Menopause action plans: what the new Act requires 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, Benefits and Reward leaders, this is the transition year. The question is no longer whether to support menopause. It is whether your organisation can evidence that support publicly, consistently and credibly.

What is a Menopause Action Plan and how does it differ 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 might 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.

Five practical steps to building your Menopause Action Plan

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

1. 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?
2. 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.
3. 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.
4. 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.
5. 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.

In conversation with Mariella Frostrup: Menopause Action Plans, how to set the new standard

Register here

Join Mariella Frostrup and Peppy's CEO to hear what good looks like

On 22nd April 2026 at 12pm (BST), Mariella Frostrup, Chair of Menopause Mandate and the UK Government's Menopause Employment Ambassador, joins Dr Mridula Pore, CEO and Co-Founder of Peppy, for a live session on Menopause Action Plans and the ERA 2025.

Mariella has spent years pushing menopause into the national conversation, including campaigning for its proper recognition in workplaces and public policy. Her appointment as the UK Government's Menopause Employment Ambassador reflects how seriously government now views employer accountability on this issue.

This session is for HR, Benefits and Reward leaders in organisations with 250 or more employees. You will leave with:

• Clarity on what the ERA 2025 requires from large employers
• A practical view of what a credible Menopause Action Plan looks like
• A framework for building the internal business case and securing leadership buy-in
• The opportunity to put your questions directly to Mariella and Mridula in a live Q&A

Register here to secure your place.

Not yet at 250 employees? The most prepared organisations do not wait for the threshold. They build the standard before they are required to.

The Employment Rights Act 2025 applies to large employers (250+ employees) in Great Britain. Voluntary Menopause Action Plan publishing begins April 2026. Mandatory requirements are expected from 2027. For official government guidance, visit gov.uk.

Frequently asked questions: Menopause Action Plans and the ERA 2025

What is a Menopause Action Plan?

A Menopause Action Plan is a published, evidence-based document that sets out the specific steps an employer is taking to support employees experiencing menopause symptoms. It goes beyond a policy by requiring named actions, measurable outcomes and demonstrable support. A policy states intent; an Action Plan provides proof.

How is a Menopause Action Plan different from a menopause policy?

A menopause policy outlines an organisation's position and general commitments. A Menopause Action Plan, as required under the Employment Rights Act (ERA) 2025, must detail what support is actually in place, how employees access it, and evidence that it is working. The two are not interchangeable.

Who is legally required to publish a Menopause Action Plan and when?

Employers with 250 or more employees in Great Britain are expected to begin voluntarily publishing Menopause Action Plans from April 2026. Mandatory publication is expected to become a legal requirement from 2027.

What happens if an employer doesn't comply with the ERA 2025 on menopause?

Failure to comply carries both legal and reputational risk. Employers who cannot evidence adequate menopause support face exposure to unfair dismissal claims, disability discrimination claims under the Equality Act 2010, and scrutiny from the Fair Work Agency. Publishing a plan that cannot be substantiated carries similar risk.

Does a Menopause Action Plan cover perimenopause?

Yes, and it should. Protection under the Equality Act 2010 applies as soon as symptoms begin to affect work — which can happen years before a formal menopause diagnosis. A credible Action Plan needs to address the full journey, from perimenopause through to post-menopause, not only confirmed cases.

What reasonable adjustments should a Menopause Action Plan include?

Reasonable adjustments vary by role and individual, but a credible plan should cover environmental changes such as temperature control, flexible working arrangements, and access to specialist clinical support. Adjustments should be documented, consistently applied across the organisation, and reviewed regularly.

What is the role of a Menopause Champion?

A Menopause Champion is a designated person within the organisation who acts as a visible, consistent point of contact for employees managing menopause symptoms. Their role gives the Action Plan credibility, ensures employees know where to turn, and signals genuine organisational commitment beyond a written document.

Do employers with fewer than 250 employees need to act?

The ERA 2025 publishing requirement applies to organisations with 250 or more employees. However, the reasonable adjustment obligations under existing employment and equality law apply to all employers regardless of size. Smaller organisations that build good practice now will be better placed if and when thresholds change.

How do you evidence that a Menopause Action Plan is working?

Evidence should be built into the plan from the outset. Useful measures include utilisation data showing how many employees are accessing support, symptom improvement metrics, confidence-at-work scores, and employee feedback. This data underpins annual ERA disclosures and demonstrates impact rather than intent.