Disclosure focus
This disclosure asks an organisation to explain how it manages health and safety for its own workforce and what the actual outcomes are. In practice, that means reporting the main risks, the controls and processes in place to prevent harm, and the results achieved over the reporting period, such as incidents, injuries, work-related ill health, and any serious events that show how effective the approach is.
The practical focus is on whether health and safety coverage is real and consistent across the organisation, not just at a few well-managed sites. Readers will want to understand whether the approach applies across all operations, locations and types of workers, how issues are identified and followed up, and whether the organisation can show that its system works in day-to-day practice rather than only on paper.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official EFRAG source.
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key datapoints to prepare
＋ Show S1-13 sub-elements (LRA working checklist)
Work out the share of the workforce covered.
Record all work-related deaths, whether caused by incidents or illness.
Count the number of workplace accidents.
Calculate the accident rate per one million hours worked.
Record all work-related illness cases.
Track the number of days lost because of work-related injury or illness.
How to prepare it
1Set the reporting boundary first: decide which people and work locations are included in the figures, and make sure the same boundary is used for every measure in this disclosure.
2Agree the counting rules before you start compiling data: define what will be treated as a fatal case, an accident, an illness case, and a lost-day event, so the numbers are built on one consistent basis.
3Gather the source records that support each figure: incident logs, absence or case records, and any working-time data needed to calculate the accident rate per million hours and the coverage percentage.
4Compile the required outputs in the format needed for the report: the coverage percentage, fatalities from accidents and illness, accident count, accident rate, illness cases, and lost days.
5Record any exclusions, boundary changes, or method changes clearly, so a reviewer can see what was left out, what changed, and why the current figures are not directly comparable with an earlier period if that applies.
6Check the completed disclosure against the official source before sign-off: confirm the boundary, definitions, calculations, and labels all match the underlying requirement and that nothing required has been missed.
Request the data
Request the health and safety incident data
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What are the period-end health and safety figures we need to report for our own workforce and work activities?
Use your organisation’s own terms first, then map them to the reporting labels. For example, ask for your incident log, case register, absence records and hours worked data in the language your teams already use, rather than using framework wording in the request.
Weak request
Please provide the ESRS S1:S1-13 health and safety metrics for the reporting period, including coverage, fatalities, accidents, accident rate, illness cases and lost days.
Why it fails: It uses framework language only, does not say which internal records to pull, and leaves the owner guessing about the population, source system, counting basis and exclusions. That makes it harder to return a usable, auditable pack.
Better request
Please send the latest figures from your incident log, case register and absence records for [period] and [boundary]: fatal work-related events, accident cases, accident rate per 1m hours, work-related illness cases, lost days, and the coverage % for the group you track. Include the source file, the population covered, the counting method, the hours-worked basis, and any exclusions so we can map your terms to the reporting labels.
Industry examples
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
Explain how the organisation defined the workforce population covered by the figures, how it counted deaths, accidents, illness cases and lost days, and how it calculated the accident rate per million hours.
Context note
Set out what the figures say about the reach of the reporting population and the level of harm experienced in the period, including whether the numbers point to isolated events or a broader pattern.
Fluctuation statement
If any figure moved materially, describe the main operational or reporting reasons for the change, such as a shift in workforce coverage, a change in incident frequency, or a different mix of accidents and illness cases.
Content index entry
S1-13 Health & Safety — [location / page] / [notes]
Download Centre
Preparation tools & forms
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
A percentage is stated without the underlying counts (numerator and denominator).The denominator — what the figure is a share of — is not explained.Partial scope is reported as if it were complete coverage.One-off activities are counted as if they were ongoing programmes.Boundary or period changes that move the figure are not flagged.Exclusions from the reported scope are not listed or explained.
Common gaps
Mistakes to avoid when collecting the data
Wrong owner
The request goes to a manager who does not hold the incident logs, so the team chases the wrong person instead of the operational owner who keeps the records.
Framework language only
The ask is written in reporting jargon, so site teams cannot match it to their own injury, absence, or case-tracking terms.
Unclear boundary
The data pull does not state which sites, workers, or business units are in scope, so different teams count different populations.
Wrong period basis
The team mixes events from different reporting windows, so the figures do not line up with the same time period.
Mixed counting method
One source counts cases, another counts people or days, and the numbers are merged without separating the basis used for each measure.
Source labels lost
Original incident codes, case notes, or system tags are stripped out during extraction, making it hard to trace each figure back to the source record.
Populations merged
Employee, contractor, and other worker records are rolled together even where they should be kept separate for the data pull.
No evidence trail
The extract is saved without the supporting file names, timestamps, or reviewer notes, so no one can show how the number was built.
No sign-off record
The final dataset is used without a named reviewer confirming it, so there is no clear trail of who checked the figures before reporting.
