Is a wellbeing policy a legal requirement in the UK?

There is no statute requiring a wellbeing policy by name, but the duties behind it are legal duties: the common law duty of care, the duty under the Health and Safety at Work etc. Act 1974 to assess risks including work-related stress, and the Equality Act 2010 duty to make reasonable adjustments for disabled employees. A written policy is how you evidence that those duties are being met.

What should an employee wellbeing policy include?

The employer's commitment and duty of care, the confidential routes to support including any employee assistance programme, what a manager should do when someone discloses a problem, how reasonable adjustments are agreed, how work-related stress is assessed against the HSE Management Standards, return-to-work arrangements, and how health information is kept under UK GDPR. Name the people responsible for each route — that is what makes it usable.

Is mental health a disability under the Equality Act 2010?

It can be. A mental impairment counts as a disability where it has a substantial and long-term adverse effect on day-to-day activities — long-term meaning it has lasted, or is likely to last, at least 12 months. Conditions that fluctuate or are in remission still count if they are likely to recur. Once you know, or ought reasonably to know, the duty to make reasonable adjustments applies whether or not there is a formal diagnosis.

What counts as a reasonable adjustment for mental health?

Common ones are a phased return, adjusted hours or start times, changes to workload or deadlines, a quieter workspace or homeworking, time off for therapy appointments, a change of line manager, and adjusted absence triggers. Reasonableness depends on the size and resources of the employer and the effectiveness of the adjustment — cost alone rarely justifies refusing a low-cost change.

How should health information from a wellbeing conversation be stored?

Health information is special category data under UK GDPR, so it needs an Article 9 condition — usually employment obligations — and tighter handling than ordinary HR notes. Record only what you need to manage the adjustment, keep it accessible to the smallest number of people who need it, store it separately from the general personnel file, and tell the employee what will be shared with their manager before you share it.

Reviewed by David White · Director · MCIPD, BA (Hons), MA Strategic HRM · Updated 17 August 2026

Templates · Word · HR Policies

Employee Wellbeing Policy Template (UK)

Free Word download for UK employers, written and reviewed by our HR team.

An editable Word wellbeing and mental health policy covering your duty of care, the routes employees can use to get confidential support, how managers should respond to a disclosure, reasonable adjustments under the Equality Act 2010 and how work-related stress is assessed against the HSE Management Standards.

What this policy covers

Your duty of care and the standard of support employees can expect
The confidential support routes available, including any employee assistance programme
How a manager should respond when an employee discloses a mental health problem
Reasonable adjustments under the Equality Act 2010, with practical examples
How work-related stress is assessed against the HSE Management Standards
Return-to-work and phased return arrangements after a mental health absence
How wellbeing data is handled under UK GDPR, since health data is special category data

When to use this policy

Adopt this policy when you launch an employee assistance programme or wellbeing support, or when your handbook has no written position on mental health and stress. Review it annually and after any significant restructure.

Putting the policy to work

1
Name the owner of each support route
A policy that says 'support is available' without naming who to contact does nothing on the day it is needed. Fill in every bracketed contact before publishing.
2
Assess work-related stress properly
The HSE Management Standards cover demands, control, support, relationships, role and change. Employers have a legal duty to assess the risk of work-related stress in the same way as any other workplace risk.
3
Treat mental health as a potential disability
A mental impairment with a substantial, long-term adverse effect on day-to-day activities is a disability under the Equality Act 2010, which triggers the duty to make reasonable adjustments. Fluctuating conditions still count.
4
Brief line managers separately
The policy only works if managers know what to do in the first conversation. Brief them on listening, on not diagnosing, on confidentiality and on the referral routes.
5
Review annually and after major change
Restructures, redundancy programmes and changes to working patterns are the times stress risk rises and the policy is most likely to be out of date.

How to complete it

Complete every bracketed field in Word, name the people who own each support route, then add the policy to your staff handbook and tell employees it exists. Brief line managers separately, since the policy only works if they know what to do on the day.

Common mistakes we see

Publishing the policy without briefing managers, so the first disclosure is still handled badly
Recording health information in general HR notes rather than treating it as special category data
Waiting for a formal diagnosis before considering adjustments
Treating stress as a personal resilience issue rather than assessing the work-related causes

Part of

This template is one letter inside a wider process. For end-to-end employer support, see Workplace Mental Health Support.

This template is provided for general use and does not constitute legal advice. If your situation is complex, contact one of our HR experts before sending or signing.