Your Menopause Action Plan Is Only Half a Plan
The deadline most HR teams are now looking at
If you work in HR for an organisation with 250 or more people, you have probably already had the email about Menopause Action Plans. Under the Employment Rights Act 2025, large employers are being asked to publish one alongside their gender pay gap figures. It has been voluntary since April 2026 and becomes a legal requirement from spring 2027, with the first compulsory plans due by April 2028.
The government guidance came out in March and on paper it is fairly simple. You pick at least one action to narrow your gender pay gap and at least one to support people going through menopause, including perimenopause and post-menopause, from a list of 18. The list includes things like manager training, access to occupational health, support groups and risk assessments. You write a short explanation of each and publish it on the government's gender pay gap service.
I spent the early part of my career in HR, and my concern with these plans is that most of the conversation starts with menopause, when for many women the problems at work started years earlier.
Menstrual health in the action plan is the missing half
Menopause is the final stage of around forty years of periods. For a lot of women those years were hard going at work long before anyone used the word menopause, and very few workplaces ever asked about it.
Research from the University of Portsmouth, published in November 2025, found that a quarter of women have severe menstrual symptoms and more than a third say their symptoms get in the way of work and daily life. Only 18% of organisations include menstrual health in their wellbeing plans, and just 12% offer any dedicated support.
Endometriosis UK's survey this April found that more than half of women have felt under pressure to go to work with severe period pain, and around a quarter have had problems at work because of time off for it. Half thought painful periods were just normal. Endometriosis alone affects around 1 in 10 women, and 1 in 6 of those eventually leave work altogether.
When women leave or step back for these reasons, it rarely gets recorded as a menstrual health issue. It goes down as sickness absence, a promotion they did not go for, or a resignation nobody quite understood.
The government guidance does mention this. It encourages employers to extend their menopause actions to other menstrual health conditions, and names endometriosis and polycystic ovary syndrome. That condition has since been renamed polyendocrine metabolic ovarian syndrome, or PMOS, to reflect that it affects hormones and metabolism across the whole body rather than only the ovaries. But it is encouragement rather than a requirement, and I suspect most employers will do what is required and stop there.
ISO 45010 puts the two together
On 7 September 2026 ISO, the international standards body, published ISO 45010, the first international standard on menstruation and menopause in the workplace. Menstruation is named first in the title, and the standard treats the two as one subject throughout.
It is guidance rather than law, so nobody can be certified against it and nobody has to follow it. It is free to access, it is written for organisations of every size, and it has a section specifically for small and medium businesses. It builds on the British Standard BS 30416, which has covered menstruation, menstrual health and menopause together since 2023.
It covers workplace culture and policy, manager awareness and training, workplace design, practical adjustments, and how to measure whether any of it is helping.
Two things are new since the 2023 British Standard: guidance on disclosure and privacy, and a template workplace charter employers can adapt. The privacy guidance is important, because a lot of women would rather struggle on quietly than have their periods or their perimenopause discussed around the office.
BSI published research alongside the launch. 57% of UK women said their employer had never talked about menstruation or menopause, 49% said they had been offered no support at all, and only 10% would feel confident raising it with a male line manager.
So UK law is asking large employers for a menopause plan, and the new international standard covers menstruation and menopause together. If you are writing a plan anyway, building it around ISO 45010 means you meet the legal requirement and cover the whole picture at the same time.
Where periods and perimenopause overlap
Perimenopause happens while women are still having periods. For many, the first sign is a change in their periods rather than hot flushes: heavier bleeding, cycles closer together or further apart, and far less predictable. Flooding at your desk at 46 is both a menstrual health issue and a perimenopause issue.
A plan that only applies once someone says the word menopause will miss the years when support could help most. And if a woman has spent her working life keeping quiet about endometriosis or heavy periods, she is unlikely to suddenly speak up about perimenopause.
Very heavy bleeding, bleeding that is new or unusual for you, or persistent pain should always be checked by your GP. Workplace support sits alongside medical care, never instead of it.
What I would put in the plan
The guidance tells you what to publish, but not how to make it useful to the woman three desks away. With my HR background and my hormone health training, this is where I would focus.
Cover the whole cycle. If you can, call it a Menopause and Menstrual Health Action Plan. Meet the legal requirement for menopause, then use ISO 45010 as your framework to include endometriosis, PMOS (formerly PCOS), heavy bleeding, PMDD and other conditions. Most of the adjustments are the same, so it costs very little more and helps far more people.
Train managers to have the conversation. Most managers do not need a biology lesson. They need to know how to start the conversation without either of them squirming, what to say when someone tells them, and what they can offer straight away. Something as simple as "that sounds hard, what would help?" goes a long way. They also need to know what stays confidential and who else can be told, which is what the new ISO 45010 disclosure guidance covers.
Sort out the basics. Easy access to toilets, free period products, somewhere cool to work, a desk fan, uniforms that are comfortable on a heavy day, and being able to step away without explaining why. ISO 45010 also recommends individual risk assessments and absence policies that take symptoms into account, so that a bad month does not end in a disciplinary. None of this is expensive.
Allow flexibility. Symptoms do not keep office hours. Being able to change a start time, work from home on a bad day or move a meeting takes a lot of the dread out of the month.
Look at the foundations. Sleep, stress and blood sugar sit underneath a lot of what women describe, whether that is period pain, perimenopause brain fog or plain exhaustion, and they are at the heart of how I work. Helping staff understand how those three connect is a practical, non-medical way for an employer to support people.
Check it is working. Ask people. Anonymous surveys, feedback through a support group, and a look at absence and leaver figures will all tell you whether anyone is using what you have put in place.
Under 250 people? This still applies to you
If you run a smaller business, you might read all this and assume it does not affect you. The duty to publish only applies from 250 employees, but the legal duties underneath it apply to everyone.
The Equality Act 2010 protects people from unfair treatment because of sex, age or disability, and severe menstrual conditions and menopause symptoms can fall under any of those. Compensation in discrimination claims is not capped. The Health and Safety at Work Act 1974 also means you should already be looking at working conditions, temperature and access to facilities.
Smaller teams can often move faster, and ISO 45010 includes a section written specifically for smaller businesses. You do not need to publish a plan to have a kind and practical one.
Three questions to ask before you publish
Would a 32-year-old with endometriosis read our plan and feel it included her?
Do our managers know what to say in the first two minutes of that conversation?
How will we know, a year from now, whether it has made any difference?
I have put together a free plain English guide for employers, Menopause at Work. It walks through the six menopause actions in the government guidance, what ISO 45010 adds, and what it all means if you have fewer than 250 staff. It is free to download from my website, no email needed.
This is the work I do through The Phase Partnership, my workplace consultancy. I offer lunchtime awareness sessions for whole teams, half-day workshops for managers and HR, and help to shape a plan that covers the whole cycle, in person across Hampshire and the South Coast or online. You can find out more at rhustrand.co.uk/workplace-wellness-consultancy.
Rhu
References
Farrer and Co, New gender pay gap and menopause action plans: what employers need to know
Addleshaw Goddard, Equality Action Plans: what employers need to know now, May 2026
University of Portsmouth, New research challenges menstrual taboo to promote more inclusive workplaces, November 2025
Endometriosis UK, Half of women in UK have felt pressure to go to work despite severe period pain, April 2026
Endometriosis UK, Menstrual Health at Work
ISO, World-first International Standard launched as demand grows for better workplace support during menstruation and menopause, September 2026
BSI, Global guidance to help keep women experiencing menstruation and menopause in work published, September 2026
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