Disclosure focus
This disclosure asks an organisation to explain how it covers its own workforce with social protection arrangements. In practice, that means describing whether employees and other workers in the workforce have access to protections such as social security or equivalent benefits, and whether that coverage is provided consistently across the organisation’s operations and locations.
The practical focus is not just on whether a policy exists, but on how far it reaches in reality. Report whether coverage applies to the whole workforce or only certain groups, countries, sites, or contract types, and make clear any gaps, exclusions, or differences in treatment that affect who is protected and where.
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
＋ Show S1-10 sub-elements (LRA working checklist)
Identify the countries where no coverage is available.
State whether coverage exists or not.
List the events covered: sickness, unemployment, injury, and maternity.
How to prepare it
1Set the reporting boundary first: decide which workforce locations and arrangements are in scope for this check, so you can answer the coverage question consistently across the group.
2Define the benefit events you will treat as covered for this disclosure, using the same practical categories each time and keeping the list aligned to the events named in the source data point.
3Gather the underlying proof from the relevant HR, payroll, benefits, or local policy records, so you can support both the yes/no coverage answer and any country-level exceptions.
4Prepare the reported output in two parts: the coverage flag, and a clear note on which event types are included, plus the countries where that protection is not available.
5Record any exclusions, gaps, or changes in approach, including where coverage differs by country, so the final disclosure explains the limits of the information rather than implying full uniformity.
6Check the draft against the official source data points before sign-off, confirming that the boundary, event list, and country exceptions match the underlying records and that nothing material has been omitted or added.
Request the data
Request the social protection coverage data from People Operations
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Which parts of our workforce are covered by social protection arrangements, what types of life events or risks are included, and where do we still have no coverage in place?
Use your organisation’s own terms first, then map them to the disclosure. For example, if you talk about benefits, welfare cover, statutory schemes, or local insurance arrangements internally, use those labels in the request and only translate them afterwards for reporting. This is a possible LRA training template; adapt it to your organisation and check the official source before sign-off.
Weak request
Can you fill in the ESRS S1 social protection disclosure for us, including coverage, events covered, and countries without coverage?
Why it fails: It uses framework language that many operational teams will not recognise, and it does not say which people, countries, systems, or internal labels to use. That makes it harder to pull the right records and increases the risk of inconsistent answers.
Better request
Please send the workforce protection summary for [reporting period] for [population boundary]. For each country or worker group, tell us whether cover exists, what it includes in your own team’s terms, and where there is no cover. If the data comes from more than one system, include the source for each line and flag any gaps or assumptions.
Industry examples
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 protection package, which employee groups were included in the count, and how you identified the listed protection types and any countries without that cover.
Context note
Explain what the figures say about the organisation’s employee protection arrangements, including whether cover is available at all, which risks are included, and where gaps remain by country.
Fluctuation statement
If the position changed from the prior period, point to changes in the number of countries without cover, shifts in the protection types offered, or a move from partial to broader coverage.
Content index entry
S1-10 Social Protection — [location / page] / [notes]
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Preparation tools & forms
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
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
The request goes to HR or payroll in framework language, so the team that actually tracks social cover in each country never confirms the figures.
Unclear population boundary
The data pull mixes employees, contractors, and other groups because nobody first states which workforce population is in scope for the count.
No country split
Records are gathered at group level only, so countries with no cover are not separated from countries where cover exists.
Wrong event list
The source team is asked for a generic benefits summary instead of the specific life events the data point is built around, so the answer cannot be mapped cleanly.
Mixed counting basis
Some sites report headcount while others report contracts or cases, which makes the final total impossible to compare across locations.
Timing mismatch
One country uses the current month while another uses the year-end snapshot, so the dataset is not built on the same cut-off date.
Source labels lost
Original file names, column names, and local codes are stripped out during consolidation, so the audit trail back to the first record is broken.
Evidence not captured
The team saves the numbers but not the supporting extracts, dates, or system references, leaving no metadata to show where each figure came from.
No sign-off trail
The draft is passed around informally and no named owner confirms it, so there is no clear record of who checked the final data set.
Where judgement is often needed
Define the reporting perimeter after a deal closes
If a business is bought or sold during the period, state the cut-off you used for including people and explain whether the answer reflects the group at period end or a time-weighted view.
Choose one country rule where local schemes differ
Where national systems describe protected events differently, map them to one internal list for sickness, job loss, injury and maternity, then explain the mapping so readers can see how the comparison was made.
