The CCLA UK Corporate Mental Health Benchmark 2025 found that 60% of the UK’s largest listed employers fail to assign clear day-to-day responsibility for mental health: only 40% do. That finding deserves more attention than it gets. It is not a measurement of malicious intent. It is a measurement of structural failure: organisations that have genuine commitment to employee mental health but have not built the governance infrastructure to deliver on that commitment.
The difference between having a policy and operationalising one
The CCLA benchmark does not ask whether UK employers care about mental health. Most do. It asks whether they have translated that care into measurable board-level governance: named accountability, data infrastructure, review cycles and mechanisms for connecting board commitment to employee experience. Most have not.
The typical large employer has a mental health policy, an employee assistance programme, a mental health awareness week presence and perhaps some MHFA-trained employees. None of these, individually or together, constitute governance. They are inputs. Governance asks what changed as a result of those inputs. How has absence due to work-related stress trended over the past 12 months? Has psychological safety in the organisation improved? Are managers confident enough to have mental health conversations? What is the board doing differently as a result of what the data shows?
For most organisations, there are no good answers to those questions. And without answers, there is no governance.
60% of the UK’s largest listed employers fail to assign clear day-to-day responsibility for mental health. Policy exists. Delivery mechanisms typically do not. CCLA UK Corporate Mental Health Benchmark, 2025
The governance gap has real costs
A mental health strategy that is not operationalised produces three predictable outcomes. The first is continued absence. Without a governance structure that connects strategy to manager behaviour to employee experience, absence rates attributed to stress and mental health continue to climb regardless of what the board has committed to.
The second is talent attrition. Employees who experience poor management of mental health issues at work leave. They often cite their manager, not the organisation’s policy, as the reason. If the manager layer has not been equipped to deliver the organisation’s mental health commitments, the gap between policy intent and employee experience produces turnover that no retention programme can fully offset.
The third is reputational risk. In a transparent labour market where employee experiences are shared publicly, the gap between an organisation’s stated commitment to wellbeing and the actual experience of working there is increasingly visible. The organisations that have genuinely operationalised their commitments have a sustainable advantage. Those that haven’t carry a credibility gap that compounds over time.
Marking Mental Health Awareness Week, sharing resources in a company newsletter and running wellbeing webinars are all valuable. They are not a substitute for governance. They satisfy the question “what do we do?” without answering the more important question “is it working?” Governance requires the second question to be asked and answered regularly.
Four elements that distinguish organisations with genuine MH governance
1. Named board-level accountability
Without a named individual at board or executive level whose performance is tied to mental health outcomes, accountability diffuses. It becomes everyone’s responsibility in the way that means it is no one’s responsibility. The individual doesn’t need to be a mental health specialist. They need to be senior enough to surface issues at the right level and accountable enough that results are tied to their role.
2. Outcome metrics, not input metrics
Most organisations track mental health inputs: the number of EAP calls made, the number of awareness sessions run, the number of MHFA-trained employees. These are activity measures. They do not tell you whether the organisation’s mental health has improved. Governance requires outcome measures: absence rates over time segmented by function and manager, employee psychological safety scores, voluntary turnover rates attributed to management or culture issues.
3. Manager capability as the primary delivery mechanism
The most consistently underinvested element of any mental health strategy is the manager layer. Board-level policy does not change employee outcomes. Manager behaviour does. The manager is the primary delivery mechanism for mental health governance. They are the ones who notice warning signs, have the early conversations, adjust workload conditions and signpost appropriately. If they lack the capability to do any of those things, the governance framework has no mechanism for producing change at the employee experience level.
The most impactful single investment in MH governance is usually not policy revision. It is training the managers who are actually responsible for the people.
4. A review cycle that closes the loop
A mental health strategy that is set once and reviewed once a year is documentation, not governance. An effective review cycle produces regular reporting of outcome metrics to the board, connects data to decisions about resource allocation and training investment, and surfaces problems early enough to act on. The cadence matters less than the consistency.
Before H2 begins is the right time to ask what was committed to and what the data shows. Most wellbeing strategies start the year with good intent and few measurement mechanisms. The mid-year review is the opportunity to close that gap before Q3 and Q4 repeat the same pattern.
Where to start if your governance is underdeveloped
Most organisations don’t need a comprehensive governance overhaul. They need to close one or two specific gaps. These are the most common starting points.
- If you have no named board accountability: identify who should own this outcome at the executive level and build it into their performance framework. This doesn’t require a policy change. It requires a conversation with the right people.
- If you have no outcome metrics: start with one. Absence rates attributed to stress and mental health, segmented by manager, is typically the most available data and the most politically useful in board conversations. Pull the last 12 months and trend it.
- If you have no manager capability programme: this is the highest-leverage gap to close. One half-day session for your manager cohort changes behaviour faster than any policy revision. Start with the managers whose teams have the highest absence or turnover data.
- If you have no review cycle: add a standing item to your next quarterly board or executive team meeting. Even 15 minutes on the key metrics is more governance than most organisations currently have.
Move your managers from policy to practice
Our Mental Health for Managers programme builds the management capability that makes board-level commitments land at the employee experience level.
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