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ESRS S1: Own Workforce · 2026-5010-final
Disclosure Requirement S1-6

Non-employees

Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official EFRAG source.

Dr Ross Kurinko, Sustainability Reporting Trainer
Reviewed by Dr Ross Kurinko · Sustainability Reporting Trainer LRA educational guidance · Not issued or endorsed by EFRAG
To prepare this disclosure
Disclosure focus

This disclosure asks an organisation to explain how it identifies and reports on people who work for it but are not its employees, such as contractors, agency workers or other non-employee labour. The focus is on showing which groups are included, how they are counted or described, and what information the organisation has gathered about them in relation to its own workforce and activities.

In practice, the main question is coverage: whether the reporting looks only at a few visible sites or flagship operations, or whether it covers the organisation’s wider operations and relevant parts of the value chain where non-employees are used. The organisation should be clear about the scope, the basis used to define these workers, and any limits in the information available.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official EFRAG source.

Before you start

A quick mental checklist before you prepare this disclosure — tick each as you settle it.

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner
Non-employee total Capture the total number of people working for the organisation who are not on its payroll, using the same population definition used in workforce reporting. Contractor register, agency labour reports, vendor invoices, site access lists, or a consolidated workforce count that excludes employees. HR / People Operations
Workforce measure basis State whether the figure is a headcount or an FTE-style measure, and keep that basis consistent with the underlying source data and reporting period. Reporting methodology note, HRIS extract, payroll summary, or workforce dashboard showing the chosen counting basis. HR Reporting / Finance
Workforce share Capture the percentage that this group represents within the relevant workforce total, using the same period and denominator used for the workforce count. Calculation workbook, workforce denominator schedule, or reporting pack showing the numerator, denominator and percentage formula. HR Reporting / ESG Reporting
＋ Show S1-6 sub-elements (LRA working checklist)

How to prepare it

1Set the reporting boundary first: decide which non-employee population you are counting for this disclosure, and keep that scope consistent across the figures you will report.
2Choose the counting basis you will use for the workforce measure, then apply it consistently as either a full-time equivalent approach or a simple headcount approach, as required by your source data.
3Gather the underlying records that support the total number, the workforce measure, and the share of workforce reported, so each figure can be traced back to a reliable internal source.
4Prepare the reported outputs in the format needed for each datapoint: the total non-employee figure, the workforce measure expressed on the chosen basis, and the percentage of workforce.
5Record any exclusions, scope changes, or methodological adjustments that affect the numbers, so readers can understand what was left out and why the reported figures changed.
6Check the final disclosure against the official source before publishing, confirming that the scope, counting basis, and reported figures align with the requirement and that nothing has been omitted or misstated.
Request the data

Request the non-employee population count and workforce share

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

How many non-employees did we have in the reporting period, and what share of the wider workforce did they represent?

Use your organisation’s own labels first, then map them to the disclosure. For example, ask for contractors, agency staff, consultants, gig workers, or other external labour categories only if those are the terms your business already uses internally. Keep the request in operational language and check the source data definitions before sign-off.

Weak request

Please provide the ESRS S1:S1-6 non-employee data for the disclosure.

Why it fails: It uses framework language only, gives no boundary, no counting basis, no internal category terms, and does not tell the owner what source or method to use. That makes the return hard to reconcile and hard to evidence.

Better request

Please send the external labour figures for [reporting period] and [boundary]: total count, whether the number is headcount or FTE, the internal category names included, the source system or file, the reference date or averaging method, and the workforce total used to calculate the share. Please add any inclusion or exclusion notes and use your organisation’s own terms.

Formal email template
Subject: Data request – non-employee count and workforce share for [reporting period]

Hello [name/team],

We are preparing the sustainability reporting pack and need the latest figures for our external labour population for [reporting period] and [boundary].

Please send:
- the total number of non-employees;
- the basis used to count them (headcount or FTE);
- the share they represent of the wider workforce;
- the internal category names included in the extract;
- the source system or file used;
- any inclusion/exclusion rules applied;
- the reference date or averaging method used;
- the denominator used for the workforce share.

If helpful, please return the information in the table format below and add any notes needed to explain the figures. Please adapt this to your organisation’s own terms, and check the source definitions before sign-off.

Many thanks,
[preparer name]
[team]
[contact details]
Short Teams / Slack version
Hi [name/team] — could you share the latest external labour figures for [reporting period] and [boundary]?

We need:
- total count
- headcount or FTE basis
- workforce share
- category names used internally
- source system/file
- any inclusion/exclusion rules
- reference date or averaging method
- denominator used for the share

Please use your usual internal terms and add any notes on the method. Thanks, [preparer name]
Industry examples
Manufacturing

Context. A plant uses agency staff, maintenance contractors, and specialist installers alongside direct staff.

Adapted request. Please share the plant’s external labour figures for [reporting period] and [site/boundary]: total number of agency staff, contractors, and other external workers; whether the figure is headcount or FTE; the workforce total used for the share; the source file or system; and any rules used to include or exclude people.

