Disclosure focus
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 European Commission source.
Prepare
What to collect before drafting
Tick each field as the evidence lands. Owners are the teams that usually hold the source files.
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Coverage status
HR / BenefitsRecord whether the workforce is covered by the relevant protection arrangement, using a simple yes/no answer for the reporting period.
Evidence Policy schedule, benefits register, insurer or scheme confirmation, and HR/benefits records showing who is enrolled.
Watch for The yes/no flag is set from a policy summary but not reconciled to the live enrolment list, so the reported coverage status does not match the actual covered population.
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Covered event types
HR / BenefitsList the kinds of events the arrangement protects against, limited to the events actually provided for in the source record for the period.
Evidence Plan terms, policy wording, insurer certificate, or scheme summary showing the event categories included.
Watch for The event list is copied from a generic template and includes categories not in the actual plan, so the reported coverage types do not match the source terms.
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Uncovered countries
HR / BenefitsIdentify the countries where the arrangement does not apply, based on the current coverage map for the reporting period.
Evidence Territory schedule, insurer exclusions, local plan matrix, or country-by-country benefits register.
Watch for The country list is built from headquarters assumptions and misses locations with no active cover, so the reported gaps do not reconcile to the territory schedule.
Before you start
- Have you decided whether you are counting only people covered by a social safety arrangement, or also those covered through another arrangement you provide or fund?
- Have you fixed which life events you will treat as in scope for this check — for example illness, job loss, work injury, or maternity-related leave?
- Have you agreed the country list you will use to spot where people are not covered, and whether that list is based on the reporting period or a different cut-off date?
- Can you trace each yes/no and country entry back to a source you can show later, such as policy records, payroll data, or insurer information?
- Have you settled the definition you will use for “covered” so the same rule is applied across all locations and employee groups?
How to prepare it
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.
Formal email template
Subject: Data request for social protection coverage review Hi [Name], I’m preparing our year-end sustainability reporting pack and need your help with the workforce protection data for [reporting period]. Please share the information for [population boundary] across [countries/sites], using the terms your team normally uses internally. I’m looking for: - whether each location or worker group has cover in place; - which types of events or risks are included, such as sickness, unemployment, injury, or maternity-related support; - where there is no cover in place, by country. If the information sits across more than one system, please include the source for each line and note any assumptions or gaps. A possible format is attached below. Please adapt this to your organisation’s own language, and please check the official source before sign-off. Many thanks, [Your name]
Short Teams / Slack version
Hi [Name] — could you send over the workforce protection data for [reporting period] for [population boundary]? Please use your usual internal terms, and include: whether cover exists, what events/risks are included, and which countries have no cover. If it’s split across systems, just note the source for each line. Thanks — [Your name]
Industry examples
Manufacturing
Context. A group with plants in several countries and a mix of direct employees and local site workers.
Adapted request. Please share the site-level workforce protection summary for [reporting period] across [plant locations]. Use the labels your benefits or payroll teams already use. For each site, confirm whether cover is in place, what events it includes, and which countries have no cover for any worker group.
Example response. Country / site: Poland plant | Worker group: direct employees | Coverage in place: Y | Included event or risk: sickness, injury, maternity support | Coverage basis: company scheme plus statutory arrangements | No-cover reason / gap note: none | Source reference: benefits register v3
Professional services
Context. A firm with office-based staff in multiple jurisdictions and locally managed benefits packages.
Adapted request. Please send the benefits coverage summary for [reporting period] across [countries]. Use your normal benefits names, and show whether each office population has cover, what it includes, and where any country has no arrangement in place.
Example response. Country / site: Spain office | Worker group: salaried staff | Coverage in place: Y | Included event or risk: sickness and maternity support | Coverage basis: local insurer policy | No-cover reason / gap note: none | Source reference: HR benefits tracker
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]Download Centre
Preparation tools & forms
Download preparation tools for S1-10 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We built the coverage figure from our own employee records and payroll files, then checked which people were in scope at the reporting date and which locations were included. For the countries we operate in, we mapped where social protection arrangements were in place and where they were not, using a documented country-by-country review.
