Disclosure focus
The practical focus is on coverage and consistency: whether arrangements apply across the whole organisation and relevant locations, or only in selected teams, sites or flagship offices. It should be clear how the organisation identifies needs, provides reasonable adjustments or equivalent support, and monitors whether disabled workers can participate on an equal basis. Where implementation differs by country, site or business unit, the report should make that variation clear.
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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Disabled employee share
HR / People AnalyticsThe percentage of the workforce who are recorded as disabled for the reporting period, using the organisation’s agreed definition and the same headcount basis used for the wider workforce measure.
Evidence HRIS or workforce reporting extract, plus the definition used for disability status and the calculation showing the disabled count over the total workforce base.
Watch for Definition/category mismatch: the disability status source does not align to the workforce denominator used for the percentage.
Before you start
- Have you settled which parts of the workforce count for this figure, and which groups stay out of it?
- Have you fixed the point in time or period-end basis you will use for the headcount and the disability share?
- Can every number be traced back to a named source, such as HR records or another internal system?
- Have you agreed what counts as a disability in your organisation for this calculation, and is that definition applied consistently?
- Have you checked that the percentage is built from the same population as the employee count, so the figures line up?
How to prepare it
Request the data
Request the disability workforce share data
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What share of our employees have self-identified as disabled in the reporting period, using the organisation’s own people data and definitions?
Use your organisation’s own people-data terms first, then map them to the disclosure. For example, ask for the internal disability status field, employee headcount basis, and the reporting cut-off date rather than using framework wording in the request.
Weak request
Please provide the ESRS S1-11 disability disclosure data for the reporting period.
Why it fails: It uses framework language only, does not say which internal system or field to use, does not define the employee population or counting basis, and does not ask for the supporting metadata needed to check the figures.
Better request
Please provide the employee disability status data from [HRIS/source system] for [reporting period], using our internal field names and agreed headcount basis. Include the total employee population in scope, the count who self-declared as disabled, any other response categories we use, the cut-off date, and a short note on how blanks or non-response are handled. This is a possible LRA training template only; adapt it to your organisation and check the official source before sign-off.
Formal email template
Subject: Request for people data on disability status for [reporting period] Hi [name/team], Could you please share the people data needed for our sustainability reporting pack for [reporting period]? We need the following, using your usual internal definitions and source system: - total employee count for the agreed population - count of employees who have self-identified as disabled - the basis used for the count (for example, point-in-time headcount or another internal basis) - the field name and any category mapping used in the source data - the cut-off date and reporting period covered - any notes on missing, blank, or undisclosed responses Please return the data in a table and include a short note on how it was prepared. This is a possible LRA training template only; please adapt it to your organisation and check the official source before sign-off. Thanks, [preparer name]
Short Teams / Slack version
Hi [name/team] — could you send the people data for [reporting period] on our employee disability status, using your normal HRIS fields and headcount basis? Please include total employees, the count self-declaring as disabled, the cut-off date, and any notes on blanks or missing responses. This is a possible LRA training template only; adapt it to your organisation and check the official source before sign-off.
Industry examples
Retail
Context. A large store-based employer with a central HR system and separate payroll records.
Adapted request. Please pull the store and head-office employee data from [HRIS] for [reporting period], using our internal disability status field and the same employee population we use for workforce reporting. Include total employees, the count self-declaring as disabled, the response categories in use, and any notes on staff who joined or left during the period.
Example response. A table with period, population, total employees, disabled count, other response categories, and a note that the figures come from the HR system at period end.
Manufacturing
Context. A multi-site employer with site-level people records and a central people analytics team.
Adapted request. Please provide the workforce disability status figures for all production sites and offices for [reporting period], using the internal people-data field and the agreed employee count basis. Include the site breakdown, total workforce, count self-identifying as disabled, and any exclusions such as contractors or temporary labour if they are not part of the internal workforce measure.
Example response. A site-by-site table showing total employees, disabled employees, and the percentage share, plus a note confirming contractors were excluded from the workforce count.
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 the organisation defines a disabled employee for this disclosure, what population was counted, and whether the figure is a headcount or another basis of measurement.
Context note
Explain what the figure says about the make-up of the workforce and how it helps readers understand inclusion across the organisation.