Decide how to treat workers just outside the core population
Set out whether you included or excluded people such as agency staff, contractors or part-year joiners, and explain the practical rule used to place them inside or outside the count.
Use a consistent basis for the coverage answer
If some locations are checked from payroll records and others from HR estimates, disclose the mix and explain which method was used to decide the final yes/no answer.
Separate full protection from partial protection
Where a country only covers some of the listed life events, say whether you treated that location as covered or not covered and explain the threshold you applied.
Explain any estimate used for hard-to-measure sites
If local data were missing and you relied on a proxy or management estimate, identify the source of the estimate and note that it was used instead of direct site-level evidence.
Be clear on how you counted multi-country employees
For people who move between countries or split time across locations, explain which country’s protection status you used and why that rule gives a single answer for the period.
Round only after the final aggregation
If you present counts or percentages alongside the coverage narrative, round at the end of the calculation and disclose the rounding approach so the totals still reconcile.
Protect privacy by grouping small populations
When a country has very few affected people, combine the data into a broader group or omit the split detail, and say that privacy limits prevented a more granular breakdown.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Food manufacturing
We say our workforce is covered by our employee protection arrangements, and those arrangements include support for illness, job loss, workplace harm and parental leave. In the countries where we operate, there are 2 where some staff are not covered by one or more of those protections. - Coverage: yes - Protections included: sickness, unemployment, injury and maternity - Countries with gaps: 2
This example shows a simple narrative way to state whether the company’s own arrangements apply, which kinds of life events they address, and how many countries still have gaps.
Illustrative (synthetic) example — Retail logistics
Our group does not yet provide full protection across every location, so the answer on coverage is no. The package we do have covers illness, unemployment, injury and maternity, and there are 5 countries where at least one of those protections is missing. - Coverage: no - Protections included: sickness, unemployment, injury and maternity - Countries with gaps: 5
This example shows how to report a partial position: state the overall yes/no outcome, list the life events addressed by the arrangements, and give the number of countries where coverage is incomplete.
How companies report S1-10 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Hera S.p.A.
Water Utilities · Italy · 2024
Hera S.p.A.'s 2024 Consolidated Financial Statements include references to social protection, diversity, and training, with specific data points noted on pages 264 and 245, such as social protection (p.264), diversity metrics (p.264), and economic activities related to climate change mitigation and adaptation (p.245). The report also mentions employment relationships and remuneration alongside diversity metrics on page 264, and employee characteristics on page 263. However, no direct quotable narrative evidence was found in the report to provide detailed disclosure on these topics.
Aena S.M.E., S.A.
Air Transportation — Airport Services · Spain · 2025
Aena S.M.E., S.A.'s 2025 sustainability report provides detailed information on social protection coverage for salaried employees, stating that the group complements 100% of state sickness benefits and that 95.95% of employees were covered by social protection in 2025, with 99.85% covered by collective bargaining agreements (p.220, p.218). The report also references diversity metrics and adequate wages related to social protection (p.70). However, no specific data on other aspects of social protection or related narrative items were found in the report.
GEA Group Aktiengesellschaft
Electrical Equipment and Machinery · Germany · 2025
GEA Group Aktiengesellschaft’s 2025 Annual Report provides some data related to workforce metrics, including collective bargaining coverage and diversity (p.233), as well as injury frequency and severity rates under a strict zero-tolerance policy (p.233). The report also references incidents of discrimination and non-respect of UN Guiding Principles (p.228), and notes that 100% of employees are covered by a health and safety management system (p.178). However, no clear or quotable narrative evidence was found in the report to elaborate on these points or provide further context.
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Scenarios to work through
A group of 120 employees is split across three countries. In two countries, the company pays into public or private schemes that cover illness, job loss, workplace injury and parental leave; in the third country, only 18 of 40 workers have any such cover through the employer.
QHow should the preparer decide whether to mark the coverage field as yes or no, and what should be captured about the third country?
Reveal model answer →Hide answer ↑Treat the answer as yes only if the organisation can show that the workforce is covered through social protection arrangements. Then describe which life events are actually covered, using plain terms such as sickness, unemployment, injury and maternity or parental leave. For the third country, name it as a place where some workers do not have that protection and make clear how many people are affected, here 22 out of 40.
Why this matters · The disclosure should show both whether protection exists and where it is missing, not just give a single yes/no without context.
A preparer is drafting the note for a multinational group and finds that one subsidiary offers sickness and injury cover, while another only provides injury cover and no support for unemployment or maternity-related absence. The team is unsure whether to list every event separately or use a broad label.