Where judgement is often needed
Set the reporting boundary after buyouts and disposals
Use the same cut-off rule across the group for new and sold businesses, explain which sites or teams were added or removed, and note any effect on the headcount base, incident totals and hours used for the coverage figure.
Choose one working definition where local rules differ
If countries or business units record injuries, illness or lost time differently, pick one group-wide method for the report, describe the local differences, and say how you converted the source records into one consistent set of figures.
Decide how to treat people close to the boundary
State whether you include contractors, agency staff, interns, temporary workers or other near-boundary groups in the safety data, and explain the rule used so readers can see who sits inside the count and who does not.
Fix the timing rule for when an event enters the year
Explain whether you count an accident, illness or lost day when it happens, when it is reported, or when it is confirmed, and keep that timing rule consistent across all measures in the disclosure.
Separate measured figures from estimates
Where records are incomplete, say which numbers come from direct logs and which are estimated or extrapolated, describe the method used to fill gaps, and identify any material assumptions that could move the totals.
Be clear on how you calculate the rate per hours worked
Disclose the hours base used for the rate, including whether it covers only the people in scope or a broader workforce pool, and explain any adjustments made for part-year service, overtime or missing time records.
Explain how you handle privacy limits in small teams
If a site, team or country is so small that naming the underlying cases could identify people, aggregate the figures to a higher level, say where that was done, and keep the method consistent from year to year.
State your rounding rule and keep it stable
Tell readers whether you round each line item before or after totals are built, what precision you use for counts and rates, and whether any rounding could cause small differences between component figures and the published total.
Clarify how you treat mixed-source illness and fatality records
If one case is recorded in more than one system or may involve both an accident and a health condition, explain the rule used to avoid double counting and show how you decided which category the case sits in.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Manufacturing
: we report the share of our workforce covered by the figures below, alongside work-related deaths, injury events, injury frequency, illness cases and days lost. The numbers are internally consistent and shown for a single reporting period.
Use this as a model for a concise quantitative disclosure that brings together coverage and the main health-and-safety outcomes for the period.
Illustrative (synthetic) example — Transport and logistics
: we set out the proportion of our people included in the data, then the period’s fatal outcomes, injuries, injury rate, sickness cases and time lost. All figures are internally consistent and intended purely for training.
Use this as a second model with a different sector and a different mix of figures, while still covering the same required datapoints.
How companies report S1-13 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Fluidra, S.A.
Electrical Equipment and Machinery · Spain · 2025
Fluidra’s 2025 Integrated Annual Report provides specific data on accident rates, showing a Total Recordable Incident Rate (TRIR) of 4.30 per million hours for employees and 12.29 for non-employees in 2025, with zero reported work-related health issue cases (p.208). The report also notes a decrease in employee injuries by 13% and details on lost time due to accidents, with 4 days lost for employees in 2025 (p.209, p.210). However, the report lacks clear narrative explanations or percentage values related to these figures, and some contextual information on accident rates remains unclear (p.208).
Assicurazioni Generali S.p.A.
Banks / Diverse Financials / Insurance · Italy · 2024
Assicurazioni Generali S.p.A.’s 2024 Annual Integrated Report provides a covered datapoint on the percentage of employees covered by health and safety measures as of 31/12/2024 (p.165). There is partial narrative context related to the number of fatalities, work-related accidents, and days lost to injuries or accidents, but no headline values are provided (p.107). Notably, the report lacks quotable evidence for other specific health and safety narrative items, leaving some aspects unclear or unreported.
Indra Sistemas, S.A.
Software and Services · Spain · 2025
Indra Sistemas, S.A.'s Sustainability Report 2025 provides a specific figure for the recordable work-related accident rate, reporting 1.7 cases per million hours worked for salaried employees and 0.8 for non-employees on page 125. The report also mentions fatalities due to work-related injuries and ill health for 2024 and 2025, though no detailed numbers are given on that page. However, the report lacks clear disclosure on the number of days lost to injuries, accidents, or fatalities, with only related context found on page 233, making this aspect unclear.
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Check your understanding
Scenarios to work through
Your group has three subsidiaries and one joint operation. Two subsidiaries keep full incident logs, while the joint operation only shares quarterly summaries, so you can see the total headcount but not every worker covered by the same safety tracking method.
QHow do you decide whether the coverage figure is ready to report, and what should you do if the tracking basis is not the same across all parts of the group?
Reveal model answer →Hide answer ↑First, check whether the people included in the health and safety tracking base are the same population you are using for the disclosure. If one part of the group is only partly captured, you should not treat the coverage figure as complete for the whole reporting set. The practical step is to reconcile the scope, identify any gaps in the underlying records, and only then calculate the percentage from a consistent base.
Why this matters · The coverage figure should be built from a consistent population, not stitched together from mixed tracking methods.
A contractor working on your site dies after a workplace accident, and later in the year an employee dies from a work-related illness. The draft report team is unsure whether to separate these events or combine them in one line.