Fluctuation statement
If the share moved materially, note whether the change reflects hiring, departures, reclassification, or better data collection, and say whether the underlying workforce size also changed.
Content index entry
S1-11 Disabilities — [location / page] / [notes]Download Centre
Preparation tools & forms
Download preparation tools for S1-11 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We prepared the figure using our own working method and the underlying records we relied on, and we can show how the inputs were gathered and combined.
Risk An assurer may test whether the method was applied consistently, whether the source data were complete and accurate, and whether the calculation can be reproduced from the evidence held.
Evidence to check Calculation workbook or system output; source extracts from HR or other relevant records; data mapping or transformation notes; version history showing the method used; reviewer sign-off on the final figure.
We used a defined set of assumptions where the raw data were not enough on their own, and we documented the main limits of the estimate.
Risk An assurer may probe whether the assumptions were reasonable, whether any important limitation was omitted, and whether the estimate could materially change if different assumptions were used.
Evidence to check Assumption log; methodology note; sensitivity or reasonableness checks; evidence of management review; records showing any known data gaps or estimation constraints.
We added the context needed to read the figure properly, including any factors that affect how it should be interpreted.
Risk An assurer may ask whether the context is sufficient, balanced and not misleading, and whether it explains any unusual movements or comparability issues.
Evidence to check Draft disclosure text; supporting narrative papers; internal review comments; evidence for any explanations of trends, one-off effects or scope changes; approval trail for the final wording.
We set out the calculation approach, the kinds of data used and where those data came from before publishing the figure.
Risk An assurer may check whether the stated approach matches the actual calculation, whether the data types and sources are complete, and whether any manual adjustments were properly controlled.
Evidence to check Method statement; data source register; system reports or extracts; reconciliation between source data and reported figure; evidence of controls over manual entries or overrides.
We reported the percentage as a share of our workforce and used percent as the unit, with the numerator and denominator defined in our working papers.
Risk An assurer may test whether the percentage is calculated on the right population, whether the unit is shown consistently, and whether the underlying headcount basis is clear and supportable.
Evidence to check Population definition; numerator and denominator workings; headcount or employee register extracts; calculation sheet showing the percentage; final published table or narrative showing the unit used.
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 data ownerChasing the figure from the wrong team, or asking in framework language instead of the organisation’s own terms, often means the person with the actual headcount records never sees the request.
- Scope left vagueIf the team does not pin down which worker groups and locations are in scope, different people will count different populations and the result will not be comparable.
- Boundary not fixedWhen the reporting perimeter is not agreed up front, some sites or entities get included by one person and excluded by another, so the final number shifts for reasons unrelated to the data itself.
- Wrong time basisUsing a different cut-off date or period from the one used in the source records produces a percentage that does not match the underlying HR extract.
- Mixed counting methodCombining a headcount file with a full-time-equivalent file, or switching between person counts and contract-based totals, distorts the percentage because the denominator is not built on the same basis as the numerator.
- Source labels lostCopying the number into a summary sheet without keeping the original field names, codes, or notes makes it impossible to trace what the source record actually meant.
- Populations mergedRolling together groups that should stay separate, such as employees and other workers, hides differences in the source data and can double count or undercount people.
- Evidence trail missingIf the team saves only the final figure and not the extract date, source file, and sign-off record, nobody can later show how the number was assembled or checked.
Judgement needed
- What counts as a disability in each countryUse the local working definition that your people data can actually support, and explain any country-by-country differences so readers can see why the same person may be counted differently across locations.
- People hired or leaving part way through the yearSet a clear cut-off for who is included in the headcount and disclose that timing choice, especially where acquisitions, disposals, or restructurings change the workforce during the reporting period.
- Employees with incomplete or self-declared statusDecide whether you rely on HR records, self-identification, or another internal source, then say how you handled missing or unconfirmed cases and whether they sit inside or outside the count.
- Workers on the boundary of the workforce populationState which groups you include or leave out, such as agency staff, contractors, interns, or other non-standard arrangements, and explain the rule you used to keep the scope consistent.
- Using estimates where records are not completeIf you have to estimate the share of disabled employees, say which parts are measured and which are modelled, why the estimate was needed, and how much of the figure is based on judgement.
