August 2026
The August note is about the split between system and individual: what Norwegian law requires of follow-up documentation, and how predictable needs are handled by default in your governing documents. Layer 1 is public regulation and is open. Everything is at system level — nothing is about individual employees.
LAYER 1 — WHAT YOU MUST DO (NORWEGIAN LAW)
No rule change — but supervisory practice makes this the most common silent risk in Norwegian governance systems: follow-up notes containing more health information than the law allows. The exposure sits in the templates, not in the intent.
Basis/source: GDPR Art. 9; WEA § 9-3
The checkpoint: do your templates ask for cause — or for functional needs?
The commission recommends that employers handle menstruation and menopause complaints systematically, not reactively. The direction is structural arrangements over individual exceptions — the same direction § 4-1 of the Working Environment Act already points. Organisations that already have system-level wording in their HSE policy are done before the guidance arrives.
Basis/source: NOU 2025:5; WEA §§ 3-1 and 4-1
The checkpoint: does the policy cover predictable needs by default — life phases, chronic conditions and accessibility — or are they handled as individual exceptions?
LAYER 2 — WHAT YOU HAVE CHOSEN (YOUR FRAMEWORKS)
The standard is under revision, and an updated edition is expected in 2027.
Basis/source: ISO 45001 — public revision status. ISO 45010:2026 was published on 7 September 2026, after this edition.
LAYER 3 — WHAT IT MEANS FOR YOUR POLICY
2 prioritised recommendations with legal basis and effort estimates are in the full edition.
Everything at system level. Nothing in a radar note is about individual employees.