Disclosure focus
This disclosure asks an organisation to explain the main actions it is taking, or plans to take, on its own workforce-related impacts, risks and opportunities, and to show what resources it is putting behind those actions. In practice, that means describing the measures in a way that lets a reader understand what is being done, why it matters, and whether the organisation has committed people, time, money or other support to make it happen.
The practical focus is on whether the response is real and organisation-wide, not just limited to a few visible initiatives. A useful report should make clear where the actions apply across the business, which parts of the workforce they cover, and how resources are allocated between different measures, rather than only highlighting flagship sites, pilot projects or one-off programmes.
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 S1-3 sub-elements (LRA working checklist)
Put in place the actions already carried out.
Set out the steps used to reduce the issue.
Set out the steps used to stop the issue arising.
Set out the steps used to put things right after harm.
Describe the actions the business has already taken.
Explain the business choices or compromises involved.
State what kind of impact is being considered.
Report the results of the assessment or review.
List the key measures used to track performance.
Describe the systems used to keep watch over progress.
How to prepare it
1Set the reporting boundary first. Decide which parts of the business, which activities, and which people-related impacts you are covering, so the disclosure is anchored to the right scope before you draft anything else.
2Agree the categories you will use. Separate the information into the practical buckets needed here: what has been done, what was put in place to stop issues arising, what was done to reduce them, and what was done to put things right.
3Gather the underlying support. Pull together the records, internal reports, tracking outputs, and other source material that show the actions taken, the impact type, the measures used, and the monitoring or review results.
4Prepare the actual disclosure content. For each required item, write the narrative or figures that explain the action, the relevant impact, the trade-offs for the business, the indicators used, the monitoring approach, and what the evaluation showed.
5Record any limits or changes in approach. Note where information has been left out, where methods have changed, or where the basis of reporting differs from prior periods, so users can understand the context of the data.
6Check the draft against the source requirements. Compare each line with the official ESRS material to confirm you have covered every required point, used the right scope, and not added or omitted anything material.
Request the data
Request the people actions and tracking evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What people-related actions have been put in place, what was done to prevent, reduce, or put right the issue, and how are we tracking whether it is working?
Use your organisation’s own terms first (for example, people plan, case handling, wellbeing action, conduct issue, manager follow-up, or employee relations log), then map those terms to the disclosure wording before sign-off. This is a possible LRA training template only; adapt it to your organisation and check the official source before sign-off.
Weak request
Please send the ESRS S1-3 actions, prevention, mitigation, remediation, impact type, trade-offs, KPIs, monitoring systems, and evaluation results for the reporting period.
Why it fails: It uses framework labels that many teams do not use day to day, so the owner may not know which records to pull. It also does not say which system, boundary, period, or internal category names to use, so the response is likely to be incomplete or hard to map.
Better request
Please send the people action tracker or case summary for [period] covering [boundary]. Include the actions taken, the steps used to prevent, reduce, or put right the issue, the issue type as your team records it, any trade-offs considered, the measures used to track progress, and the latest results. Use your own team labels first, then we will map them to the reporting pack.
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
For this disclosure, we describe the impact type, the actions already put in place, the main indicators used to track progress, the monitoring approach, and the latest evaluation outcome, using the same basis consistently across the reporting period.
Context note
These figures show how the organisation has responded to the identified impacts, what it is watching to judge progress, and where any trade-offs have been accepted in order to carry out the response.
Fluctuation statement
If the numbers move materially, explain whether that reflects a change in the underlying impact, a shift in the response measures, a different monitoring result, or a revised assessment of effectiveness.
Content index entry
S1-3 Actions & Resources — [location / page] / [notes]
Download Centre
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 the wrong team, so the people who actually run the action, prevention, mitigation or remedy never confirm what happened.
Framework language only
The data call uses reporting jargon instead of the organisation’s own terms, and staff cannot map it cleanly to the work they manage.
Scope left vague
No one states which business units, sites, worker groups or activities are in scope, so different teams collect different slices of the same topic.
Boundary not fixed
The collector does not define whether the figures cover the whole group, a subsidiary, or only a local operation, which makes the dataset inconsistent.
