Disclosure focus
The practical focus is on whether the response is real and organisation-wide, not just limited to a few visible initiatives. A useful report should make clear where the actions apply across the business, which parts of the workforce they cover, and how resources are allocated between different measures, rather than only highlighting flagship sites, pilot projects or one-off programmes.
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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Implemented actions
Sustainability / operationsA plain summary of the steps already put in place to address the issue, including what was done and at what level of progress.
Evidence Action tracker, project updates, management papers, implementation logs.
Watch for Actions are described as planned rather than actually completed, so the reported status does not match the delivery tracker.
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Prevention steps
Risk / operationsThe measures set up to stop the issue arising again, covering the controls or changes introduced to reduce future occurrence.
Evidence Control design documents, policy updates, risk treatment plans, process change records.
Watch for Prevention controls are mixed up with general improvement work, so the datapoint does not reconcile to the risk treatment plan.
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Reduction measures
Operations / sustainabilityThe steps taken to lessen the size, frequency, or seriousness of the issue where it cannot be avoided entirely.
Evidence Mitigation plan, incident response records, operational change logs, issue tracker.
Watch for Reduction measures are recorded at the wrong stage, so the item is confused with prevention or with post-incident repair.
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Repair actions
Legal / operationsThe actions taken to put right harm already caused, including any restoration, compensation, or follow-up work already underway.
Evidence Remediation plan, claims or compensation records, restoration work orders, case management files.
Watch for Repair activity is captured without the affected cases, so the datapoint misses the actual remediation population.
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Impact category
Sustainability / riskThe kind of effect being described, stated in business terms and aligned to the specific issue being reported.
Evidence Impact assessment, issue register, stakeholder analysis, incident classification notes.
Watch for The impact is labelled using a different category set than the assessment register, so the definition does not align.
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Response actions
Operations / sustainabilityThe concrete steps taken in response to the impact, including what was done and by whom.
Evidence Response plan, action log, incident records, management reporting.
Watch for Response actions are pulled from the wrong period, so the reported steps do not match the incident timeline.
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Trade-off assessment
Finance / strategyA short explanation of the business choices made, showing the balance between the impact response and other commercial considerations.
Evidence Decision paper, board pack, approval memo, risk-benefit analysis.
Watch for The trade-off narrative is written from the final outcome only, so the original decision basis is lost.
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Performance indicators
Finance / sustainabilityThe measures used to track progress or performance for the matter being reported, with the exact metric names and values used internally.
Evidence KPI dashboard, management report, scorecard, data dictionary.
Watch for The KPI values are taken from a different metric definition than the management dashboard, so the figures do not reconcile.
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Tracking systems
IT / data governanceThe systems, tools, or processes used to monitor the matter over time, including where the data comes from and how it is checked.
Evidence System descriptions, control documentation, monitoring workflow, IT or data governance records.
Watch for The monitoring source is named at a high level but not tied to the actual system of record, so the datapoint cannot be traced.
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Review findings
Sustainability / internal auditThe results of the evaluation, including what the review found and whether the measures are working as intended.
Evidence Evaluation report, audit findings, review minutes, performance analysis.
Watch for The evaluation result is reported for the wrong review cycle, so the finding does not match the assessment period.
Before you start
- Which people-related issues, teams, sites, or activities are you actually covering here, and which are out of scope?
- For each action, have you settled whether it is already in place, still being rolled out, or only planned?
- Are you using the same reporting period and cut-off as the rest of your people data, so the figures line up?
- Can each number or statement be traced back to a named internal source, owner, or system record?
- Have you agreed what counts as the issue type, the action taken, and any knock-on business trade-offs in your own operating language?
- Do your tracking measures and review results use the same definitions throughout, so comparisons are like-for-like?
How to prepare it
Request the data
Request the people actions and tracking evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What people-related actions have been put in place, what was done to prevent, reduce, or put right the issue, and how are we tracking whether it is working?
Use your organisation’s own terms first (for example, people plan, case handling, wellbeing action, conduct issue, manager follow-up, or employee relations log), then map those terms to the disclosure wording before sign-off. This is a possible LRA training template only; adapt it to your organisation and check the official source before sign-off.
Weak request
Please send the ESRS S1-3 actions, prevention, mitigation, remediation, impact type, trade-offs, KPIs, monitoring systems, and evaluation results for the reporting period.
Why it fails: It uses framework labels that many teams do not use day to day, so the owner may not know which records to pull. It also does not say which system, boundary, period, or internal category names to use, so the response is likely to be incomplete or hard to map.
