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ESRS S1: Own Workforce · 2026-5010-final

Disclosure Requirement S1-9

Adequate Wages

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.

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Reviewed by Dr Ross Kurinko · Sustainability Reporting Trainer LRA educational guidance · Not issued or endorsed by EFRAG

To prepare this disclosure

4datapoints↓ 5claims to verify↓ 5evidence areas↓ 3report examples↓

Disclosure focus

This disclosure asks an organisation to explain whether the people it employs are paid enough to meet an adequate standard of living, and how it knows that. In practice, the report should show the approach used to assess pay, the parts of the workforce covered, and any gaps where pay has not yet been assessed or brought into line.

The practical focus is on coverage and consistency across the organisation, not just on a few well-paid or flagship sites. Readers should be able to see whether the assessment applies across countries, business units and worker groups, and whether any differences in pay practices are linked to location, role or employment type.

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.

Have you decided which parts of the workforce are included in this check, and which countries you will cover? Have you settled the pay benchmark you will use for the comparison, and is it the same basis across the countries in scope? Have you confirmed the cut-off date or reporting period for the figures, so the comparison is taken from one consistent point in time? Can you trace the headcount and pay data back to a source you can explain, rather than relying on an estimate? Have you agreed how you will identify anyone paid below the chosen benchmark, and how you will calculate the share of workers affected?

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner

Adequate wage flag Record whether the organisation has checked if pay meets the chosen adequacy benchmark for the reporting population and period, and whether the result is yes or no. Pay review output, wage benchmark calculation, HR or payroll summary, and the documented basis for the yes/no conclusion. Reward / HR analytics

Wage benchmark basis Capture the specific benchmark or reference point used to judge pay adequacy, including the named source and how it was applied. Benchmark policy note, external reference document, internal methodology paper, or board-approved pay standard used for the assessment. Reward / sustainability reporting

Affected countries List the countries where the pay adequacy check was carried out and where the result is relevant for reporting. Country-level payroll extracts, entity mapping, and the consolidated reporting workbook showing which locations were included. HR operations / finance

Below-threshold share State the percentage of employees whose pay falls below the selected adequacy threshold for the reporting scope and period. Headcount by pay band, threshold calculation, and the working paper showing the numerator and denominator used for the percentage. HR analytics / payroll

＋ Show S1-9 sub-elements (LRA working checklist)

How to prepare it

1Set the reporting boundary first: identify which parts of the business, which worker groups, and which countries are in scope for this wage assessment, so you know exactly where the check applies.

2Agree the comparison basis before you calculate anything: choose the pay reference or external yardstick you will use, and define the threshold that will be used to test whether pay is sufficient.

3Gather the underlying records: pull together payroll data, headcount information, country coverage, and any other source material needed to support the assessment and the percentage calculation.

4Work through the result for each relevant country: determine whether pay meets the chosen benchmark, and calculate the share of employees who fall below the threshold where that applies.

5Prepare the disclosure package in a clear format: record the yes/no outcome, name the benchmark used, list the countries affected, and state the percentage figure with enough context to make it understandable.

6Document any scope decisions or changes, then check the final wording and figures against the official source to confirm the submission matches the underlying requirement and nothing material has been missed.

Request the data

Request the pay-benchmark data and below-threshold headcount

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

Are our people paid at or above the pay floor we use, and if not, where and for whom does the gap sit?

Use your organisation’s own pay and reward language first, then map it to the reporting fields below. For example, if you talk about salary bands, pay floors, living-pay checks or local market benchmarks internally, use those terms in the request and only translate them into the reporting labels when you prepare the return. Check the source material before sign-off.

Weak request

Please provide the ESRS S1-9 adequate wages data, including whether we meet the benchmark, the benchmark used, countries affected, and the percentage of employees below threshold.

Why it fails: It uses framework language that many internal owners will not recognise, and it does not tell them which internal report, population, or counting basis to use. That makes the return harder to prepare and easier to misread.

Better request

Please send the latest pay-floor review extract for [period], showing the benchmark used, the countries or sites included, the headcount and share of people below that benchmark, and the report or system the figures came from. Use our internal pay and reward terms in the return, and add any scope or assumption notes.

Formal email template

Subject: Request for pay-benchmark data for [reporting period]

Hi [name/team],

Could you please share the latest extract for the pay review covering [reporting period]?

We need the following, using our internal pay and reward terms where possible:
- the benchmark used for the review;
- the countries or locations included;
- the number and share of employees paid below that benchmark;
- the population and counting basis used;
- the source system or report used to produce the figures.

Please include any notes on scope, exclusions, or assumptions, and confirm who reviewed the numbers before they were sent.

A possible LRA training template is attached below for reference only. Please adapt this to your organisation and check the source material before sign-off.

