Menopause at work
Written by Nicolai Bjerknes Slinning, Founder, Sydera.io Technologies AS · Working Group Expert, ISO/TC 283/WG 6 and WG 10 · member of SN/K 551. Last reviewed .
Menopause is not an illness and not an HR problem. It is a life stage many employees are in at the same time, meeting working conditions that were usually designed without it in mind: temperature, shift patterns, breaks, access to water and toilets, sleep, concentration and predictability in rotas. This page is about what can be done in the governance layer — in the text that decides what happens — without anyone having to disclose anything about their own health first.
A working-environment question, not a medical one
Occupational health and safety law across the EEA requires work to be organised so that it does not cause undue physical or mental strain. That duty attaches to the conditions in the work, not to an individual diagnosis. When an employee going through menopause struggles at work, it is rarely because the body is changing — it is because the working conditions cannot absorb variation. A room that cannot be ventilated, a rota with no predictability, or a break culture where nobody leaves their post affects everyone who has a day that is not standard. Designing the work is the employer's responsibility whoever happens to be doing it.
What actually helps is usually mundane
Organisations that do this well tend to have unremarkable measures: local control of temperature, cold drinking water, breathable uniforms, a break that can be taken when needed rather than only at eleven, the option to swap a shift without stating a reason, and somewhere to rest. None of these require anyone to explain themselves. All of them are easier to run as a standard available to everyone than to assess case by case.
The distinction that keeps it safe: which level the arrangement sits at
Split what the employer does in two. What is available to everyone — temperature, breaks, shift swaps, uniforms, a rest space — is described in the governance document, and nobody needs to disclose anything about their health to use it. What genuinely requires an individual judgement is handled in a separate track with restricted access, and there the lawful basis must be identified before anything is written down. When everything is pushed into the second track, the organisation gets two problems at once: fewer people are helped, and the documentation holds information it should not have.
Where documents start too late
Four patterns recur when we read routines. The measure is triggered only once the employee takes the initiative and states a reason. The arrangement is described as an exception a manager may grant, not as something that exists. The follow-up form has a free-text field where a manager writes something about a named person's health. And nobody owns the arrangement — it sits with an unnamed function, with no date for the last review.
Individual adjustments come in addition, not instead
The statutory route to individual adjustment for reduced working capacity stands whatever else you do. The point is that it should not be the only way in. When an arrangement exists only as an individual case, the threshold becomes personal: you have to explain something private to someone who decides your pay. Most people choose not to, and the organisation loses both the work and the information. Arrangements available by default reduce that threshold to zero.
Guidance alongside legal requirements
ISO 45010:2026 offers guidance on menstruation and menopause at work, and ISO 45003 offers guidance on psychosocial risk. Neither is a requirements document, and neither replaces an assessment of your lawful basis under data protection law. Treated as guidance alongside relevant legal requirements they are useful. Treated as the answer key they become a recipe for holding information the organisation is not allowed to hold.
How to start with one text
Take one routine — rota planning, breaks, the working-environment chapter of the handbook — and read it with two questions. Does anything happen on its own, or only once a person explains themselves? And does the text require someone to record something about a named person's health for the routine to work? Where the answer to the second is yes, the measure can almost always move one level up. That is exactly the exercise we run in a free review.
One governance document reviewed free of charge. We read the document, never employees. The document must not contain personal data.
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Frequently asked questions
- Is a menopause policy a legal requirement?
- In most EU and EEA countries there is no rule requiring a document with that title. The duties are to organise work so it does not cause undue strain and to keep your internal control in writing. Many employers still write one, because it makes the arrangements visible and easier to use.
- Can we ask employees whether they are going through menopause?
- Better not to. That is health information and a special category of personal data. Build the arrangements so they can be used without anyone disclosing anything, and let each person choose what to share.
- What can we do at no cost?
- Breaks that can be taken when needed, shift swaps without stating a reason, cold drinking water, local temperature control, and one clear sentence in the routine saying the arrangements are available to everyone. Most of this is text and practice, not procurement.
- How do we document the work without writing about individuals?
- Describe the arrangement, not the case: what exists, for whom, how it is triggered, who owns it, and when it was last reviewed. All of that can be written without a single detail about a named person.
- What does the free review look at?
- We read one governance document and point to up to three areas for improvement with reference to relevant legal requirements, plus one suggested rewrite. We read the document, never employees, and the document must not contain personal data.