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ESRS S1: Own Workforce · 2026-5010-final
Disclosure Requirement S1-12

Training

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 supports the training and development of its own workforce. In practice, the report should show what learning opportunities are available, who can access them, and whether they are designed to help people do their jobs safely and effectively, build skills, and progress in their roles.

The practical focus is on coverage and consistency across the workforce, not just a few showcase programmes. A useful report should make clear whether training is available across different sites, functions and worker groups, how participation is managed, and whether there are gaps between what is offered and what people actually receive.

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
Employee review coverage The share of employees included in the review, with the numerator and denominator clearly defined and the period covered. HR or performance review records, review completion reports, and the calculation file used to derive the percentage. HR / People team
Training hours total The full number of training hours delivered in the reporting period, using one consistent basis for all sessions and participants. Learning management system exports, attendance logs, course records, and the roll-up calculation supporting the total. Learning and Development
Average training per employee The average training hours per employee, together with the employee count used in the calculation and the period covered. The total training-hours calculation, the employee population file, and the working paper showing how the average was derived. Learning and Development / HR
+ Show S1-12 sub-elements (LRA working checklist)

How to prepare it

1Set the reporting boundary first: decide which employees are included in this disclosure and keep that scope consistent across the figures and narrative.
2Agree the definitions you will use for the three required items: the share of employees covered by the review, the total learning time recorded, and the average learning time per employee.
3Gather the underlying records that support each item, such as the employee review list and the training logs needed to calculate the totals and the average.
4Calculate and assemble the reported outputs from the source records, making sure the percentage, the total hours, and the per-employee average all tie back to the same scope.
5Record any exclusions, adjustments, or changes in method so a reviewer can see why the reported population or numbers differ from earlier periods or internal working papers.
6Check the final disclosure against the official source to confirm you have covered every required item and have not missed any supporting detail or changed the intended meaning.
Request the data

Request the training review data from People Analytics

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

How many people were reviewed for training, and what training time was recorded for the reporting period?

Please use your organisation’s own terms first (for example, learning review, development check-in, skills review, course time, learning hours), then map them to the disclosure fields. Keep the wording in your internal language and check the official source before sign-off.

Weak request

Please provide the ESRS S1:S1-12 training metrics for the year, including the percentage of employees reviewed, total training hours, and average hours per employee.

Why it fails: This uses framework language that many operational teams will not use day to day, and it does not tell the owner what source, boundary, counting basis, or internal labels to use. It also leaves room for inconsistent interpretation of who is included and how time is measured.

Better request

Please send the learning review extract for [period] for [boundary]. We need the count of employees who had a learning or development review, the total learning time recorded, and the average time per employee, using your team’s own labels. Please include the source system, population covered, counting basis, time basis, and any exclusions or duplicates.

Formal email template
Subject: Request for training review and learning time data for [reporting period]

Dear [name/team],

Could you please provide the data needed for our sustainability reporting on employee learning for [reporting period]?

We need, for the agreed reporting boundary ([boundary]), the following in your own internal terms and source extracts where available:
- the number of employees who had a training or learning review during the period;
- the total learning or training time recorded for those employees; and
- the average learning or training time per employee.

Please also include:
- the system or file used;
- the population covered;
- the counting method used for people reviewed;
- the basis used for time recorded;
- any exclusions, duplicates, or missing records; and
- the name of the person who prepared the extract.

If helpful, please send this in a simple table. Adapt this to your organisation’s own language, and check the official source before sign-off.

Many thanks,
[Your name]
Short Teams / Slack version
Hi [name], could you send the training / learning data for [period] for [boundary]? We need: people reviewed, total learning hours/time, and average per employee, plus the source system and any notes on exclusions or duplicates. Please use your team’s own terms in the extract. Thanks.
Industry examples
Manufacturing

Context. A plant uses shift-based toolbox talks, mandatory safety refreshers, and role-specific machine training recorded in a local learning log.

Adapted request. Please share the training log for [period] for the plant and support teams. We need the number of employees who had a learning review, total recorded training time, and average time per employee. Please use your site terms, and include the log source, shift coverage, and any sessions that were cancelled or repeated.

Example response. The site learning log shows 428 employees reviewed, 1,964 total training hours, and 4.6 hours per employee. Source: site learning tracker. Coverage: plant and maintenance teams. Two cancelled sessions were excluded; duplicate entries were removed.

Professional services

Context. A firm tracks mandatory compliance modules, client-skills workshops, and coaching sessions in a central learning platform.

