Workers who are not employees

Disclosure 2-8 requires the total number of workers who are not employees and whose work is controlled by the organisation. Payroll status is not the test. First determine whether the individual lacks an employment relationship with the reporting organisation under national law or practice; then determine whether the organisation controls the work.

Control of work means that the organisation directs the work performed or controls the means or methods used to perform it. Control can be exercised solely by the organisation or shared with another organisation, such as a supplier, customer, employment agency, contractor or joint-venture partner. Explain how the control assessment was made.

The disclosure covers all qualifying workers performing work for the entities included in sustainability reporting under Disclosure 2-2. Start with those entities, remove employees reported under Disclosure 2-7, assess control for the remaining workers and remove duplicates across agency, procurement, access and timesheet systems.

Agency workers, apprentices, contractors, home workers, interns, self-employed persons, subcontractors and volunteers are possible examples, not automatic classifications. Labels such as temporary, seasonal, casual or outsourced do not determine employee status or control. Supplier personnel are outside the total when the organisation controls only the service outcome and not their work, means or methods.

Report the total number and describe the most common worker types, their contractual relationship with the organisation and the work they perform. State whether relationships are direct or indirect through a third party and identify the type of third party. A general description is sufficient; a quantitative breakdown by worker type is optional additional transparency.

Describe whether the total is headcount, FTE or another measure and whether it represents period end, an average or another timing basis. Do not add incomparable units without conversion or clear explanation. Where exact figures are unavailable, GRI Guidance permits estimates to the nearest ten workers or, when the number exceeds 1,000, to the nearest 100; explain the estimation method and limitations under 2-8-b.

Describe significant fluctuations during and between reporting periods and report the threshold used to determine significance. If none occurred, a brief direct statement is sufficient. Explaining drivers such as seasonality, major projects or outsourcing changes is useful context but not a separate requirement.

If all workers performing work for the organisation are employees and there are no workers who are not employees, a brief statement confirming this is sufficient.

Reasons for omission are permitted for Disclosure 2-8. An informal exclusion note or a claim that a group is not material is insufficient. Identify the unmet requirement and use a permitted reason—Not applicable, Legal prohibitions, Confidentiality constraints, or Information unavailable / incomplete—with the explanation required by GRI 1 in the content index.

The five datapoints below are an LRA operational decomposition of the three requirements in Disclosure 2-8. They are not five separate GRI requirements.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official GRI source.

A quick mental checklist before you prepare this disclosure — tick each as you settle it.

Key datapoints to prepare

Identify workers who are not employees and assess control of work

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

Do not request a generic list of contractors or non-payroll people. Ask separately about employment relationship, direct or indirect contractual relationship, the third party, direction of work, control of means or methods, shared control and actual work performed.

Subject: GRI 2-8 worker population and control assessment for [period]

Dear [name/team],

For every entity reported under GRI 2-2, please provide records of individuals performing work who are not included in the confirmed GRI 2-7 employee population. For each common group, identify the employment status, direct or indirect contractual relationship, relevant third-party type, work performed, who directs the work, who controls the means or methods, and whether control is shared.

Please also provide the source systems, duplicate-removal logic, total in a consistent unit, headcount/FTE method, period-end/average basis, estimates, significant-fluctuation threshold and movement analysis. Do not classify people solely as contractor, temporary, seasonal, casual, agency or outsourced.

Many thanks,
[preparer name]

Please provide the GRI 2-8 assessment for all GRI 2-2 entities: non-employee status, direction or control of means/methods, direct/indirect relationship and third party, work performed, reconciled total, methodology and significant fluctuations.

Notes that turn data into a disclosure

LRA training templates — adapt them to your organisation, and check the official source before sign-off.

For each claim, check the evidence

Mistakes to avoid when collecting the data

Where judgement is often needed

Illustrative examples

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

Scenarios to work through

Relevant GRI requirements and related disclosures

Available framework references and nearby disclosures relevant to preparing this requirement.

Questions this page answers