Example response. Agency staff: 42; contractors: 18; specialist installers: 6; total external labour: 66; basis: headcount; workforce total used for share: 1,320; share of workforce: 5.0%; source: site labour tracker; notes: excludes visitors and delivery drivers.

Retail / Logistics

Context. A distribution business uses temporary warehouse workers and outsourced security staff across multiple depots.

Adapted request. Please provide the external worker numbers for [reporting period] across [depots/region]: total count, headcount or FTE basis, internal labels used for temporary warehouse workers and outsourced services, the denominator used for the workforce share, and the source report used to compile the figures.

Example response. Temporary warehouse workers: 95; outsourced security staff: 14; total external workers: 109; basis: FTE; workforce total used for share: 2,180; share of workforce: 5.0%; source: workforce planning dashboard; notes: figures are averaged across the quarter and exclude agency office cover.

Draft your disclosure

Notes that turn data into a disclosure

LRA training templates — adapt them to your organisation, and check the official source before sign-off.

Method note

State whether the non-employee figure is built on full-time equivalent or headcount, and make clear that the percentage is calculated against the overall workforce total.

Context note

Explain what the numbers show about reliance on people outside the payroll, both in absolute terms and as a share of the wider workforce.

Fluctuation statement

If the figures move from one period to the next, link the change to shifts in the number of non-employees, the workforce total, or the measurement basis used.

Content index entry
S1-6 Non-employees — [location / page] / [notes]
Download Centre

Preparation tools & forms

Professional preparation tools for S1-6 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI-assistant.

Free · Community members
01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧
Go deeper · S1-6
Learn to prepare this disclosure end-to-end

This guide covers one Disclosure Requirement. The ESRS / CSRD Reporting course walks the full European workflow — double materiality, datapoints, evidence and assurance — with exercises on your own data.

Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.

Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check
We used a clear basis to estimate the non-staff count where direct counting was not possible, and we can show how that estimate was built.The assurer will test whether the estimate is supportable, whether assumptions were reasonable, and whether the method could have materially changed the figure.Working papers showing the estimation method, assumptions, source data, calculation steps, management review notes, and any sensitivity or reasonableness checks.
We explained the calculation choices and reporting approach because they affect how the figure should be read.The assurer will probe whether the chosen approach was applied consistently, whether alternative options were considered, and whether the explanation is enough for a user to understand the number.Draft and final disclosure wording, internal accounting or reporting policy, decision papers on the selected approach, and evidence of review by the preparer and approver.
We stated what share of our own workforce this group represents, and we can trace that percentage back to the underlying counts.The assurer will check whether the percentage is arithmetically correct, whether the denominator is appropriate, and whether the same population was used throughout.Calculation file showing numerator and denominator, source population data, reconciliation to the workforce base, and sign-off on the final percentage.
We disclosed the total number for this group and retained the records used to build that total.The assurer will test completeness, duplication, and whether the total includes the right people and excludes the wrong ones.Population listing, source registers or system extracts, inclusion and exclusion rules, reconciliations, and evidence of management review of the final total.
We chose a headcount-style approach or a full-time-equivalent approach for the total, and we can show why that approach was used.The assurer will examine whether the chosen basis matches the underlying data and whether it was applied consistently across the reporting period.Methodology note, policy or reporting guidance, calculation workbook, source data fields used for the chosen basis, and evidence of consistency checks.
We reported the figure using either a period-end snapshot or an average across the period, and we can show how that timing basis was applied.The assurer will test whether the timing basis is clearly defined, consistently applied, and suitable for the disclosed number.Reporting methodology, period-end or averaging calculations, source extracts for the relevant dates or periods, and review evidence confirming the selected timing basis.

Evidence pack to prepare

Common reporting gaps

Figures are stated without the supporting narrative, or narrative without figures.Scope is inconsistent between the text and the numbers.The reporting boundary is left undefined.Material changes since the previous period are not disclosed.Estimates and measured values are not distinguished.Source records for the figures are not identified.
Common gaps

Mistakes to avoid when collecting the data

Wrong owner
The count gets chased from the wrong team, so the person who actually tracks agency staff, contractors or other non-payroll workers is never asked.
Framework language instead of business terms
The request is sent using ESRS-style labels, which confuses local teams that only recognise their own job titles, supplier categories or site-level headcount reports.
Scope not pinned down
People start collecting figures before agreeing which non-payroll workers are in scope, so different teams include different groups and the final number cannot be reconciled.
＋ Show 6 more

Where judgement is often needed

Choose one counting basis and keep it consistent
Decide whether to count people as individual workers or convert them into full-time equivalents, explain the basis used, and keep the same approach across periods unless a change is clearly described.
Set a clear cut-off date for the population
Use one reporting date or period-end snapshot for the count, and if you include people who were in scope only for part of the year, say how they were brought into the total.
Define who sits inside the non-employee group
Where local labour practices or contract types differ by country, explain the practical rule used to decide which external workers are included and which are left out.
＋ Show 5 more
Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — Food manufacturing

: we report the number of people who are not on our payroll and show how they sit within our wider workforce. In this example, they are 48 out of 320 workers, which is 15% of the total.

Illustrative only; figures are internally consistent and shown as a share of the wider workforce.