Adapted request. Please provide the learning platform extract for [period] across the firm. We need the number of staff who completed a learning review, total learning time, and average time per person. Please include the platform name, business units covered, your completion rules, and any manual adjustments.

Example response. The platform extract shows 1,250 staff reviewed, 7,500 total learning hours, and 6.0 hours per person. Source: central learning platform. Coverage: all UK entities. Completion counted once per person per module; one duplicate enrolment was removed.

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 how you defined the employee population, how you counted those included in the review process, and how you calculated total learning time and the per-person average.

Context note

Explain what the review coverage percentage and training figures indicate about how widely employees were assessed and how much development time was recorded overall and per person.

Fluctuation statement

If the figures move materially, note whether the change reflects a wider or narrower review reach, more or fewer training hours, or a shift in the average time per employee.

Content index entry
S1-12 Training — [location / page] / [notes]
Download Centre

Preparation tools & forms

Professional preparation tools for S1-12 — 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
Go deeper · S1-12
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 calculated the coverage figure from the training activity we could evidence for the period, using our own employee count as the denominator and the recorded training time as the numerator.The assurer may test whether the calculation basis is consistent, whether the employee population used is the right one for the period, and whether any training time was omitted, double-counted, or included without support.Calculation workbook; source training records; employee headcount extract for the reporting period; methodology note showing the numerator and denominator used; reconciliation from raw records to the published figure.
We limited the figure to the workforce group we intended to report on and applied the same scope rule throughout the dataset, so the published percentage reflects one consistent population.The assurer may probe whether the scope was set before calculation, whether exclusions or inclusions were applied consistently, and whether the reported population matches the underlying records.Scope memo; population definition used for the metric; HR extract showing included and excluded employees; audit trail of any adjustments; sign-off confirming the scope applied before publication.
We relied on source records from the reporting period and checked the underlying data for obvious gaps, duplicates, and mismatches before finalising the number.The assurer may question data completeness, accuracy, and whether the figure was built from reliable source data rather than estimates or partial records.Training attendance logs; learning system export; performance review tracker; data quality checks; exception log; evidence of follow-up on missing or inconsistent entries.
We kept evidence that links the published figure back to the original records, so the calculation can be traced from the final number to the source files.The assurer may test whether the audit trail is complete enough to support the reported figure and whether the evidence retained is contemporaneous and traceable.Version-controlled calculation file; source system extracts; supporting documents for any manual entries; change log; approval trail; retention of the files used in the final calculation.
Before publication, we reviewed the result for reasonableness against prior periods and internal expectations, and we resolved any unusual movements or data issues we found.The assurer may probe whether pre-publication checks were substantive, whether anomalies were investigated, and whether the final disclosure could be misleading because of unresolved issues.Reasonableness review notes; prior-period comparison; variance analysis; issue resolution records; management review or approval evidence; final sign-off confirming no outstanding data concerns.

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
Chasing the learning team alone can miss the people who hold headcount, payroll, or local training records, so the figures come from the wrong source.
Framework language, not business language
Asking for the data using disclosure labels instead of the organisation’s own terms can leave teams unsure which course lists, HR fields, or finance reports to pull.
No clear boundary
If you do not define which entities, countries, and worker groups are in scope, different teams may count different populations and the totals will not match.
+ Show 5 more

Where judgement is often needed

Choose the employee population before calculating the review rate
Set out which people sit in the training population for the year, explain any exclusions or inclusions at the margins, and keep the same basis when you compare periods unless a change is clearly described.
Decide how to handle business bought or sold during the year
State whether people who joined or left through acquisitions, disposals or similar changes are counted only for the time they were in the group, and explain any restatement or non-restatement of earlier figures.
Use one practical rule where local job categories do not match
If country-level role labels or worker groupings differ, map them to a single internal approach for reporting and disclose the rule used so readers can see how the numbers were made comparable.
+ Show 6 more
Examples

Illustrative examples

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

Illustrative (synthetic) example — manufacturing

We reviewed 78% of our workforce during the year, covering 390 of 500 employees. Those reviews took 1,560 training hours in total, which is an average of 3.2 hours per employee reviewed.

Synthetic illustration only. This shows how to present the share of employees reviewed, the total time spent, and the average time per reviewed employee in a single quantitative disclosure.

Illustrative breakdown of employee review activity (people)
Headcount390110
Illustrative (synthetic) example — consumer goods

We covered 62% of our staff in the period, equal to 248 of 400 employees. The related learning time came to 744 hours overall, or 3.0 hours for each employee included in the review.

Synthetic illustration only. This example combines the proportion of staff covered, the total hours delivered, and the average hours per person covered.

