How to create a menopause action plan: A step-by-step guide for employers
Employers with 250 or more employees can now voluntarily publish an action plan alongside their gender pay gap data. Subject to secondary legislation, these action plans are expected to become mandatory from spring 2027.
The requirement comes from the Employment Rights Act 2025, which created the framework for equality action plans. These plans are designed to show the practical steps large employers are taking to address their gender pay gap and support employees experiencing menopause.
For employers, the voluntary period is an opportunity to prepare properly rather than wait for the legal requirement to take effect. A useful menopause action plan should be based on evidence, reflect the needs of your workforce and set out actions that can be tracked over time.
This guide from JMW's employment law team explains how to create a menopause action plan using the government's six-step process, and what employers should consider at each stage.
At a glance: How do you create a menopause action plan?
The government has set out six steps for creating an action plan:
| Step | Requirement |
|---|---|
| 1. Understand the issues | Use workforce data and employee feedback to identify the barriers affecting gender equality and menopause at work |
| 2. Choose your actions | Select evidence-informed actions that address the gender pay gap and provide menopause support |
| 3. Write a supporting narrative | Explain why you chose each action and how you will measure whether it works |
| 4. Submit your action plan | Publish the plan through the government's gender pay gap service |
| 5. Track outcomes | Measure progress against a clear baseline and review whether your actions are working |
| 6. Review your plan | Revisit and update the plan as your organisation's needs and evidence change |
The government's full action plan guidance for employers covers both the gender pay gap and menopause in the workplace.
What is a menopause action plan?
A menopause action plan sets out the evidence-based steps an employer is taking to support employees experiencing menopause as part of a wider equality action plan.
The Employment Rights Act 2025 gives the government power to require large employers to develop and publish equality action plans. These plans cover two connected areas of workplace gender equality:
- Addressing the organisation's gender pay gap
- Supporting employees going through menopause
The measures were originally introduced through the Employment Rights Bill, which received Royal Assent on 18 December 2025 and became the Employment Rights Act 2025. Employers may therefore still encounter older references to the Employment Rights Bill and menopause action plans when researching the changes.
The plans build on existing gender pay gap reporting. Employers with 250 or more employees have been required to publish specified gender pay gap data annually since 2017. The new framework moves beyond reporting the figures by asking large employers to set out what they are actually doing to improve workplace gender equality.
At present, publishing an action plan is voluntary. The government expects mandatory action plans to take effect from spring 2027, subject to secondary legislation. The Employment Rights Act also allows future regulations to set out how non-compliance will be enforced, so employers should keep the final regulations and guidance under review.
Which employers need to create an action plan?
The voluntary action plan process is available to employers with 250 or more employees. The same threshold is expected to apply when action plans become mandatory.
During the 2026 to 2027 reporting year, eligible employers can voluntarily publish their first plan by:
- 30 March 2027 for most public authority employers
- 4 April 2027 for private, voluntary and all other public authority employers
Private and voluntary sector employers must also identify a responsible person when submitting the plan. This will usually be a director, partner or senior officer who confirms that the information is accurate.
Groups with more than one legal entity should also check the structure carefully. A separate action plan is required for each legal entity with 250 or more employees. Organisations can use the same actions across different entities where appropriate, but each entity still needs its own submission.
The government explains the current position in its overview of the action plan requirements.
How to create a menopause action plan in six steps
A strong menopause action plan should be built around the issues that exist in your own organisation. It should not simply reproduce a policy template or select actions because they are easy to implement.
The government's six-step framework provides a useful structure.
Step 1: Understand the issues in your organisation
Start with evidence. Before deciding which menopause action to include, identify where employees may be experiencing barriers and where your organisation's current approach could improve.
The government recommends analysing data across the employee lifecycle. This may include recruitment, pay, performance, progression, flexible working, retention and exit data. Employers should also engage with employees to understand their experience of menopause at work. Menopause is most commonly experienced between the ages of 45 and 55, but it can happen earlier, so employers should avoid designing support around age assumptions alone.
Practical steps may include:
- Reviewing existing gender pay gap data and what may be driving the gap.
- Looking at sickness absence, retention and progression data where appropriate.
- Identifying whether women are leaving or progressing less frequently at particular levels or stages of their careers.
- Considering whether menopause-related workplace issues are concentrated in particular roles, locations or teams.
- Using staff surveys, interviews, focus groups or employee networks to understand what support employees need.