Thanks,
[preparer name]

Short Teams / Slack version

Hi [name] — could you send the pay review extract for [period]?

Please include the benchmark used, the countries covered, and the number/share of people below that benchmark, plus the source report and any scope notes.

Use our internal pay/reward terms in the return where possible. Please adapt this to your organisation and check the source material before sign-off.

Thanks

Industry examples

Retail / Distribution

Context. A business with stores, depots and a head office wants one return across different pay structures.

Adapted request. Please share the pay-floor review for [period] across stores, depots and head office. Include the local benchmark used in each country, the number and share of colleagues below that floor, and the payroll or reward report used to build the figures. Please separate store, depot and office populations using our usual workforce labels.

Example response. Country: UK; Workforce group: Store colleagues; Benchmark: local living-pay check; Employees in scope: 4,820; Employees below benchmark: 96; Share below benchmark: 2.0%; Basis: headcount; Source: payroll extract v3; Notes: excludes seasonal staff.

Manufacturing

Context. A plant-based employer needs the data split by site and worker group.

Adapted request. Please provide the wage-floor review for [period] by site. Use our site and shift-worker labels, and include the benchmark used, the number and share of employees below it, and the system extract used for the analysis. Flag any sites where the pay floor differs by country or collective arrangement.

Example response. Country: Spain; Site: Valencia plant; Workforce group: Production operators; Benchmark: statutory minimum; Employees in scope: 1,140; Employees below benchmark: 0; Share below benchmark: 0.0%; Basis: headcount; Source: payroll and site roster; Notes: no exceptions identified.

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

Explain which pay benchmark was used, how the organisation defined the adequacy test, which countries were included, and how the below-threshold share was calculated.

Context note

Set out what the figures mean in practice by linking the chosen benchmark to the countries affected and the proportion of employees whose pay falls below it.

Fluctuation statement

If the figures changed, note whether that reflects a different benchmark, a change in the countries covered, or a shift in the share of employees below the threshold.

Content index entry

S1-9 Adequate Wages — [location / page] / [notes]

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Preparation tools & forms

Professional preparation tools for S1-9 — 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.

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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 · S1-9

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.

Explore the ESRS / CSRD course →

Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check

We used a wage comparison basis that we believe is fit for purpose across the countries in scope, and we checked that the benchmark set we relied on meets the minimum screening criteria we applied for both EU and non-EU locations.The benchmark may be incomplete, outdated, or not suitable for one or more countries, which could make the comparison unreliable.Benchmark methodology note; source documents for each benchmark; country-to-benchmark mapping; date of last update; internal review showing the criteria applied and why each benchmark was accepted.

For the calculation, we started from the lowest pay received by employees in the relevant population, left out interns and apprentices, added only the fixed pay elements that are guaranteed, and used the comparison level that matches the country or sub-national area concerned.The calculation basis may be inconsistent across locations or may include/exclude the wrong pay elements, leading to an overstated or understated result.Payroll extracts; calculation workbook; definition of included pay elements; population filters showing interns and apprentices excluded; country or regional mapping logic; reviewer sign-off on the calculation approach.

We have identified which wage benchmark applies in each place and can show how each benchmark was assigned to the countries covered by the figure.A benchmark may have been applied to the wrong country, or the mapping may be too broad or too narrow for the disclosed locations.Benchmark-to-country mapping table; rationale for each assignment; list of countries and any sub-national areas used; management review notes; version-controlled mapping file.

Where our review found employees below the wage threshold, we recorded the relevant countries and calculated the share of employees affected for each one.The affected-country list or percentages may be incomplete, based on the wrong denominator, or not traceable to source data.Exception analysis by country; headcount denominator used for each percentage; payroll and HR data extracts; calculation checks; evidence of review of outliers and edge cases.

Based on the checks we completed before publication, we concluded that not every employee is paid at the level we regard as adequate.The statement may be unsupported if the underlying analysis is partial, if the population is misstated, or if the conclusion is not consistent with the evidence held.Final assurance pack; reconciliation between payroll and reported population; sign-off memo; exception log; evidence of pre-publication review and approval; supporting schedules for the conclusion stated.

Evidence pack to prepare

The governing policy or written commitment behind this disclosureA methodology / definition note setting out how the disclosure was scoped and preparedSource-system exports the figures or facts were drawn fromThe internal approval / sign-off record for the disclosure before publicationMinutes or records evidencing the relevant engagement or consultation

Common reporting gaps

The information is presented without a date or as-at point.The scope or boundary of the statement is left undefined.Key terms are used inconsistently across the report.Material changes since the previous period are not disclosed.Assertions are made without supporting detail or a source record.Boilerplate is used that does not actually answer what is asked.

Common gaps

Mistakes to avoid when collecting the data

Wrong owner asked

The team goes to the wrong business owner, so the answer comes from someone who does not hold the payroll or local pay data.