Illustrative breakdown of employee review activity (people)
Headcount248152
Company reportsReal published reports
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How companies report S1-12 in practice

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

Acciona, S.A.
Electric Utilities / IPP / Energy Traders · Spain · 2025
Open report →
Acciona’s 2025 Sustainability Report provides data on employee participation in performance and professional development appraisals, reporting rates of 97% for women and 94% for men, alongside average training hours of 16.9 for women and 25.2 for men (p.231). The report also mentions consolidated training hours in occupational risk prevention, with 519,279 hours in 2025 (p.247), and references ongoing internal training programmes for recruiters (p.213). However, the report does not clearly disclose a specific numeric value for the overall training or appraisal metrics beyond these segmented figures, and some related narrative items remain unclear or not fully detailed (p.231).
Aena S.M.E., S.A.
Air Transportation — Airport Services · Spain · 2025
Open report →
Aena S.M.E., S.A.'s 2025 sustainability report provides detailed numeric data on employee training, including total training hours by professional category (p.311) and investment in employee training and development programmes by country, with figures for Spain, the United Kingdom, and Brazil (p.304). The report also includes data on employee training related to occupational health and safety across these countries (p.306). However, there is no quotable narrative evidence found in the report to provide context or explanation for these figures.
GEA Group Aktiengesellschaft
Electrical Equipment and Machinery · Germany · 2025
Open report →
GEA Group Aktiengesellschaft’s 2025 Annual Report provides a numeric value for the total workforce as of December, reporting 19,531 employees on page 155. The report also includes data on average training hours per employee, with figures such as 10.3 hours for males and 9.6 hours for females detailed on page 168. However, no clear narrative explanation or additional qualitative information related to the disclosure was found in the report.
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Scenarios to work through

A group of 240 staff completed a learning programme during the year, but the HR report only shows the total course hours and does not say how many people were included in the review. The team also has a separate spreadsheet for managers and another for the rest of the workforce.

QHow should you decide whether the headcount figure is ready for disclosure, and what should you do if the split records do not cover everyone in the same way?
Reveal model answer →

A company recorded 1,860 training hours for the year across 310 employees. The draft note shows the total hours, but the average per employee has not been calculated, and one business unit wants to exclude induction sessions because they were short.

QShould the average be based on all recorded training time, and how do you handle the calculation if some sessions are not part of the training total?
Reveal model answer →

A preparer has a report showing 420 staff reviewed for learning needs out of 500 employees, with 2,100 total hours and an average of 5.0 hours per employee. A later payroll update shows that 12 people joined mid-year and were included in the hours, but the review count was not updated.

QDo you keep the draft as it is, or do you revisit the figures before finalising the disclosure?
Reveal model answer →

A business unit can show course attendance logs for 180 employees and a separate learning-platform export with 900 hours. However, the logs do not identify whether the same people appear in both records, and the average per employee has been estimated by dividing hours by the full headcount of 260 without checking.

QCan you rely on the estimate, or do you need more evidence before you publish the training figures?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

ESRS
S1-12
within ESRS S1: Own Workforce
Open official source →
Primary
Related & explore
Go deeper · S1-12
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 S1-12 ESRS Own Workforce, what data do I need to prepare before drafting the disclosure?+
How do I use the S1-12 step-by-step preparation section in practice?+
What should I include in the S1-12 evidence pack for assurance readiness?+
What are the five assurance claims I need to verify for S1-12?+
What are the common reporting gaps or mistakes for S1-12 Own Workforce?+
How do I use the S1-12 workbook download to prepare the disclosure?+
What is the printable S1-12 Library Card PDF for?+
How should I turn the S1-12 data into a draft narrative?+
Does the S1-12 page give an example disclosure I can copy structure from?+
Where can I find real company report examples for S1-12 Own Workforce?+
More questions this page can help with
S1-12 ESRS Own Workforce: what are the minimum datapoints to collect before I start drafting?How do I set ownership for S1-12 Own Workforce data between HR, ESG and finance?What evidence should I keep to support S1-12 employee review coverage and training metrics?How do I check whether my S1-12 training hours and average training per employee are internally consistent?What should I look for in the S1-12 common mistakes section before submission?How do I use the S1-12 narrative starters to write a first draft quickly?What is included in the S1-12 Prep & Assurance workbook download?Can I use the S1-12 illustrative example table as a template for my own disclosure?How do I build an assurance-ready evidence pack for S1-12 Own Workforce?Where does the S1-12 page point me for real published report examples?How do I avoid overclaiming in the S1-12 draft output section?What is the best way to use the S1-12 content-index line in a report draft?
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