- Rounding and small-number protectionChoose one rounding approach and apply it consistently, but if small numbers could expose individuals, aggregate further or suppress detail and explain the privacy safeguard you used.
- Different systems giving different totalsWhere payroll, HR, or local reporting systems do not match, pick one source of truth, describe the reconciliation steps, and note any known gaps or exclusions that affect the final percentage.
- Changes in organisational structure during the yearWhen a business unit is added, sold, or reclassified, explain whether the workforce count reflects the opening position, the closing position, or an average basis, and keep the method stable from one period to the next unless you clearly justify a change.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
We counted our workforce at year-end and identified the share of employees who told us they have a disability.
- In our manufacturing group, 48 of 1,200 employees self-identified as disabled, which is 4%.
- We present this as a simple workforce mix indicator for the reporting period, using our own internal headcount records.
This example shows how to disclose the proportion of employees who self-identify as disabled, using a clear year-end headcount basis and a numerically consistent percentage.
We reviewed our staff records at the reporting date and calculated the portion of our people who reported a disability.
- In our financial services group, 27 of 900 employees were recorded as disabled, equal to 3%.
- We use this as a straightforward workforce composition measure for the period, based on our internal employee data.
This example shows the same disclosure for a different sector, with a different workforce size and a matching percentage derived from the count of disabled employees.
Quality ladder
- Basic
We report 6% of our workforce as disabled.
- Better
We report that 6% of our 500 employees are disabled, based on our year-end HR records.
- Best
At year-end, 6% of our 500 employees were recorded as disabled in our HR system, and the share was unchanged from last year because our headcount mix stayed broadly stable.
Check your understanding
Scenarios to work through
A preparer is drafting the people section and has the headcount split by disability status from HR records. The figure is available for the reporting period, but the team is unsure whether to present it as a percentage of all employees or as a headcount.
A group reporter has data from one subsidiary that classifies disability using local HR self-identification records, while another subsidiary uses occupational health records. The team is considering combining the figures without checking whether the underlying definitions match.
The sustainability team has a draft table showing the percentage of employees with disabilities, but the number is based on last year’s workforce file. The current reporting period has a different employee population after a restructuring.
A preparer has a draft narrative that says the organisation supports inclusion and accessibility, but it does not include any numeric information on employees with disabilities. The team wonders whether the narrative alone is enough.
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Advice, not assurance
Framework references
Relevant ESRS requirements and related disclosures
ESRS
S1-11
within ESRS S1: Own Workforce
Guides that settle this question
Related & explore
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FAQ
Questions this page answers
Use the page’s plain-language explainer and the step-by-step ‘how to prepare’ section to frame the disclosure, then focus on the one datapoint listed for preparation: disabled employee share. The page is designed to help you turn that into a draft, not to act as an official standard.
The page says the datapoint to prepare is disabled employee share, so you should gather the underlying workforce data needed to calculate that figure. The page does not add extra metrics, so keep the scope tied to that datapoint and document how you derived it.
The page gives a step-by-step preparation section, so use that to define what workforce population is included and how the share is calculated. Keep the methodology consistent, and make sure it is clear enough for review and assurance.
The page is aimed at sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the team that can coordinate the data and evidence pack. In practice, that usually means assigning one accountable owner and clear support from the relevant data source owners.
The page includes an evidence pack with five items for assurance readiness, so use that as the basis for your file set. Build the pack around the source data, calculation support, and any documents needed to show how the disabled employee share was prepared.
The page says there are five assurance claims to verify, each with a claim, risk and evidence prompt. Use those claims to test whether your draft is supported by the underlying records before you finalise the disclosure.
The page lists common reporting gaps and mistakes, so use that section as a pre-submission check. It is there to help you spot missing support, weak methodology, or gaps between the data and the narrative before assurance or publication.
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 data, evidence, and review points in one place before drafting.
The Download Centre also includes a printable Library Card in .pdf format. Use it as a quick reference while you work through the preparation, evidence, and draft-output sections of the page.
The page has a draft-output section with visualisation ideas, narrative starters, and a content-index line. Use those prompts to convert the prepared disabled employee share data into a short narrative and a clean draft structure.
More questions this page can help with