Framework terms used instead of local language

People ask for the information in ESRS-style wording, and the organisation cannot map that request to its own pay, HR or country reporting terms.

Scope not pinned down

The data pull starts before the team has fixed which workforce groups, entities or countries are in scope, so the figures end up covering the wrong population.

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Where judgement is often needed

Choosing the pay yardstick where local practice differs

Pick one benchmark for each country on a consistent basis, explain why that measure best fits the local context, and keep the same approach unless a change is clearly justified and described.

Handling countries with more than one plausible benchmark

If several local reference points could be used, state which one you selected, why it was preferred over the alternatives, and whether the same choice was applied across all affected locations.

Deciding who counts in the headcount

Set out the employee population included in the calculation, explain any exclusions or borderline cases such as recent joiners, leavers, part-time staff or workers on leave, and keep the scope aligned with the way the figures were built.

＋ Show 6 more

Examples

Illustrative examples

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

Illustrative (synthetic) example — Apparel manufacturing

We assessed whether our pay floor in each country meets the relevant living-wage benchmark, and the result is **yes** for this reporting period. - We used the **Anker reference** as the comparison point. - The countries where this check was relevant were **Bangladesh, Vietnam, and Romania**. - Across those locations, **1,200 of 15,000 employees** were paid below the benchmark, which is **8%**.

This is a made-up example for training only. It shows how to describe the pay-floor check, the benchmark chosen, the countries in scope, and the share of employees below that level without naming any real organisation.

Illustrative (synthetic) example — Food processing

Our review found that our pay arrangements do **not** yet meet the chosen living-wage reference in every country covered by the assessment. - We compared pay against the **MIT living wage estimate**. - The countries included were **Mexico, Poland, and South Africa**. - In those locations, **540 of 9,000 employees** were below the benchmark, equal to **6%**.

This is a fictional training example. It demonstrates a plain-language way to state the outcome of the wage check, identify the benchmark, list the affected countries, and report the proportion of workers below the threshold.

Company reportsReal published reports

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How companies report S1-9 in practice

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

Continental AG

Tires · Germany · 2025

Open report →

Continental AG’s 2025 Annual Report provides data on employee remuneration, showing that 0% of own employees were paid below an adequate wage in both 2024 and 2025, and reports a gender pay gap of 2.9% in 2025 compared to 22.9% in 2024 (p.183). The report includes some workforce metrics such as headcount by gender and age group (p.181) and mentions safeguarding human rights in the workforce, though specific details or additional narrative on this topic are not found (p.182, p.193). There is no further quotable evidence related to other aspects of the disclosure in the report.

Covivio

Real Estate · France · 2025

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Covivio’s 2025 Sustainability Report references various workforce-related standards and disclosures, including S1‑15, 3.3.1.4, 401‑3, and others, indicating some alignment with recognised sustainability frameworks (p.189). However, the report does not provide any quotable narrative or detailed data on the specific disclosure in question, as no substantive evidence was found within the report. Additionally, numerical data present on page 65 appears unrelated or insufficiently explained to clarify the disclosure, leaving key information missing or unclear.

Amadeus IT Group, S.A.

Hotels, Restaurants, Leisure, Tourism Services · Spain · 2025

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Amadeus IT Group, S.A.'s 2025 Non-Financial Report provides detailed workforce data, including headcount by geographical area and employee characteristics such as gender, age, and professional category (pp. 26, 190, 212). It also covers workforce distribution across over 100 offices worldwide and includes information on collective agreements by country (pp. 26, 195). However, the report does not contain any direct narrative or quotable evidence specifically addressing the disclosure topic, and there is no explicit discussion of related policies or outcomes.

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Scenarios to work through

A group has payroll data for three countries. In one country, a local benchmark is used to test pay levels, and a small set of staff are still below that benchmark after allowances are counted.

QShould the preparer mark this as a positive or negative result for the pay-level check, and what supporting details need to be captured alongside it?

Reveal model answer →

A company operates in two countries and uses different local reference points to assess whether pay is at an acceptable level. One country clears the test, while the other does not, but the team is unsure whether to report only the shortfall country.

QShould the preparer list only the country with the shortfall, or all countries covered by the assessment?

Reveal model answer →

HR has a pay review showing that all employees in a single country are above the chosen wage benchmark. The team wonders whether the percentage field can be left blank because there are no workers below the line.

QHow should the preparer handle the percentage field when nobody is below the benchmark?

Reveal model answer →

A preparer has two possible reference points for the same country: a statutory minimum and an internal living-cost estimate. The team used the internal estimate for the review, but a manager wants the lower statutory figure shown because it makes the result look better.

QWhich benchmark should be disclosed, and how should the preparer decide what to show?

Reveal model answer →

Framework references