Wrong period basis
Some teams pull current-year activity while others use the period when the work was approved or completed, so the timeline does not line up.
Mixed counting method
Headcounts, cases, actions and spend are blended without a single counting rule, so the totals cannot be compared or checked.
Source labels lost
Original file names, system codes or local category names are stripped out, so the evidence can no longer be traced back to the source record.
Populations merged
Separate groups that should stay distinct, such as different worker categories or action types, are rolled into one bucket and the detail is lost.
Evidence trail missing
The pack has the numbers but not the supporting metadata, version history or sign-off record, so nobody can show where the data came from or who approved it.
Where judgement is often needed
What counts as in-scope people after a buy-in or sale-out
Use the same organisational perimeter you applied for the rest of the people data, and explain when a purchase or disposal changes which workers, contractors or other covered groups are included.
How to handle different local job labels for the same worker group
Map country-specific titles and employment labels into one internal grouping rule, then state the rule you used so readers can see how like-for-like groups were combined.
Where to draw the line for workers near the perimeter
Set out whether you included people who are partly managed by the organisation, on temporary assignment, or otherwise close to the boundary, and explain the practical rule used to decide.
Whether to report by event date or by reporting-period average
Choose one timing basis for counting actions, resources and affected people, apply it consistently, and say if any late changes or backdated items were brought into the period.
When to use estimates instead of direct counts
If complete headcounts or action records are not available, use a documented estimate method, label it clearly, and explain where the figure is based on system data versus judgement.
How to round small numbers without distorting the picture
State the rounding rule used, keep totals and component figures internally consistent, and note any cases where rounding changes the visible split between categories.
How far to aggregate people data for privacy reasons
Combine small groups where needed to avoid identifying individuals, but explain the aggregation rule and any minimum group size so users understand the loss of detail.
How to separate prevention, mitigation and remedy in one programme
If one initiative serves more than one purpose, describe the main purpose you assigned to it and explain any split or overlap so the same action is not counted twice.
How to treat actions that are still underway at period end
Show whether you reported only completed work or also live programmes, and make clear the cut-off used for items that started before period end but were not finished.
How to align internal monitoring results with the narrative on actions
Link the measures you track to the actions you describe, explain any gaps between the two, and disclose the basis used when a KPI is a proxy rather than a direct measure.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — food processing
We describe one issue affecting our own workforce: repetitive strain linked to manual packing, which we addressed through line redesign, extra lifting aids and refreshed supervisor training. We also set out the practical steps we used to reduce the risk, the support we gave to affected workers, and the business choices we made where faster throughput had to be balanced against safer working methods. - Actions already in place: 14 prevention steps and 6 follow-up measures were rolled out across 3 sites; 2 worker cases received direct support and 1 case required a formal remedy plan. - For the impact itself, we recorded a physical health issue affecting 18 workers; we responded with job rotation, adjusted shift patterns and targeted training, while accepting a 3% reduction in hourly output at the busiest site. - To track progress, we used three indicators: 92% of supervisors completed the new training, 87% of high-risk tasks were covered by the monitoring checks, and the review found a 28% fall in reported strain incidents versus the prior quarter.
This is a synthetic, internally consistent example showing how to narrate the actions taken, the nature of the workforce harm, the trade-off with output, and the measures used to monitor and assess progress.
Illustrative (synthetic) example — logistics and warehousing
We report a case involving fatigue and stress among night-shift staff after a period of sustained peak demand, and we explain the steps we took to prevent recurrence, lessen the harm and support recovery. Our response included roster changes, extra rest breaks, a confidential support route and a review of overtime limits, even though this meant slower parcel turnaround for a short period. - We put in place 11 preventive controls, 5 harm-reduction actions and 4 recovery measures; 3 employees received direct follow-up and 1 team was offered a formal repair process. - The issue we identified was mental well-being strain affecting 26 workers; we acted with revised shift planning, workload caps and manager coaching, while accepting a 5% drop in same-day dispatch performance during the adjustment period. - We monitored the situation with four measures: 95% of night supervisors completed the new briefing, 90% of high-load shifts were checked weekly, 8% of staff used the support route, and the latest review showed a 31% decline in fatigue-related complaints.
