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ESRS S1: Own Workforce·Disclosure Requirement S1-11
Disabilities
Practical guidance for preparing this disclosure. Use this card to identify the information to prepare, verify claims and organise supporting evidence. For exact requirements, always refer to the official European Commission source.
Published passport
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Editorial review in progress
Prepared from official source material and published report evidence. No named approver is recorded yet, so this page carries no byline.
Use it alongside the official European Commission source while that review is in progress.
Standard
ESRS S1: Own Workforce
Disclosure Requirement S1-11 · 2026-5010-final
Last reviewed
—
LRA educational guidance · Not issued or endorsed by European Commission
To prepare this disclosure
Disclosure focus
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.
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.
Before you start
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key information to prepare
| Preparation field | What to capture | Evidence hint | Owner |
|---|---|---|---|
| Disabled employee share | 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. | HRIS or workforce reporting extract, plus the definition used for disability status and the calculation showing the disabled count over the total workforce base. | HR / People Analytics |
＋ Show S1-11 sub-elements (LRA working checklist)
Calculate the share of employees who are disabled, using the organisation’s chosen headcount basis and a clear, consistent method.
State the result as a percentage of the total employee population covered by the measure.
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
Professional preparation tools for S1-11 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI Assistant.
Assurance readiness
For each claim, check the evidence
| Claim | Risk | Evidence to check |
|---|---|---|
| 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. | 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. | 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. | 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. | 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. | An assurer may ask whether the context is sufficient, balanced and not misleading, and whether it explains any unusual movements or comparability issues. | 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. | 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. | 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. | 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. | 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.
Common gaps
Mistakes to avoid when collecting the data
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.
Where judgement is often 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
Illustrative examples
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.
Company reports
How companies report S1-11 in practice
Examples of full and partial reporting practice. These are evidence-led reviews, not exact disclosure templates to copy.
Raben Group
Ground Transportation — Trucking · Netherlands / Poland · 2025
Raben Group's 2025 Sustainability Report provides a specific figure for employees with disabilities, reporting that 1.7% of their workforce, amounting to 141 individuals, have disabilities (p.75). This data is presented in a table showing the number of employees with disabilities by gender. However, the report does not provide further context or additional details on policies, initiatives, or trends related to disability inclusion.
Acciona, S.A.
Electric Utilities / IPP / Energy Traders · Spain · 2025
Acciona, S.A.'s 2025 Sustainability Report provides a specific figure for the percentage of employees with disabilities, reported as 3.92% and 4.25% on page 230. The report also includes detailed information on employee relations and collective bargaining coverage (p.436) as well as employment breakdowns by country, gender, age, and contract type (p.435). However, the evidence map does not clarify whether further details on disability inclusion policies or related outcomes are provided, leaving some aspects of the disclosure unclear.
Hyundai Glovis Co., Ltd.
Water Transportation · South Korea · 2025
Hyundai Glovis Co., Ltd.'s 2025 Sustainability Report provides some data on employee numbers and percentages, including a figure of 76 employees representing 53.90% female on page 109, and mentions parental leave and training related to employees on pages 50 and 111. The report also notes 100% of employees in certain categories on page 123 and references parental leave data on page 126. However, there is no clear narrative or detailed explanation found in the report regarding the specific disclosure, as no quotable evidence was identified.
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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 →Hide answer ↑
Use a percentage of employees with disabilities, based on the organisation’s own employee population for the period. If the underlying source is a headcount, convert it into a percentage before finalising the disclosure, and make sure the basis used is clear and consistent with the rest of the report.
Why this matters · This item is about showing the share of the workforce with disabilities, not just listing a raw count.
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 →Hide answer ↑
Not safely. The preparer should first check that the underlying data are built on a comparable basis, because the reported percentage should reflect a consistent approach across the organisation. If the sources are not aligned, the team needs to reconcile them or explain the basis used before publishing the figure.
Why this matters · Comparable inputs matter, because mixed definitions can distort the reported share.
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 →Hide answer ↑
Recalculate it for the current reporting period. The disclosure should reflect the workforce position for the period being reported, so an older percentage would not give a current picture unless the report clearly explains that it is historical and why it is being used.
Why this matters · The figure should describe the period under report, not an outdated workforce snapshot.
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 →Hide answer ↑
No. The disclosure needs the actual percentage of employees with disabilities. A general narrative can sit alongside the metric, but it cannot replace the numerical information that this datapoint is asking for.
Why this matters · For this item, the key output is the percentage itself, with narrative only as support.
Framework references
Relevant ESRS requirements and related disclosures
Available framework references and nearby disclosures relevant to preparing this requirement.
ESRS
S1-11
within ESRS S1: Own Workforce
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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?+−
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.
What data do I need to collect for the S1-11 disabled employee share datapoint?+−
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.
How should I set the scope and methodology for S1-11 disabled employee share?+−
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.
Who should own the S1-11 disclosure process in practice: ESG, HR, or data owners?+−
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.
What evidence pack do I need to make S1-11 assurance-ready?+−
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.
What are the five assurance claims to verify for S1-11?+−
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.
What are the common reporting gaps or mistakes to avoid in S1-11?+−
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.
How do I use the S1-11 workbook download to prepare the disclosure?+−
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.
What is the printable Library Card for S1-11 and how should I use it?+−
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.
How do I turn the S1-11 data into a draft disclosure?+−
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
S1-11 ESRS S1 own workforce: what should I check before I calculate disabled employee share?How do I build an evidence pack for S1-11 disabled employee share that is ready for review?What should go into the S1-11 workbook before I hand the draft to assurance?How do I assign ownership for the S1-11 own workforce disclosure across ESG and HR?What are the most common mistakes in S1-11 disabled employee share reporting?Can I use the S1-11 page to draft narrative wording for the disclosure?Where do I find the step-by-step preparation guidance for S1-11?What does the S1-11 page say about evidence for disabled employee share?How do I use the downloadable PDF Library Card for S1-11?Does the S1-11 page include real company report examples I can compare against?What visualisation ideas are suggested for the S1-11 disclosure draft?Is there a one-to-one ESRS or IFRS equivalent for S1-11 on this page?
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