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London Reporting Academy ESRS S1 · Own Workforce · Disclosure Requirement S1-11

Applicable from FY2027

This revised ESRS edition applies from reporting year 2027. For reporting years 2024–2026, use the ESRS 2023 edition.

Disabilities

S1-11 · mandatory · narrative disclosure

This disclosure asks an organisation to explain how it supports and includes people with disabilities across its own workforce. In practice, the report should describe the main policies, processes and workplace adjustments in place, and how these are applied in day-to-day employment matters such as recruitment, access to work, development, progression and retention. The emphasis is on what is actually in place and how it works in practice, rather than a general statement of commitment.

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.

  • Disabled employee share

    HR / People Analytics

    The 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?
+ Show S1-11 sub-elements (LRA working checklist)

How to prepare it

Confirm the reporting boundary for this workforce metric, so you know which employees are in scope before you start counting.
Set a clear internal rule for who is treated as disabled for this disclosure, using one consistent business definition across the organisation.
Gather the underlying records that support the count, such as HR or people-system data, and check they are current and complete.
Calculate the percentage from the relevant employee totals and the disabled-employee count, making sure the figures reconcile to the source records.
Record any exclusions, assumptions, data gaps, or changes in method, so the reported number can be traced and explained later.
Compare the final output with the official source and your internal working papers to confirm the disclosure is accurate and consistent before sign-off.

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.

Free · Email access

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.
+ Show 4 more

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.
+ Show 4 more

Examples

How it reads on the page

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

Illustrative (synthetic) example — manufacturing

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.

Illustrative (synthetic) example — financial services

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.

QHow should the metric be presented for this disclosure?
Reveal model answer →

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.

QCan the two sets of figures be merged straight away for the reported percentage?
Reveal model answer →

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.

QShould the team carry forward last year’s percentage, or recalculate it for the current period?
Reveal model answer →

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.

QIs a general statement on inclusion sufficient for this disclosure?
Reveal model answer →
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Framework references

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S1-11

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FAQ

Questions this page answers

For S1-11 (ESRS S1: Own Workforce), what exactly should I prepare before I start drafting the disclosure?+
What data do I need to collect for the S1-11 disabled employee share datapoint?+
How should I set the scope and methodology for S1-11 disabled employee share?+
Who should own the S1-11 disclosure process in practice: ESG, HR, or data owners?+
What evidence pack do I need to make S1-11 assurance-ready?+
What are the five assurance claims to verify for S1-11?+
What are the common reporting gaps or mistakes to avoid in S1-11?+
How do I use the S1-11 workbook download to prepare the disclosure?+
What is the printable Library Card for S1-11 and how should I use it?+
How do I turn the S1-11 data into a draft disclosure?+

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