- Involving HR, senior leaders, line managers and relevant employee groups from the outset.
This stage can also help employers identify whether support is being raised late, whether employees know where to go for help and whether inconsistent handling by managers is creating avoidable problems.
The aim is to establish a clear baseline. Without that evidence, it is difficult to know which action will make the biggest difference or whether it has worked later.
Read the government's Step 1 guidance: understand the issues in your organisation.
Step 2: Choose the right actions
Once you understand the issues, choose the actions that address them.
The government has published 18 evidence-informed actions. Employers must currently select a minimum of two for their action plan:
- At least one action must address the gender pay gap.
- At least one action must support employees experiencing menopause.
Employers must also be working on at least two actions classified as new or in progress. Actions that are already established can be included as embedded actions, but relying only on existing practice will not meet that expectation.
The six menopause-specific actions are:
- Train managers to support employees experiencing menopause. Manager training should help line managers understand the workplace impact of menopause, have supportive conversations and know what help the organisation can provide.
- Offer occupational health advice. This can provide specialist input where menopause symptoms are affecting an employee's work or workplace wellbeing.
- Set up menopause support groups and networks. Internal networks, peer support or a menopause champion can give employees accessible information and a clear route to support.
- Offer workplace adjustments. Depending on individual needs, these may include temperature control, access to ventilation, additional breaks, changes to working patterns, flexible working or other adjustments to the working environment.
- Conduct a menopause risk assessment. This can help identify workplace factors that may aggravate menopause symptoms and highlight practical steps to address them.
- Review policies and procedures. Employers should consider whether policies on menopause, sickness absence, flexible working, health and safety, wellbeing and capability or performance management work together effectively.
The right menopause action will depend on what Step 1 shows. If employees do not know what support exists, clearer communication and manager training may be priorities. If employees report barriers in the physical workplace, risk assessments and workplace adjustments may be more useful. If policies are inconsistent or difficult to use, reviewing procedures may have the greatest immediate value.
A menopause action plan should therefore reflect the organisation rather than take a one-size-fits-all approach.
Read the government's Step 2 guidance: choose your actions.
Step 3: Write a clear supporting narrative
Selecting an action is only part of the process. Employers also need to explain why they chose it, and how they will know whether it is working.
For every action marked as new or in progress, the government asks employers to provide supporting text covering:
- Why the organisation chose the action
- How progress and impact will be tracked
For embedded actions, employers can explain how the action became part of established working practice and what results they have seen.
The current voluntary process allows up to 100 words of supporting text for each action and up to 200 words for the overall supporting narrative.
This is where clear ownership and measurable commitments matter. Avoid relying on broad statements such as saying the business is “committed to supporting employees experiencing menopause”. Instead, explain what will happen, who will lead it, how it will be implemented and what evidence will be used to assess progress.
For example, if the menopause action is manager training, the supporting text might identify which managers will receive training, when it will be delivered and how the organisation will assess whether managers feel more confident handling menopause-related workplace issues afterwards.
Read the government's Step 3 guidance: write a supporting narrative.
Step 4: Submit and publish your action plan
Employers publish the action plan through the government's gender pay gap service, alongside their gender pay gap data.
Before submitting, make sure you have:
- Chosen the actions your organisation will take
- Prepared the supporting text for each relevant action
- Written the overall supporting narrative
- Identified the responsible person where one is required
- Confirmed who will submit the plan and that they have access to the gender pay gap service
The published plan will be available to the public alongside the organisation's gender pay gap data. This makes it particularly important that the action plan reflects what the organisation genuinely intends to do, rather than what it would like to be seen to be doing.
Read the government's Step 4 guidance: submit your action plan.
Step 5: Track whether your actions are working
A menopause action plan should remain a working document after publication. Employers need evidence showing whether their chosen actions are producing meaningful change.
The government recommends creating baseline metrics before an action begins and then measuring the same indicators after implementation. Depending on the action, this might involve looking at:
- Employee feedback on menopause support
- Uptake of workplace adjustments or flexible working arrangements
- Sickness absence or retention patterns where appropriate
- Progression data
- Use of occupational health or support networks
- Manager confidence after training
- Whether employees know how and where to request support
Where possible, use reliable data that the organisation already collects before creating new reporting processes. Employers should also consider whether outcomes differ between teams, job types, locations or groups within the workforce.
Monitoring is not simply about showing success. If an action is not producing the intended result, the evidence should help the organisation understand why and decide whether to change its approach.
