Menstruation 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 .

    Menstruation is a normal part of working life for a large part of the workforce, and it is almost never mentioned in governance documents. The result is that practice becomes personal: some people get to swap a shift, others do not, and anyone who needs something has to explain why. That is a governance problem before it is a health question — and it is solved in the text that decides what happens.

    The conditions, not the body

    What makes a menstruation day hard at work is rarely menstruation alone. It is the distance to the toilet, a break that cannot be moved, no supplies available, a uniform that will not survive an accident, or a shift swap that requires an explanation to someone who decides your pay. All of those are conditions the employer designs.

    Arrangements that work because nobody has to request them

    Free supplies in the toilets, in the same way as soap and paper. Toilet access from the working position without having to find cover. A break that can be taken when needed. Shift swaps with no reason required. Dark or spare uniform items available. None of these need a form, a conversation or a record.

    Menstrual leave: what the question is really about

    The debate about menstrual leave or a dedicated absence scheme is political and runs differently across countries. For an employer today it is more useful to look at self-certified absence and flexibility: if a day at home requires a reason that in practice becomes health information, the organisation has built a recording duty it does not need. An arrangement that requires no reason solves the wellbeing problem and the data protection problem at once.

    Where governance documents stay silent

    Most health and safety handbooks say nothing about this. What exists tends to sit as an individual case: the employee gets in touch, the manager decides, and something is written in a note. That is the most expensive and most privacy-heavy route to an outcome that could have been a routine available to everyone.

    Data protection: keep it at system level

    Menstruation is health information once it is linked to a person, and health information is a special category of personal data under GDPR Article 9. A routine designed to avoid turning documentation into personal data describes what is available and how it is triggered — and says explicitly that no reason is to be recorded.

    Guidance alongside legal requirements

    ISO 45010:2026 offers guidance on menstruation and menopause at work and was published on 7 September 2026. It is a guidance standard and cannot be certified against. We use it to decide what is worth describing, not as a checklist to tick.

    One document, three findings

    Send in the routine you already have — breaks, uniforms, self-certified absence, shift swaps — and get up to three areas for improvement with reference to relevant legal requirements plus one suggested rewrite. Free, and with no employee involved.

    Check one routine — free

    One governance document reviewed free of charge. We read the document, never employees. The document must not contain personal data.

    Sources

    Frequently asked questions

    Does an employer have to provide menstrual products?
    In most EEA countries there is no explicit legal duty. Many organisations do it anyway, for the same reason they provide soap and paper: it is cheap, it removes a barrier, and it needs no record.
    Is a period policy the same as menstrual leave?
    No. A policy describes what is available and how it is triggered. Menstrual leave is one possible element and is regulated differently country by country. Most of the value lies in access, breaks and flexibility.
    Can we require a reason for an absence day?
    Be careful. As soon as the reason becomes health information it is a special category of personal data. Self-certified absence without a stated reason is both simpler and safer.
    Should this sit in the health and safety handbook or the staff handbook?
    In the health and safety structure, as part of working-environment work. Then it connects to hazard identification, measures and review rather than becoming a perk with no owner.
    What about small organisations with no health and safety function?
    Three sentences in an existing routine are enough: what exists, that no reason is required, and who owns it. The requirement is that governance exists in writing, not that it is long.

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