Is a menopause action plan mandatory?
Not yet. Publishing a menopause action plan is voluntary from 6 April 2026 and, subject to legislation, is expected to become mandatory from spring 2027 for employers with 250 or more employees.
That is the short answer. The rest of this page sets out the dates, who is caught, what the plan has to contain, and what happens if you do not publish one.
The dates
| Date | What happens |
|---|---|
| 6 April 2026 | Publishing a menopause action plan becomes voluntary. Employers can publish, and the reporting framework exists, but there is no obligation. |
| Spring 2027 | Publication is expected to become mandatory for employers with 250 or more employees, subject to legislation. |
| 30 March 2027 | First mandatory publication deadline for public authorities. |
| 4 April 2027 | First mandatory publication deadline for private and voluntary sector employers. |
The deadlines mirror the existing gender pay gap reporting dates, and plans are published alongside gender pay gap data on the same government service. If you already report a gender pay gap, the mechanism will be familiar. The audience is the same too: the plan is public, permanently, and anyone can read it.
Source: Employment Rights Act 2025 and the accompanying gender pay gap and menopause action plan guidance, GOV.UK. Checked 18 August 2026.
Who has to publish one
Employers with 250 or more employees. The threshold is the same one used for gender pay gap reporting, and it is counted the same way, on a snapshot date.
Two points that catch people out. First, the count is per legal entity, not per group. A group of five companies with 120 staff each may fall outside the threshold, while a single company of 260 falls inside it. The guidance does not resolve whether obligations attach to the group or the entity. If you sit near the line, take a view early and write it down. Second, sitting below the threshold removes the publication duty. It does not remove the health and safety duty to assess risk, or the Equality Act duty to make reasonable adjustments. Those apply regardless of headcount.
What the plan has to contain
The guidance sets out 18 suggested actions across five categories. An employer must select a minimum of two: at least one addressing the gender pay gap, and at least one addressing menopause.
The guidance runs as six steps, in order, and the order matters more than the count. The first is to understand the issues in your own organisation, engaging employees and using workforce data, before selecting which actions to take. Everything downstream is supposed to follow from what that first step finds.
What happens if you do not publish
Enforcement follows the gender pay gap model, where the Equality and Human Rights Commission can take action against non-compliant employers. In practice the sharper risk is not enforcement. It is that a missing or thin plan becomes evidence in a tribunal claim brought by one of your own employees.
Tribunals have already awarded substantial sums in menopause-related discrimination claims. In each case the question that did the damage was the same: what did the employer know, and what did it do about it. A published plan that names real actions taken for stated reasons is a good answer. A template with two boxes ticked is not.
Source: Equality and Human Rights Commission enforcement powers under the Equality Act 2010. Employment tribunal awards in menopause-related claims, including Lynskey v Direct Line Insurance Services, judgment 2023.
What the requirement does not include
Several things are widely assumed to be part of this and are not. Knowing which is which saves money and stops the exercise turning into a procurement round before anyone has established what the problem is.
| Not required | What is actually the case |
|---|---|
| Funding clinical care | You are not required to provide hormone replacement therapy, private menopause clinics, coaching or counselling. Many employers choose to, and some of it is valuable, but none of it is what the publication duty asks for. |
| A menopause policy | A policy is one of the suggested actions, not a requirement in itself. A policy nobody has read is also one of the weakest things you can put in a plan, because it is trivially easy to write and proves nothing. |
| Collecting health data on individuals | Nothing in the duty requires you to know who in your workforce has menopause symptoms. Collecting that against named employees creates a UK GDPR Article 9 problem you do not need. |
| An occupational health referral scheme | Useful in some organisations, irrelevant in others. It is an action you might select, not a baseline expectation. |
| Reporting a menopause pay gap | You report your gender pay gap as you already do. There is no separate menopause pay figure to calculate. |
Where the guidance is still unclear
Two points are genuinely unresolved, and if either affects you it is worth forming a position now and writing down the reasoning. A documented decision made in good faith reads very differently from silence.
- Whether the obligation attaches per legal entity or per company group. The threshold is counted per entity, following the gender pay gap model. But a group running one workforce across several entities will struggle to explain publishing for one and not the others.
- How often a plan must be refreshed and what counts as a material change. Annual publication is the working assumption given the gender pay gap cycle, but what triggers an out-of-cycle update is not spelled out.
Both are the kind of gap where the safest position is the one you can evidence. If you have a baseline and a review date in the document, an argument about timing is a much smaller argument.
What to do before spring 2027
The plan itself is a short document and can be written in an afternoon. What cannot be written in an afternoon is the first step: understanding the issues in your organisation. That needs data your employees have to give you voluntarily, and mostly they will not.
- Establish a baseline now, while publication is still voluntary. A finding you can date to 2026 is worth more than one dated the month before the deadline.
- Run a menopause risk assessment per work area, not per site.
- Find out whether the provision you already fund is reaching anyone. Most employers cannot answer this, and it is the single most useful number in the whole exercise.
- Write the plan from what you found, and keep the baseline so you can remeasure against it in 6 or 12 months.
Summ Signal does the first and third for you, self-serve, and gives you the evidence the second needs. We are not a menopause provider, we sell your employees nothing, and we take no commission from any provider we measure. That is why we can tell you when something you are paying for is not working.