Better request
Please send the people action tracker or case summary for [period] covering [boundary]. Include the actions taken, the steps used to prevent, reduce, or put right the issue, the issue type as your team records it, any trade-offs considered, the measures used to track progress, and the latest results. Use your own team labels first, then we will map them to the reporting pack.
Formal email template
Subject: Request for people action and tracking evidence for [reporting period] Hello [name], We are preparing the sustainability reporting pack and need your help with the people-related actions and tracking information for [reporting period] across [boundary]. Please send a short extract or summary covering: - the main actions put in place - the steps taken to prevent, reduce, or put right the issue - the type of people issue or impact each action relates to - any trade-offs or side effects the team considered - the measures used to track progress - the latest results from those measures - the source system or file used Please use your team’s own wording first, then we will map it to the reporting labels. If helpful, you can return it in the table format below. This is a possible LRA training template only; please adapt it to your organisation and check the official source before sign-off. Many thanks, [preparer name] [role] [contact details]
Short Teams / Slack version
Hi [name] — could you share the people actions and tracking evidence for [period] across [boundary]? Please include the action taken, the prevention / reduction / fix steps, the issue type, any trade-offs, the measures used, and the latest results. Use your team’s own terms first; we’ll map them later. Thanks, [name]
Industry examples
Manufacturing
Context. A plant HR team tracks absence, safety-related people issues, and supervisor follow-up actions in a local workbook and case system.
Adapted request. Please share the site people action log for [period] at [site]. Include the action taken, the prevention or fix steps, the issue type as recorded locally, any trade-offs, the tracking measures, and the latest results. Use the site’s own labels first.
Example response. The site returns a table with action ID, issue type, action description, follow-up step, trade-off note, KPI, latest result, and evidence link to the workbook and meeting minutes.
Retail
Context. A regional people team manages store-level engagement actions, manager coaching, and employee relations follow-up in a shared dashboard.
Adapted request. Please send the regional people improvement dashboard for [period] across [region]. Include the actions taken, the steps to prevent or reduce the issue, the store issue type, any business trade-offs, the measures used, and the latest dashboard results. Use your own store and region terms first.
Example response. The team provides a dashboard extract showing action name, store cluster, issue category, coaching or policy step, trade-off note, measure, latest score, and link to the dashboard snapshot.
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
For this disclosure, we describe the impact type, the actions already put in place, the main indicators used to track progress, the monitoring approach, and the latest evaluation outcome, using the same basis consistently across the reporting period.
Context note
These figures show how the organisation has responded to the identified impacts, what it is watching to judge progress, and where any trade-offs have been accepted in order to carry out the response.
Fluctuation statement
If the numbers move materially, explain whether that reflects a change in the underlying impact, a shift in the response measures, a different monitoring result, or a revised assessment of effectiveness.
Content index entry
S1-3 Actions & Resources — [location / page] / [notes]Download Centre
Preparation tools & forms
Download preparation tools for S1-3 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We say the coverage figure was built from the full set of in-scope people we chose for the period, and we can show how we defined that population, any exclusions, and why those choices were made.
Risk An assurer will test whether the population behind the figure is complete, consistently defined, and not narrowed or widened without a clear basis.
Evidence to check ['Population definition note or methodology paper', 'Inclusion and exclusion rules used for the period', 'Source extracts or system reports showing the in-scope population', 'Approval trail for any scope judgement or change']
We explain the way we tracked whether the actions were working, including what we measured, how often we reviewed it, and how we decided if progress was real.
Risk An assurer will probe whether the monitoring approach is capable of showing progress rather than just activity, and whether the review method was applied consistently.
Evidence to check ['Tracking framework or KPI dashboard', 'Review cadence and assessment criteria', 'Meeting packs or management updates showing progress checks', 'Records of any changes to the tracking method']
We have set out the main measures and the resources we used to deal with the identified workforce issues, and we can evidence that these were the actions actually planned or under way.
Risk An assurer will check whether the disclosed actions are genuinely the main responses, whether resources are identifiable, and whether the description matches what was implemented.
Evidence to check ['Action plan or programme register', 'Budget, headcount or other resource allocation records', 'Project status reports', 'Internal sign-off confirming the disclosed actions']
Where there was harm that had already happened, we describe the steps we took to put things right or to help others do so, and we can show who was responsible for each step.
Risk An assurer will look for evidence that remedial steps were not just aspirational, but were actually arranged, supported or carried out for the affected people.