This is a synthetic, internally consistent example showing how to describe the impact type, the response taken, the operational trade-off, and the indicators, monitoring and review results used to judge whether the response is working.
How companies report S1-3 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Continental AG
Tires · Germany · 2025
Continental AG’s 2025 Annual Report includes some related context on capital and operational expenditures for key actions, mentioning total amounts of current and planned CapEx and OpEx for target achievement (p.143, p.133). The report also addresses material impacts and management approaches related to environmental and workforce issues (p.115, p.163, p.213). However, there is no clear or direct disclosure of the specific datapoint sought, and several narrative items are not found or remain unclear in the report.
SNCF Group
Ground Transportation — Railroads · France · 2025
SNCF Group’s 2025 Full-Year Financial Report includes a description of a network of 600 local prevention specialists and measures to combat bullying and discrimination in the workplace, as well as a whistleblowing system (p.255). The report provides partial context on impact assessment methodologies and compliance checks (p.227), and mentions actions taken to respond to effects by adapting corporate strategy, organisation, and governance (p.72). However, no headline values or detailed narrative items directly addressing the disclosure were found elsewhere in the report.
Telecom Italia S.p.A.
Telecommunication Services · Italy · 2025
Telecom Italia S.p.A.’s 2025 Annual Report includes references to actions and resources related to sustainability issues affecting its own workforce and consumers, as noted on pages 152 and 153. The report also mentions climate change policies and mitigation efforts, with specific operational expenditure of 23.8 thousand euros dedicated to these actions (p.181, p.185). However, no direct or quotable narrative evidence explicitly detailing the company’s sustainability disclosure was found in the report.
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Scenarios to work through
A group has rolled out a new grievance channel for its own workforce, but the first reporting draft only describes the channel and leaves out the training sessions, policy updates and staffing added to make it work. The team also has a separate note on a pay review that was used to address a known concern.
QShould the disclosure bring together the concrete steps already put in place, including prevention, reduction and remedy measures, rather than listing only the new channel?
Reveal model answer →Hide answer ↑Yes. The write-up should cover the actual steps the organisation has already put in place to deal with the issue, and it should distinguish between measures aimed at stopping problems before they happen, reducing harm where it is already arising, and putting things right after harm has occurred. If a pay review was part of the response, it belongs in the account of actions taken, alongside the other measures, so the reader can see the full response rather than just one visible initiative.
Why this matters · Describe the full response package, not just the most visible action.
A preparer is drafting a section on a workplace safety issue and has a long list of controls, but the draft does not say which part of the workforce was affected, what the organisation actually did, or what trade-off was accepted when production targets were adjusted to allow extra training time.
QHow should the preparer decide what to include so the account shows the nature of the impact, the response, and any business trade-off that came with it?
Reveal model answer →Hide answer ↑The disclosure should explain what kind of impact the organisation was dealing with, then set out the steps taken in response, and also make clear any business trade-off that was accepted as part of that response. In practice, that means linking the issue to the affected people and describing the operational choice made, such as slowing output to create time for training, rather than leaving the reader to infer the connection.
Why this matters · Show the impact, the response, and the practical cost of acting.
The sustainability team has introduced a supplier audit programme and a new whistleblowing hotline, and it wants to report both as part of its people-related actions. However, the draft does not say how the team will track whether those measures are working, or what indicators will be used to judge progress over time.
QWhat should the preparer add so the disclosure shows how the organisation will follow up on the measures and assess whether they are effective?
Reveal model answer →Hide answer ↑The preparer should add the measures used to monitor progress, the indicators chosen to track them, and the outcome of the review so far. That means explaining what is being watched, how it is being watched, and what the early or latest assessment shows, rather than stopping at a list of initiatives. If the organisation has a dashboard, audit cycle or other tracking method, that belongs in the narrative because it shows how the response is being checked in practice.
Why this matters · Pair each action with a way to track whether it is working.
