seriously, this is an opportunity to document and publicise what they have already built. For those who have not, the voluntary year - April 2026 to spring 2027 - is not optional in any meaningful strategic sense. It is the window in which to build the capability, gather the data, and develop the institutional readiness that cannot be created under deadline pressure.
The wider context: where this fits
The Equality Action Plan requirement does not sit in isolation. It is part of a broader legislative programme that is reshaping employer accountability for women's health and workplace equality.
The Employment Rights Act 2025 also introduces, across its wider provisions: day-one parental leave rights, strengthened protections for pregnant employees and those returning from maternity leave, enhanced sexual harassment prevention duties, and — from 1 January 2027 - a reduction of the unfair dismissal qualifying period from two years to six months with the compensatory award cap abolished entirely.
That last change significantly increases the legal exposure of any employer who dismisses, manages out, or applies capability processes to employees experiencing menopause symptoms without proper process and adjustment - including in the first six months of employment. The Employment Rights Act 2025 is not a standalone menopause measure. It is part of a legislative landscape that is becoming substantially less forgiving of poor practice.
Looking further ahead, the Government has also proposed extending pay gap reporting to include ethnicity and disability under the Equality (Race and Disability) Bill. The Government's own guidance notes that menopause action plans may also support employees experiencing endometriosis, fibroids, or polycystic ovarian syndrome - signalling a broader direction of travel toward accountability for women's health conditions across the lifecycle, not just menopause. The recent Employment Appeal Tribunal ruling in Pal v Accenture [2026] EAT 12, which reinforced the legal framework for disability discrimination claims connected to chronic women's health conditions, sits squarely in this emerging landscape.
What smaller employers should know
The mandatory requirement applies to employers with 250 or more employees. Smaller organisations are not currently required to publish an Equality Action Plan.
However, two things are worth noting. First, the legal obligations under the Equality Act 2010 - the duty to make reasonable adjustments, the prohibition on discrimination, the duty of care under the Health and Safety at Work Act 1974 - apply to employers of all sizes. Those have not changed. Second, as menopause becomes more visible as both a legal and reputational issue, the absence of any visible support becomes increasingly notable in smaller organisations, particularly those competing for experienced female talent.
The action plan framework is available for voluntary adoption by any employer. For smaller organisations, the five-step process and 18 recommended actions provide a practical structure for building menopause support in a proportionate, evidence-based way - without waiting for a legal mandate.
For HR: the practical questions to answer now
If you are responsible for compliance or people strategy in an organisation of 250 or more employees, the voluntary year beginning April 2026 is the right moment to work through the following:
Audit: What do you already have - policy, training, flexible working practice, occupational health access, absence recording? What is the gap between what exists on paper and what employees actually experience?
Data: What does your workforce data show about retention, absence, and engagement among women aged 40 to 60? What would the cost of current attrition look like if menopause-related exits were identified and quantified?
Governance: Who owns this? Senior sign-off is required. Has menopause support been discussed at board or leadership team level as a business risk and a compliance matter?
Action selection: From the 18 recommended actions, which three to five are most relevant and most achievable in your organisation in the first year? The Government encourages more than the minimum. Selecting actions that address both policy infrastructure and cultural normalisation will be more durable than policy alone.
Publication: Even if you choose not to publish voluntarily in 2026, internal development of the plan - including the consultation, the data gathering, and the action selection - builds the organisational readiness you will need before mandatory publication begins.
This is a starting point, not a ceiling
The minimum legal requirement - one action on menopause - is a floor, not a destination. The organisations that will benefit most from this legislative moment are those that use the framework as a prompt to do what the evidence has long suggested: engage with their workforce, understand the real experience of menopausal employees, train their managers to respond practically and compassionately, and build the conditions in which experienced women are retained rather than lost.
Menopause support done properly is not a cost. It is an investment in the retention of experienced professionals at the peak of their institutional value - and it is now, for the first time, a formal accountability requirement.
For a full picture of what effective employer support looks like in practice, including the adjustments that make the most difference and the legal framework that underpins them:
Menopause Workplace Adjustments: What You Can Ask For (UK Guide) - the practical detail on what organisations can and should provide
Your Legal Rights at Work During Menopause (UK Guide) - the current legal protections, including the growing case law on discrimination and disability
How to Talk to Your Manager About Menopause - how these conversations actually happen at line management level
If you’re responsible for people, compliance, or retention, this legislation is already shaping expectations in your organisation - whether you have a plan in place or not.
I work with organisations to translate this into practical action: Equality Action Plans, manager training, and menopause-aware workplace strategy.
→ Get in touch to discuss implementation support
This article is informed by the Employment Rights Act 2025, Government Equalities Office guidance published 4 March 2026, ACAS implementation guidance, and CIPD analysis. It is written within the scope of health and nutrition coaching practice. It does not constitute legal advice. For specific compliance questions, consult an employment law solicitor or HR legal specialist.
References
Employment Rights Act 2025. UK Government Legislation. Royal Assent 22 December 2025.
Government Equalities Office. (4 March 2026). Government launches landmark gender pay gap and menopause action plans to help women thrive at work. gov.uk
Government Equalities Office. (4 March 2026). How to improve gender equality in the workplace: actions for employers — the 18 evidence-informed recommended actions. gov.uk
ACAS. (2026). Employment Rights Act 2025: timeline and guidance. acas.org.uk
CIPD. (2026). Equality action plans: changes under the Employment Rights Act 2025. cipd.org
Farrer & Co. (March 2026). New gender pay gap and menopause action plans: what employers need to know. farrer.co.uk
Berry Smith. (March 2026). Menopause action plans and new equality duties for employers. berrysmith.com
Blake Morgan. (March 2026). Employment Rights Act 2025: equality action plans. blakemorgan.co.uk
UK Government. (February 2026). Plan to Make Work Pay and Employment Rights Act: timeline update. gov.uk
Littler. (March 2026). UK Government launches guidance on pay gap and menopause action plans. littler.com
Pal v Accenture (UK) Ltd [2026] EAT 12. Employment Appeal Tribunal, judgement 19 January 2026.
Equality Act 2010. UK Government Legislation.
UK Government. (2024). Menopause in the Workplace Literature Review.