Read the government's Step 5 guidance: track the outcomes of your actions.
Step 6: Review and update your action plan
Employers should review the plan regularly so that it develops alongside the workforce and the evidence.
The detailed mandatory requirements are still subject to legislation. Under the government's current plans, once mandatory action plans take effect employers will be expected to:
- Carry out an interim progress review one year after submitting the mandatory action plan
- Carry out a further interim review after two years
- Complete a more detailed review after three years
- Review their actions at the end of each year and revise them where appropriate
Employers must continue to be working on at least two actions. If an action becomes fully embedded, is removed or no longer meets the organisation's needs, another action may need to be introduced.
This review process is why employers should set measurable objectives from the beginning. An action plan that has clear ownership, realistic timescales and relevant measures will be much easier to review than one based on broad commitments.
Read the government's Step 6 guidance: review your plan.
What should employers do before action plans become mandatory?
Large employers do not need to wait until spring 2027 to start preparing. The voluntary period provides time to understand the mandatory requirements as they develop and test what works within the organisation.
Useful practical steps include:
- Decide who owns the action plan. Bring together HR, senior leadership, equality and diversity, workplace wellbeing and occupational health where relevant, with clear responsibility for delivery.
- Review your gender pay gap data. Identify the areas that may require further analysis rather than treating the headline figure in isolation.
- Speak to employees. Build open dialogue through surveys, focus groups or established employee networks and make sure people know how to raise menopause-related concerns.
- Review existing policies and procedures. Check that menopause, sickness absence, flexible working, wellbeing, health and safety and capability or performance management procedures do not work against each other or inadvertently disadvantage menopausal employees.
- Train managers. Give managers practical guidance on supportive conversations, workplace adjustments, available support and when to involve HR or occupational health.
- Consider practical workplace adjustments. These might include temperature control, ventilation, additional breaks, flexible working or changes to the working environment, depending on individual circumstances.
- Make support easy to find. Consider support networks, a menopause champion, Employee Assistance Programmes and clear signposting to occupational health where appropriate.
- Make the plan measurable. Set actions, timescales and measures so that progress can be reviewed rather than relying on general commitments.
Starting early also gives employers the opportunity to test and refine their approach before mandatory action plans are expected to begin. This can help organisations retain experienced employees, identify barriers to progression and understand whether menopause-related issues are contributing to wider gender equality concerns. Publishing a meaningful plan during the voluntary period can also show current and prospective employees that the organisation is taking menopause support and workplace gender equality seriously.
JMW has previously explained the background to the legislation:
How does a menopause action plan fit with existing employment law responsibilities?
A menopause action plan does not replace an employer's existing employment law responsibilities.
Menopause is not currently a standalone protected characteristic under the Equality Act 2010. However, treatment connected with menopause may engage existing protections, including disability discrimination, sex discrimination and age discrimination, depending on the facts.
Where menopause symptoms amount to a disability for the purposes of the Equality Act, employers may also have a duty to consider reasonable adjustments. The appropriate response will depend on the employee, their symptoms, the workplace and the disadvantage they experience.
This means employers should look beyond the publication of the action plan itself. Good practice should also be reflected in day-to-day management, relevant workplace policies, sickness absence decisions, performance management and the way requests for support are handled.
For more detail, read JMW's menopause employment law guidance for employers, and our guidance on whether menopause can amount to a disability under UK employment law.
Employers reviewing their internal framework can also find more information about JMW's employment law advice on contracts, policies and procedures.
How JMW helps employers prepare for menopause action plans
The move towards mandatory equality action plans gives large employers a clear reason to review how menopause support works across their organisation now.
Our employment law team advises businesses on the practical and legal issues involved in preparing for the new requirements. We help employers review workplace policies and procedures, consider reasonable adjustments, address individual employee issues and make sure managers understand how to respond consistently when menopause affects work.
We also advise on the wider employment law implications of menopause in the workplace, including sex and disability discrimination, sickness absence, performance issues and Employment Tribunal risk.
Our approach is practical. A menopause action plan should not sit separately from the way your organisation already manages its workforce. We help employers connect the plan with their existing policies, management processes and wider employment strategy so that the actions are workable and measurable.
To discuss how the Employment Rights Act 2025 and the expected mandatory action plan requirements may affect your organisation, speak to our employment law team on 0345 872 6666 or complete our online enquiry form.