Evidence to check ['Case logs, grievance records or remediation files', 'Responsibility matrix or ownership records', 'Correspondence with affected parties or representatives', 'Completion evidence for remedial actions']
We have explained how we balanced workforce-related actions against other commercial pressures, and we can show the internal discussion where those trade-offs were considered.
Risk An assurer will test whether the tension between people-related action and business constraints was genuinely assessed, rather than omitted or simplified.
Evidence to check ['Decision papers or trade-off analyses', 'Executive or committee minutes', 'Risk registers showing competing pressures', 'Internal approvals or escalation records']
For the negative workforce issues we identified, we grouped them by type and described the steps already taken, the steps planned, and the steps still in progress to stop, reduce or fix them.
Risk An assurer will check whether the issue types are clearly distinguished and whether the response actions are complete, current, and matched to each issue.
Evidence to check ['Issue log or impact assessment', 'Action tracker with status and owners', 'Evidence of completed, ongoing and planned measures', 'Management review showing linkage between issue type and response']
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 the wrong team, so the people who actually run the action, prevention, mitigation or remedy never confirm what happened.
- Framework language onlyThe data call uses reporting jargon instead of the organisation’s own terms, and staff cannot map it cleanly to the work they manage.
- Scope left vagueNo one states which business units, sites, worker groups or activities are in scope, so different teams collect different slices of the same topic.
- Boundary not fixedThe collector does not define whether the figures cover the whole group, a subsidiary, or only a local operation, which makes the dataset inconsistent.
- Wrong period basisSome teams pull current-year activity while others use the period when the work was approved or completed, so the timeline does not line up.
- Mixed counting methodHeadcounts, cases, actions and spend are blended without a single counting rule, so the totals cannot be compared or checked.
- Source labels lostOriginal file names, system codes or local category names are stripped out, so the evidence can no longer be traced back to the source record.
- Populations mergedSeparate groups that should stay distinct, such as different worker categories or action types, are rolled into one bucket and the detail is lost.
- Evidence trail missingThe pack has the numbers but not the supporting metadata, version history or sign-off record, so nobody can show where the data came from or who approved it.
Judgement needed
- What counts as in-scope people after a buy-in or sale-outUse the same organisational perimeter you applied for the rest of the people data, and explain when a purchase or disposal changes which workers, contractors or other covered groups are included.
- How to handle different local job labels for the same worker groupMap country-specific titles and employment labels into one internal grouping rule, then state the rule you used so readers can see how like-for-like groups were combined.
- Where to draw the line for workers near the perimeterSet out whether you included people who are partly managed by the organisation, on temporary assignment, or otherwise close to the boundary, and explain the practical rule used to decide.
- Whether to report by event date or by reporting-period averageChoose one timing basis for counting actions, resources and affected people, apply it consistently, and say if any late changes or backdated items were brought into the period.
- When to use estimates instead of direct countsIf complete headcounts or action records are not available, use a documented estimate method, label it clearly, and explain where the figure is based on system data versus judgement.
- How to round small numbers without distorting the pictureState the rounding rule used, keep totals and component figures internally consistent, and note any cases where rounding changes the visible split between categories.
- How far to aggregate people data for privacy reasonsCombine small groups where needed to avoid identifying individuals, but explain the aggregation rule and any minimum group size so users understand the loss of detail.
- How to separate prevention, mitigation and remedy in one programmeIf one initiative serves more than one purpose, describe the main purpose you assigned to it and explain any split or overlap so the same action is not counted twice.
- How to treat actions that are still underway at period endShow whether you reported only completed work or also live programmes, and make clear the cut-off used for items that started before period end but were not finished.
- How to align internal monitoring results with the narrative on actionsLink the measures you track to the actions you describe, explain any gaps between the two, and disclose the basis used when a KPI is a proxy rather than a direct measure.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
We describe one issue affecting our own workforce: repetitive strain linked to manual packing, which we addressed through line redesign, extra lifting aids and refreshed supervisor training. We also set out the practical steps we used to reduce the risk, the support we gave to affected workers, and the business choices we made where faster throughput had to be balanced against safer working methods.
- Actions already in place: 14 prevention steps and 6 follow-up measures were rolled out across 3 sites; 2 worker cases received direct support and 1 case required a formal remedy plan.
- For the impact itself, we recorded a physical health issue affecting 18 workers; we responded with job rotation, adjusted shift patterns and targeted training, while accepting a 3% reduction in hourly output at the busiest site.