Non-payroll workers within the workforce (people)
Non-payroll workers48
Other workers272
Illustrative (synthetic) example — Logistics and warehousing

: we set out the count of people working for us but not directly employed, alongside the size of the whole workforce. Here, 126 out of 840 workers are in that group, equal to 15% of our workforce.

Illustrative only; figures are internally consistent and shown as a share of the wider workforce.

Non-payroll workers within the workforce (people)
Non-payroll workers126
Other workers714
Company reportsReal published reports
Compare side by side →Get it free

How companies report S1-6 in practice

Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

Indra Sistemas, S.A.
Software and Services · Spain · 2025
Open report →
Indra Sistemas, S.A.'s Sustainability Report 2025 provides detailed employee metrics, including total workforce numbers from 2021 to 2025 (p.92) and breakdowns by contract type for 2024 and 2025, showing 60,907 and 62,396 employees respectively (p.94). The report also includes data on full-time employees by category and gender, indicating near 100% full-time employment in middle management across the years (p.265), as well as workforce distribution by country, with figures for Spain and Europe from 2021 to 2025 (p.259). However, no numeric or narrative evidence specifically addressing other aspects of the disclosure was found in the report.
Snam S.p.A.
Gas Utilities · Italy · 2025
Open report →
Snam S.p.A.'s 2025 Annual Report provides a numeric value for the total number of non-employee workers, reporting 135 and 105 respectively on page 366. The report also mentions workforce details such as total employees and some employment practices, including remuneration aligned with European standards (pp. 362, 365, 367, 481). However, there is no quotable narrative specifically addressing the disclosure beyond these datapoints, leaving some narrative elements unclear or missing.
Iberdrola, S.A.
Electric Utilities / IPP / Energy Traders · Spain · 2025
Open report →
Iberdrola’s 2025 Sustainability Report provides numeric data on total headcount expressed in full-time equivalents, with figures such as 45,400 and 42,208 reported on page 98. The report also includes employee coverage by representatives in Spain at 98% (p.89) and details on training and skills development metrics (p.90). However, no narrative explanations or qualitative descriptions related to these workforce disclosures were found in the report.
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Check your understanding

Scenarios to work through

Your people data team has counted 18 agency workers and 7 contractors who worked on site during the reporting period. The HR file also shows 120 employees on the payroll at year-end.

QHow should you present the non-employee figure, and what extra context do you need to add so the number is understandable?
Reveal model answer →

A facilities contract covers 12 cleaners, but only 9 of them worked at your sites during the reporting period; the other 3 were assigned elsewhere by the supplier. Your draft table currently includes all 12.

QShould the disclosure include all 12 people, or only the 9 who actually worked for you during the period?
Reveal model answer →

You have 80 employees and 20 non-employees. A draft note says the non-employee group is '20% of staff' because 20 divided by 100 equals 20%.

QIs that percentage basis acceptable, and what should you check before finalising it?
Reveal model answer →

Your group has 45 non-employees in total. Of these, 30 are agency workers and 15 are self-employed contractors. The draft narrative mentions only the total and leaves out the measurement basis.

QWhat should you add so the disclosure is complete enough for a reader to understand the number?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

ESRS
S1-6
within ESRS S1: Own Workforce
Open official source →
Primary
Related & explore
Go deeper · S1-6
Learn to prepare this disclosure end-to-end

This guide covers one Disclosure Requirement. The ESRS / CSRD Reporting course walks the full European workflow — double materiality, datapoints, evidence and assurance — with exercises on your own data.

Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.

FAQ

Questions this page answers

For S1-6 (ESRS S1: Own Workforce), what data do I need to prepare before I start drafting the disclosure?+
How do I work out the workforce measure basis for S1-6 on this page?+
What does the page mean by non-employee total for S1-6, and how should I collect it?+
How should I calculate or present workforce share for S1-6 using this page?+
What is the step-by-step process on the S1-6 page for preparing the disclosure?+
What evidence do I need to keep for S1-6 if I want the disclosure to be assurance-ready?+
How do I use the six assurance claims on the S1-6 page in practice?+
What are the common reporting gaps or mistakes for S1-6 that I should avoid?+
How can I use the Prep & Assurance workbook for S1-6?+
What should I take from the printable Library Card PDF for S1-6?+
How do I turn the S1-6 data into a draft disclosure on this page?+
More questions this page can help with
S1-6 ESRS S1 Own Workforce: what should I collect first before drafting the disclosure?S1-6 own workforce disclosure: how do I use the step-by-step preparation section?S1-6 non-employee total: what source data should I look for?S1-6 workforce share: how do I make sure the numbers are internally consistent?S1-6 assurance-ready evidence pack: what should be in it?S1-6 common mistakes: what do reviewers usually miss?How do I use the S1-6 Prep & Assurance workbook and Library Card together?What does the S1-6 illustrative example show me about the final disclosure format?How can an HR data owner support the S1-6 disclosure using this page?How can an assurance reviewer use the S1-6 claim-risk-evidence checks?What narrative starters are available for the S1-6 draft output?Where can I find real company report examples for S1-6 on this page?
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