Risk An assurer will probe whether the scope was set consistently, whether all relevant countries and worker groups were included, and whether the coverage figure could be overstated or understated because of missing entities, duplicate records, or inconsistent cut-off dates.
Evidence to check Population extracts used for the calculation; payroll and HR source files; the scope memo showing which entities, countries and worker categories were included or excluded; the country-by-country mapping of social protection arrangements; version control or sign-off showing the final cut-off date and any adjustments.
We separated the disclosed figure from any estimates by tracing it back to underlying records and by documenting where local data had to be normalised before consolidation. Where a country used a different scheme or classification, we recorded the basis for treating it as covered or not covered so the same rule was applied across the group.
Risk An assurer will test whether the data was comparable across countries, whether local classifications were translated consistently, and whether management judgement was applied in a way that could bias the result.
Evidence to check Data transformation notes; mapping tables between local categories and group reporting categories; reconciliation between local submissions and the consolidated figure; documented judgement papers for any ambiguous cases; review evidence showing the same rule was applied across locations.
Before publication, we checked the figure against headcount totals, reviewed exceptions, and investigated any unusual movements from the prior period. We also had the underlying working papers reviewed by a second person so that the final disclosure matched the supporting files.
Risk An assurer will look for evidence that the final number was independently checked, that anomalies were investigated, and that the published disclosure agrees to the source workings without unexplained differences.
Evidence to check Reconciliation to headcount and other control totals; exception logs and follow-up notes; prior-period comparison analysis; reviewer sign-off or evidence of independent review; final working paper pack and the published disclosure showing consistency with the support.
For the part of the disclosure dealing with gaps in protection, we used a documented list of major life events and checked each country against that list using local policy documents and benefit summaries. Where a gap existed, we kept the supporting note showing why the event was treated as not covered.
Risk An assurer will probe whether the list of events was complete and applied consistently, whether local documents actually support the coverage conclusion, and whether any gaps were omitted or described too narrowly.
Evidence to check The approved list of major life events used for the assessment; local policy documents, employee handbooks or benefit summaries; the country-by-country assessment matrix; notes explaining any gaps identified; evidence of management review of the final wording.
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.
Where drafts go wrong
Mistakes to avoid and where judgement is needed
The left column is what preparers get wrong while collecting; the right column is where you will have to make and explain a judgement.
Mistakes to avoid
- Wrong ownerThe 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 boundaryThe data pull mixes employees, contractors, and other groups because nobody first states which workforce population is in scope for the count.
- No country splitRecords are gathered at group level only, so countries with no cover are not separated from countries where cover exists.
- Wrong event listThe 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 basisSome sites report headcount while others report contracts or cases, which makes the final total impossible to compare across locations.
- Timing mismatchOne 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 lostOriginal 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 capturedThe 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 trailThe draft is passed around informally and no named owner confirms it, so there is no clear record of who checked the final data set.
Judgement needed
- Define the reporting perimeter after a deal closesIf 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 differWhere 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 populationSet 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 answerIf 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 protectionWhere 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 sitesIf 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 employeesFor 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 aggregationIf 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 populationsWhen 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
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
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.
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.
Quality ladder
- Basic
I report that our workforce social cover is in place.
- Better
I report that our workforce social cover is in place for sickness, job loss, injury and maternity, and I note that it applies across all countries where we operate.
- Best
I report that our workforce social cover is in place for sickness, job loss, injury and maternity across all operating countries this year, with no countries left out, and I note that this reflects our current plan design rather than a change in the workforce.
Check your understanding
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.
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.
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’.
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.
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Advice, not assurance
Framework references
Relevant ESRS requirements and related disclosures
ESRS
S1-10
within ESRS S1: Own Workforce
Guides that settle this question
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FAQ
Questions this page answers
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.
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.
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.
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.
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.
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.
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.
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.
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.
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