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.
Preparation
Key datapoints to prepare
＋ Show S1-9 sub-elements (LRA working checklist)
State whether an adequate wage applies.
Identify the benchmark used.
List the countries affected.
Give the percentage of employees below the threshold.
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.
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
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
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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 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.
Wrong period basis
The team mixes a snapshot from one date with figures built over a different reporting window, so the numbers do not line up.
Counting bases mixed
Headcount, full-time equivalent and payroll records are blended together, which makes the percentage below the threshold impossible to trust.
Source labels lost
The original country names, benchmark names or file labels are stripped out during collection, so nobody can trace where each figure came from.
Separate groups merged
Employees who should be tracked separately by country or pay basis are rolled into one file, which hides differences that matter for the disclosure.
Evidence trail incomplete
The team saves the numbers but not the supporting notes, extracts or approval record, so the source and sign-off cannot be checked later.
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.
Treating business changes during the year
If acquisitions, disposals or restructurings changed the workforce base, explain whether the figures reflect the opening group, the closing group or a blended view, and describe any restatement or carve-out used.
Using estimates where payroll data is incomplete
Where exact pay data is not available for part of the workforce, say which figures were estimated, how the estimate was built, and how much of the result is based on measured versus approximated data.
Setting the cut-off date for the calculation
Choose a clear reporting date or period-end basis for the assessment, explain any timing differences between payroll records and the workforce snapshot, and apply the same cut-off consistently.
Dealing with different pay definitions across countries
If local rules or contracts define pay components differently, explain how you normalised the data so the comparison is like-for-like, and note any items included in one country but not another.
Rounding and presentation of the percentage below threshold
State the rounding rule used for the share of employees below the benchmark, apply it consistently across countries and the group total, and make sure the rounded figure still matches the underlying calculation.
Protecting privacy when the workforce is small
When a country or site has too few people for a safe breakdown, aggregate the data to avoid identifying individuals, explain the level at which you combined it, and note any resulting limits on detail.
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.
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
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
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
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 →Hide answer ↑Treat it as a negative result for that country because some workers still fall short of the benchmark after the full pay package is considered. Record which benchmark was used, name the country, and state the share of workers below the threshold using the same basis used in the internal review.
Why this matters · The disclosure is not just a yes/no flag; it also needs the benchmark, the affected places, and the proportion of workers below the chosen line.
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 →Hide answer ↑List every country included in the assessment, not only the one with a gap. The point is to show the full scope of the review, so the reader can see where the comparison was made and where any shortfall sits.
Why this matters · When the assessment spans more than one country, the geography field should reflect the whole set, not just the problem cases.
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 →Hide answer ↑Enter zero for the share below the threshold, rather than leaving the field empty. The narrative should still identify the benchmark and the country, so the reader can see that the check was performed and that no one in scope fell short.
Why this matters · A clean result still needs to be reported as a result, not omitted.
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 →Hide answer ↑Disclose the benchmark actually used in the assessment, not a different one chosen for presentation. The supporting note should match the method applied in the pay review, so the reported outcome can be traced back to the same comparison basis.
Why this matters · The benchmark field must reflect the real test used, so the result is understandable and traceable.
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 S1-9 Own Workforce page to prepare a first draft disclosure?+−
Start with the plain-language explainer, then work through the step-by-step preparation section and the listed datapoints. The page also gives draft-output ideas, so you can turn the collected information into a narrative and a simple content-index line.
What data do I need to collect for S1-9 Own Workforce before drafting the disclosure?+−
The page says to prepare four datapoints: an adequate wage flag, the wage benchmark basis, the affected countries, and the below-threshold share. Use those as the starting point for your data request and check that the figures are internally consistent.
How should I set the scope for S1-9 Own Workforce in practice?+−
Use the page’s preparation section to decide which workforce data are in scope and then test the scope against the datapoints listed on the page. The affected countries and below-threshold share help you see where the disclosure needs to be broken down.
Who should own the S1-9 Own Workforce data collection and sign-off?+−
The page is designed for ESG, HR and data owners, so ownership should sit with the team that can source the workforce data and explain the methodology. The assurance section and evidence pack are useful for agreeing who will provide support and who will sign off the draft.
What evidence should I keep to make the S1-9 Own Workforce disclosure assurance-ready?+−
The page includes an evidence pack with five items for assurance readiness, alongside five assurance claims to verify. Use both together so you can show the claim, the risk it addresses and the supporting evidence in one place.
What are the common mistakes to avoid when reporting S1-9 Own Workforce?+−
The page lists common reporting gaps and mistakes, so it is meant to help you spot missing scope, weak methodology and unsupported figures before publication. A good check is whether each datapoint can be traced back to the evidence pack and the workbook.
How do I use the Prep & Assurance workbook for S1-9 Own Workforce?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is intended to help you organise the preparation and assurance steps. Use it to capture the datapoints, evidence and review notes before turning them into a draft.
What is the printable Library Card for S1-9 Own Workforce used for?+−
The Download Centre also includes a printable Library Card in .pdf format. It is a practical companion for keeping the key points, datapoints and assurance checks to hand while you prepare the disclosure.
Can I use the synthetic example disclosure on the S1-9 Own Workforce page as a template?+−
Yes, but only as an illustrative starting point. The page says the example is synthetic, so use it to see how the data table and narrative might look, then replace it with your own figures and wording.
How do I turn S1-9 Own Workforce data into a draft narrative and content-index line?+−
The draft-output section gives visualisation ideas, narrative starters and a content-index line to help you shape the final text. Use those prompts after you have checked the datapoints and evidence pack so the draft is consistent with the underlying data.
More questions this page can help with
S1-9 Own Workforce: what should I ask HR for to complete the disclosure?S1-9 Own Workforce: how do I check whether my wage benchmark basis is documented properly?S1-9 Own Workforce: what should be in the evidence pack before assurance review?S1-9 Own Workforce: how do I use the step-by-step preparation section without missing anything?S1-9 Own Workforce: what are the most common reporting gaps in the page’s guidance?S1-9 Own Workforce: how do I use the workbook to track the below-threshold share?S1-9 Own Workforce: how do I write the narrative starter from the page into a report draft?S1-9 Own Workforce: what does the synthetic example show for a quantitative table?S1-9 Own Workforce: how do I use the assurance claims and risks list in review?S1-9 Own Workforce: where can I find real published reports on this topic from the page?
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