A company has completed a remediation process after a complaint about working conditions, but the draft report only says the complaint was closed. It does not explain what was done to address the harm, whether the fix was aimed at the people affected, or whether the result was reviewed afterwards.
QHow should the preparer decide whether the remediation story is complete enough for the disclosure?
Reveal model answer →Hide answer ↑The account should make clear what was done to put matters right for the people affected, not just that the case was closed. It should describe the remedy itself, show that it was linked to the harm that had occurred, and include the result of the follow-up review if one was carried out. A bare closure note is not enough because it does not let the reader see the action taken or whether it achieved the intended outcome.
Why this matters · For remedy, explain the fix and the result, not only the case status.
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 use the S1-3 ESRS S1 Own Workforce page to draft the disclosure from scratch?+−
Start with the plain-language explainer, then work through the step-by-step preparation section and the datapoints to prepare. The page is designed to help you turn source data into a draft narrative, supported by the example disclosures and draft-output section.
What data do I need to collect for S1-3 Own Workforce before I start writing the disclosure?+−
The page says to prepare data on implemented actions, prevention steps, reduction measures, repair actions, impact category, response actions, trade-off assessment, performance indicators, tracking systems, and review findings. Use that list as your collection checklist so you can see what is available, what is missing, and what needs owner sign-off.
How should I set the scope and methodology for the S1-3 Own Workforce disclosure?+−
Use the page’s step-by-step preparation guidance to decide what sits in scope and how each datapoint will be treated consistently. The page is meant to help you define the working method for the disclosure, rather than giving a fixed reporting template.
Who should own the S1-3 Own Workforce data and narrative 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 evidence the actions, indicators, and review findings. A practical approach is to assign one lead for the draft and named owners for each datapoint and evidence item.
What should I put in the evidence pack for S1-3 Own Workforce assurance readiness?+−
The page includes an evidence pack with five items to support assurance readiness, alongside six assurance claims to verify. Use those sections to build a file that links each claim to the relevant risk and evidence before the draft is finalised.
What are the six assurance claims I need to check for S1-3 Own Workforce?+−
The page says there are six assurance claims to verify, each framed around claim, risk, and evidence. It does not list them in the source text here, so you need to use the page itself and the evidence pack to work through them.
What are the common reporting mistakes on the S1-3 Own Workforce page and how do I avoid them?+−
The page lists common reporting gaps and mistakes so you can spot weak drafting before sign-off. A practical use is to compare your draft against those gaps, then check whether each datapoint is supported by evidence and whether the narrative matches the underlying data.
How do I use the synthetic example disclosures on the S1-3 Own Workforce page?+−
Use the synthetic examples as a model for structure, level of detail, and how quantitative information can be presented in a table. They are illustrative only, so they should help you draft your own wording without treating the example as a reporting requirement.
What should the draft output for S1-3 Own Workforce look like on this page?+−
The page gives draft-output ideas including visualisation options, narrative starters, and a content-index line. Use those to turn your prepared data into a readable draft that is easier for reviewers and assurance teams to follow.
How do I use the Prep & Assurance workbook and printable Library Card for S1-3 Own Workforce?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf format. Use the workbook to organise preparation and assurance checks, and the Library Card as a quick reference while drafting or reviewing.
More questions this page can help with
S1-3 ESRS S1 Own Workforce checklist for ESG managers: what should I gather before drafting?How do I build an evidence pack for S1-3 Own Workforce using the page’s assurance claims?What is the best way to turn S1-3 Own Workforce data into a first draft narrative?Which S1-3 Own Workforce datapoints should HR own versus sustainability own?How can I use the S1-3 Own Workforce example table to format my own quantitative disclosure?What are the most common S1-3 Own Workforce reporting gaps to check before sign-off?How do I use the S1-3 Own Workforce workbook to track preparation and assurance actions?What should an assurance reviewer look for in an S1-3 Own Workforce draft?How do I write the content-index line for S1-3 Own Workforce?Where can I find real company report examples for S1-3 Own Workforce on the page?How do I use the review findings datapoint in S1-3 Own Workforce reporting?What visualisation ideas does the S1-3 Own Workforce page suggest for the draft output?
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