Legislation

Menopause Action Plans: what the law actually requires

A plain-English guide to the Equality Action Plan provisions of the Employment Rights Act 2025 — who is in scope, what has to be published, and how to decide what to commit to.

Updated August 2026

8 minute read

Contents

What the law says

The Employment Rights Act 2025 introduces a requirement for larger employers to publish an Equality Action Plan. The plan covers two areas: gender pay gap and menopause. This guide deals with the menopause element.

The requirement is deliberately light-touch in its minimum form. An employer must set out the steps it is taking to support employees experiencing menopause, choosing at least one action from six areas described in government guidance.

Who is in scope

Employers with 250 or more employees. This is the same threshold and broadly the same population that already files gender pay gap reports, so most organisations in scope will already be familiar with the reporting cycle and the portal.

If you are close to the threshold

Headcount fluctuates. If you are approaching 250 employees it is worth preparing on the assumption you will be in scope, rather than discovering you are with weeks to spare.

The key dates

Date

What happens

Status

April 2026

Voluntary publishing opens alongside gender pay gap data

In effect now

Spring 2027

Requirement expected to become mandatory

Subject to legislation

Annually thereafter

Plans republished against prior commitments

Expected

The mandatory date remains subject to legislation, and further government guidance has been expected. We update this page as the position develops.

The six action areas

Government guidance sets out six menopause-specific actions. An employer must commit to at least one:

Guidance is clear that employers should choose the actions that best address the barriers identified within their own organisation. It does not, however, require them to identify those barriers first — and that is where most published plans will fall down.

Publishing and sign-off

Plans are published on the government gender pay gap portal, in the same place and on the same cycle as pay gap data. Each plan must be signed off by a named director.

A thin action plan is worse than no action plan. It is a public document, carrying a named director’s signature, that your own staff and future candidates will read.

That is the practical risk. A plan committing to the cheapest available action, with nothing behind the choice, is a statement about the organisation that will be read by exactly the people best placed to judge whether it is true.

Choosing your actions

The decision is genuinely difficult, because the six actions address quite different problems. Manager training does nothing for an organisation whose managers are already confident but whose policy is silent on adjustments. A policy review does nothing where the policy is sound but nobody knows it exists.

This is what a diagnostic is for. Our instruments consistently find gaps that leadership did not know existed — most often between what HR believes is in place and what the workforce reports experiencing.

If the evidence shows

The likely action

Why

Managers unsure how to respond

Train managers

Capability is the most common high-impact gap

Staff unaware support exists

Review policies and communication

Provision without visibility changes nothing

Environmental complaints recurring

Conduct a risk assessment

Identifies practical, fixable friction

Low disclosure despite good intent

Support groups or networks

Psychological safety, not policy, is the barrier

Demonstrating progress

Because plans republish annually against prior commitments, the second year asks a harder question than the first: did it work?

An employer with no baseline cannot answer it. An employer who tied each committed action to a measurable indicator — a specific survey question, a policy audit score, a risk rating — can answer it with evidence, and publish the movement.

Northern Ireland

These provisions apply to Great Britain only

Employment law is devolved in Northern Ireland, and the Employment Rights Act 2025 provisions do not extend there. Northern Ireland employers are not required to publish a Menopause Action Plan. Many choose to anyway — and we have written a separate guide on why, and what good practice looks like outside the statutory framework.

Free Readiness Checklist

A one-page checklist covering everything a credible Menopause Action Plan needs, and where most employers fall short.

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Related Insights

Guidance

Menopause Action Plans in Northern Ireland

Why NI employers are out of scope, and what to do about it

Compliance

What the six action areas actually mean in practice

A breakdown of each, and when it is the right choice

Culture

Why manager capability is the most common gap

What our organisational audits consistently find