- To track progress, we used three indicators: 92% of supervisors completed the new training, 87% of high-risk tasks were covered by the monitoring checks, and the review found a 28% fall in reported strain incidents versus the prior quarter.
This is a synthetic, internally consistent example showing how to narrate the actions taken, the nature of the workforce harm, the trade-off with output, and the measures used to monitor and assess progress.
We report a case involving fatigue and stress among night-shift staff after a period of sustained peak demand, and we explain the steps we took to prevent recurrence, lessen the harm and support recovery. Our response included roster changes, extra rest breaks, a confidential support route and a review of overtime limits, even though this meant slower parcel turnaround for a short period.
- We put in place 11 preventive controls, 5 harm-reduction actions and 4 recovery measures; 3 employees received direct follow-up and 1 team was offered a formal repair process.
- The issue we identified was mental well-being strain affecting 26 workers; we acted with revised shift planning, workload caps and manager coaching, while accepting a 5% drop in same-day dispatch performance during the adjustment period.
- We monitored the situation with four measures: 95% of night supervisors completed the new briefing, 90% of high-load shifts were checked weekly, 8% of staff used the support route, and the latest review showed a 31% decline in fatigue-related complaints.
This is a synthetic, internally consistent example showing how to describe the impact type, the response taken, the operational trade-off, and the indicators, monitoring and review results used to judge whether the response is working.
Quality ladder
- Basic
We spent €1.2 million on employee wellbeing actions.
- Better
We spent €1.2 million on employee wellbeing actions, split between training, support services and case follow-up.
- Best
We spent €1.2 million on employee wellbeing actions across all sites this year, with most of the increase coming from added support services after a rise in reported stress cases.
Check your understanding
Scenarios to work through
A group has rolled out a new grievance channel for its own workforce, but the first reporting draft only describes the channel and leaves out the training sessions, policy updates and staffing added to make it work. The team also has a separate note on a pay review that was used to address a known concern.
A preparer is drafting a section on a workplace safety issue and has a long list of controls, but the draft does not say which part of the workforce was affected, what the organisation actually did, or what trade-off was accepted when production targets were adjusted to allow extra training time.
The sustainability team has introduced a supplier audit programme and a new whistleblowing hotline, and it wants to report both as part of its people-related actions. However, the draft does not say how the team will track whether those measures are working, or what indicators will be used to judge progress over time.
A company has completed a remediation process after a complaint about working conditions, but the draft report only says the complaint was closed. It does not explain what was done to address the harm, whether the fix was aimed at the people affected, or whether the result was reviewed afterwards.
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Advice, not assurance
Framework references
Relevant ESRS requirements and related disclosures
ESRS
S1-3
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 datapoints to prepare. The page is designed to help you turn source data into a draft narrative, supported by the example disclosures and draft-output section.
The page says to prepare data on implemented actions, prevention steps, reduction measures, repair actions, impact category, response actions, trade-off assessment, performance indicators, tracking systems, and review findings. Use that list as your collection checklist so you can see what is available, what is missing, and what needs owner sign-off.
Use the page’s step-by-step preparation guidance to decide what sits in scope and how each datapoint will be treated consistently. The page is meant to help you define the working method for the disclosure, rather than giving a fixed reporting template.
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 evidence the actions, indicators, and review findings. A practical approach is to assign one lead for the draft and named owners for each datapoint and evidence item.
The page includes an evidence pack with five items to support assurance readiness, alongside six assurance claims to verify. Use those sections to build a file that links each claim to the relevant risk and evidence before the draft is finalised.
The page says there are six assurance claims to verify, each framed around claim, risk, and evidence. It does not list them in the source text here, so you need to use the page itself and the evidence pack to work through them.
The page lists common reporting gaps and mistakes so you can spot weak drafting before sign-off. A practical use is to compare your draft against those gaps, then check whether each datapoint is supported by evidence and whether the narrative matches the underlying data.
Use the synthetic examples as a model for structure, level of detail, and how quantitative information can be presented in a table. They are illustrative only, so they should help you draft your own wording without treating the example as a reporting requirement.
The page gives draft-output ideas including visualisation options, narrative starters, and a content-index line. Use those to turn your prepared data into a readable draft that is easier for reviewers and assurance teams to follow.
The Download Centre includes a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf format. Use the workbook to organise preparation and assurance checks, and the Library Card as a quick reference while drafting or reviewing.
More questions this page can help with