QWhat is the right way to handle the fatality disclosure when the causes differ but both are work-related?
Reveal model answer →Hide answer ↑Count both events in the fatality line, because the disclosure is about deaths linked to work, whether the cause was an accident or an illness. You should not split them into separate headline totals if the reporting line is asking for one combined figure. Keep the underlying records clear so the source of each death is still traceable.
Why this matters · Work-related deaths are counted together even when the trigger is different.
During the year, one site records 14 lost-time accidents and another records 6 more. The safety team also has the total hours worked and can calculate a rate, but the draft narrative only mentions the accident count because the rate looks small.
QShould you report only the number of accidents, or also include the rate based on hours worked?
Reveal model answer →Hide answer ↑Include both the count of accidents and the rate derived from hours worked. The point is to give readers both the absolute number of events and a normalised measure that lets them compare across periods or operations of different size. If the rate is calculated from the total hours worked, make sure the same accident set is used in both figures.
Why this matters · Use both the raw count and the hours-based rate so the picture is complete and comparable.
Your occupational health provider sends a year-end file showing 9 work-related illness cases, but two of those cases were first logged by HR and one was later reclassified as not work-related. The draft table still shows 9 because that was the first number received.
QWhat should you do before finalising the illness figure and the lost-days figure linked to those cases?
Reveal model answer →Hide answer ↑Reconcile the health provider file with HR and case-management records before locking the numbers. If a case is later shown not to be work-related, it should not stay in the illness total. Then check the lost-days figure against the final set of recognised cases so the days lost are tied to the same population of incidents.
Why this matters · Illness and lost-day figures need the same final case basis, after any reclassification is resolved.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
FAQ
Questions this page answers
How do I prepare disclosure S1-13 on own workforce using this page step by step?+−
Use the page’s step-by-step preparation section to work through the disclosure in order, then check the datapoints, evidence pack and common mistakes before drafting. It is designed as practitioner guidance, so you can use it to organise the work rather than treat it as an official source.
What data do I need to collect for S1-13 own workforce before I start drafting?+−
The page says to prepare six datapoints: reporting coverage share, work-related deaths, work accident count, accident frequency rate, work illness cases and lost work days. Start by confirming which of these you can evidence and where each figure will come from.
How should I define the reporting coverage share for S1-13 in practice?+−
The page flags reporting coverage share as a datapoint to prepare, but it does not give a formal definition or calculation method. Use the page’s preparation steps and evidence pack to make sure your chosen scope and calculation are documented and consistent.
Who should own the S1-13 own workforce data collection and sign-off?+−
The page does not assign roles, so ownership needs to be set internally. In practice, this usually means agreeing who gathers the workforce data, who checks the evidence, and who signs off the draft before assurance.
What evidence should I keep for assurance on S1-13 own workforce?+−
The page includes an evidence pack with five items to support assurance readiness, plus six assurance claims to verify. Use those as the basis for your file so each reported figure can be traced back to source records and review checks.
What are the common mistakes to avoid when reporting S1-13 own workforce?+−
The page has a section on common reporting gaps and mistakes, so it is useful for a pre-submission check. Use it to spot missing data, weak evidence, unclear scope or inconsistencies before you finalise the disclosure.
How do I use the S1-13 workbook download to build the disclosure?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf. Use the workbook to organise the datapoints, evidence and assurance checks, then use the page’s draft-output section to turn that into a disclosure.
Can I use the synthetic example on the S1-13 page as a template for my own numbers?+−
Yes, as a structure only. The page says the example disclosures are synthetic and illustrative, so you can use them to see how the data table and narrative might look, but not as a source of real figures or requirements.
What should the draft output for S1-13 own workforce include?+−
The page suggests visualisation ideas, narrative starters and a content-index line for the draft output. That gives you a practical starting point for turning the prepared data into a readable disclosure.
Where can I find real company examples for S1-13 own workforce reporting?+−
The page includes a 'From company reports' table that links to real published reports where the topic is disclosed. Use it to see how others present similar information, while still building your own disclosure from the page’s guidance and your own evidence.
More questions this page can help with
What is the fastest way to turn S1-13 own workforce data into a draft disclosure?How do I check whether my S1-13 own workforce dataset is complete enough for assurance?Which S1-13 own workforce datapoints should be in my evidence pack?How do I avoid common errors when calculating work accident frequency rate for S1-13?What should I put in the narrative starter for S1-13 own workforce?How do I use the printable Library Card for S1-13 own workforce?What does the S1-13 prep and assurance workbook help me organise?How do I document reporting coverage share for S1-13 own workforce?What assurance claims does the S1-13 page say I need to verify?How do I build a clean audit trail for S1-13 own workforce reporting?Can the S1-13 page help me benchmark against published company reports?What should I check before I finalise the S1-13 own workforce content-index line?
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