QWhat level of detail should be given for the kinds of events covered?
Reveal model answer →Hide answer ↑List the actual events that are covered in the organisation’s arrangements, rather than using a vague umbrella phrase. If the cover differs by entity or country, the description should make that difference clear, so readers can see that one location covers sickness and injury while another covers only injury.
Why this matters · Be specific about the types of protection in place, because the point is to show what workers are covered for in practice.
A company has operations in five countries. Four countries have employee social insurance arrangements, but in one country the local labour market is informal and the employer has no scheme in place for its 15 staff there. The draft note currently says only that the group has ‘broad coverage globally’.
QWhat should the preparer do about the country with no cover?
Reveal model answer →Hide answer ↑Replace the broad statement with a clear list of the places where protection is absent. The country without cover should be identified, and the note should make it obvious that the 15 staff there are not included in any social protection arrangement through the employer.
Why this matters · Where protection is missing, the location should be named so readers can see the gap, not just infer it from a general statement.
A preparer has data showing that 78 of 90 workers in Country A are covered, 50 of 50 in Country B are covered, and 0 of 12 in Country C are covered. The team wants to report only the two countries with cover because the third one is sensitive.
QShould the country with no cover be left out, or included in the disclosure?
Reveal model answer →Hide answer ↑It should be included. The note needs to identify the countries where workers lack this protection, even if that means naming a country with zero coverage. Leaving it out would hide a material gap in the picture of social protection across the workforce.
Why this matters · The disclosure is meant to surface both coverage and non-coverage, so countries without protection belong in the answer.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
FAQ
Questions this page answers
How do I prepare disclosure S1-10 (ESRS S1 Own Workforce) using this page in practice?+−
Start with the plain-language explainer, then work through the step-by-step preparation section and the three datapoints to prepare: coverage status, covered event types and uncovered countries. The page is designed to help you turn those inputs into a draft disclosure and an assurance-ready evidence pack.
What data do I need to collect for S1-10 before I draft the disclosure?+−
The page says to prepare three core datapoints: coverage status, covered event types and uncovered countries. Use those as the minimum data set before you move into the draft-output section.
How should I decide the scope for S1-10 coverage status and covered event types?+−
Use the page’s preparation section to define what is in scope, then record the coverage status and the event types that are covered. The page also flags uncovered countries, so scope should be clear enough to show where the disclosure does and does not apply.
Who should own the S1-10 data and evidence pack in practice?+−
The page is aimed at sustainability and ESG managers, HR teams, data owners and assurance reviewers, so ownership should sit with the people who can confirm the data and evidence. Use the workbook to assign tasks and keep the evidence pack aligned to the disclosure.
What evidence do I need to make S1-10 assurance-ready?+−
The page includes an evidence pack with five items and four assurance claims to verify. Use those together so each claim has a clear risk and supporting evidence before review.
What are the common mistakes to avoid when reporting S1-10?+−
The page lists common reporting gaps and mistakes to help you spot weak points before sign-off. A practical use is to compare your draft against those gaps and check that the coverage status, event types and uncovered countries are all complete.
How do I use the Prep & Assurance workbook for S1-10?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it to organise the preparation steps, track the evidence pack and support assurance readiness.
What is the printable Library Card for S1-10 used for?+−
The Download Centre also includes a printable Library Card in .pdf format. It is there as a practical reference alongside the workbook when you are preparing the disclosure and checking your draft.
Can I use the synthetic example disclosure on the S1-10 page as a template?+−
Yes, as a worked illustration only. The page says the example disclosures are synthetic, and the quantitative table is internally consistent, so you can use it to see how the data might be presented without treating it as a real company example.
How do I turn S1-10 data into a draft narrative and content index line?+−
The draft-output section gives visualisation ideas, narrative starters and a content-index line. Use those to convert your prepared data into a readable draft once the scope and evidence are in place.
More questions this page can help with
S1-10 ESRS S1 Own Workforce: what should I check before I start collecting data?S1-10 disclosure: how do I document coverage status and uncovered countries clearly?What does the S1-10 evidence pack need to contain for assurance review?How do I use the S1-10 step-by-step preparation section with HR data owners?What are the S1-10 reporting gaps and how do I avoid them?How do I use the S1-10 workbook to track claims, risks and evidence?Where can I find example company reports for S1-10 topics on the page?How do I write a draft S1-10 disclosure from the page’s narrative starters?What are the three datapoints to prepare for S1-10 own workforce disclosure?Is there a printable S1-10 reference sheet in the Download Centre?
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