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ESRS S1: Own Workforce · 2026-5010-final

Disclosure Requirement S1-15

Remuneration

Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official EFRAG source.

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Reviewed by Dr Ross Kurinko · Sustainability Reporting Trainer LRA educational guidance · Not issued or endorsed by EFRAG

To prepare this disclosure

2datapoints↓ 6claims to verify↓ 5evidence areas↓ 3report examples↓

Disclosure focus

This disclosure asks an organisation to explain how pay and other forms of remuneration for its own workforce are set and used in practice. The focus is on whether remuneration arrangements are aligned with the organisation’s approach to people management, including how they may support fair treatment, retention, motivation and performance across the workforce.

In practical terms, the reporting should cover the organisation’s own employees as a whole, not just a few selected sites or senior roles. The emphasis is on the main remuneration principles, how they are applied across the business, and any important differences or features that affect different groups of workers.

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.

Have you fixed which pay comparison you are using for the gap figure, and who sits inside each side of that comparison? Have you decided which pay ratio you will show, and which two pay amounts it compares? Are the figures taken from the same reporting period and pay basis across both measures? Can each number be traced back to a source record or payroll extract you can explain? Have you agreed the working definitions for pay, so the same items are counted on both sides?

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner

Pay gap figure Capture the reported percentage difference in pay between the relevant groups, using the organisation’s chosen basis and period consistently. Payroll extracts, pay-gap calculation workbook, and the underlying employee grouping logic used for the reporting period. Reward / HR analytics

Pay ratio figure Capture the reported ratio comparing pay between the relevant pay levels or groups, using one consistent method and reporting period. Payroll data, ratio calculation file, and the definition used to select the two pay points or groups. Reward / HR analytics

＋ Show S1-15 sub-elements (LRA working checklist)

Calculate the percentage difference in pay between the two groups being compared, using the method set out in the source disclosure. Work out the pay ratio between the two groups being compared, using the method set out in the source disclosure.

How to prepare it

1Set the reporting boundary first: decide which workforce population and pay records will sit inside this disclosure, so the two figures are built from the same defined group.

2Agree the calculation basis for each metric: one measure should show the pay difference as a percentage, and the other should show the relationship between pay levels as a ratio.

3Pull together the underlying payroll and HR evidence used for the calculations, and make sure the source data can support how the workforce group was defined.

4Prepare the reported outputs in the required form, keeping the percentage gap and the pay ratio separate and clearly labelled.

5Record any exclusions, scope choices, or changes in method so a reviewer can see why the numbers were prepared the way they were and whether anything changed from the prior period.

6Check the final disclosure against the official source text and the underlying records to confirm the scope, definitions, calculations, and presentation all align before publication.

Request the data

Request the pay gap and pay ratio data from Reward / Pay Analytics

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

What pay gap and pay ratio figures should we use for the reporting period, and what source data and method sit behind them?

Use your organisation’s own pay and reward language first, then map it to the reporting disclosure. For example, ask for your pay gap and pay ratio outputs, the underlying pay files, and the method used to calculate them. Keep the request in the terms your team already uses, and check the source material before sign-off.

Weak request

Please provide the ESRS S1:S1-15 remuneration data and evidence for the disclosure.

Why it fails: This uses framework language that many internal owners will not recognise, and it does not say which figures, source files, or calculation details are needed. It is too vague to help the owner pull the right data quickly or to let the reviewer trace the numbers back to the source.

Better request

Please send the latest pay gap and pay ratio outputs for [period], together with the source export, calculation basis, scope, and any notes on adjustments or assumptions. Use your team’s usual pay and reward terms, and confirm which version is approved for reporting.

Formal email template

Subject: Request for pay gap and pay ratio data for [reporting period]

Hello [name/team],

We are preparing the sustainability reporting pack and need your help with the pay gap and pay ratio figures for [reporting period].

Please send:
- the final figures you would use for [reporting period]
- the source file(s) or export(s) used to produce them
- the calculation basis and any assumptions or adjustments
- the population and boundary included
- the internal category labels used in the analysis
- any notes needed to explain the output clearly

If there are multiple versions, please confirm which one is the latest approved version and who reviewed it.

Please share the material by [date]. If anything is unclear, I’m happy to adapt this to your team’s usual terms.

Thanks,
[Your name]

Short Teams / Slack version

Hi [name] — could you send the latest pay gap and pay ratio figures for [period], plus the source file and any notes on how they were calculated? Please include the boundary, population, and the internal labels used. Thanks.

Industry examples

Manufacturing

Context. A plant-based group with hourly and salaried staff, multiple sites, and a central reward team.

Adapted request. Hi [name] — for [period], could you share the pay gap and pay ratio figures for the group, plus the payroll export, the calculation basis, and any site or worker-group exclusions? Please include the internal labels you use for hourly, salaried, and bonus-eligible staff.

Example response. Attached: 1) approved pay gap workbook, 2) payroll extract from [system], 3) notes showing the group boundary, included staff, and calculation basis, 4) version history and reviewer sign-off.

Financial services

Context. A regulated business with multiple legal entities and a central compensation team.

Adapted request. Hello [name/team], please provide the latest pay gap and pay ratio pack for [period] across the entities in scope, including the compensation file, the method used, and any entity-level notes. Please use the internal grade and population labels your team already works with.

Example response. Returned: entity list in scope, compensation analysis workbook, source HR/pay export, methodology note, and confirmation of the approved version for reporting.

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 two figures were calculated, including the pay basis used, the employee population included, and any exclusions or adjustments applied before the numbers were finalised.

Context note

Explain what the percentage gap and the pay multiple indicate about the relationship between higher- and lower-paid workers, and note whether the figures point to a wider or narrower spread in pay.

Fluctuation statement

If either figure has changed materially, link the movement to the underlying workforce or pay-setting factors that drove it, such as changes in headcount mix, pay awards, or the composition of the group included in the calculation.

Content index entry

S1-15 Remuneration — [location / page] / [notes]

Download Centre

Preparation tools & forms

Professional preparation tools for S1-15 — 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.

Free · Community members

01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧

Go deeper · S1-15

Learn to prepare this disclosure end-to-end

This guide covers one Disclosure Requirement. The ESRS / CSRD Reporting course walks the full European workflow — double materiality, datapoints, evidence and assurance — with exercises on your own data.

Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.

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Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check

We prepared the coverage figure using our own payroll and HR records, then checked that the population included the relevant staff group for the reporting period and that any exclusions were deliberate and documented.Assurer will probe whether the headcount basis was complete, whether anyone was left out without a clear reason, and whether the period and population used for the calculation were consistent with the published figure.['Payroll extract and HR master data used for the calculation', 'Population reconciliation showing included and excluded employees', 'Documented scope note explaining any exclusions or boundary choices', 'Version-controlled calculation file with period-end cut-off']

For the pay-gap figure, we used gross hourly pay data for men and women and built the calculation from the ordinary salary element plus other pay items available across the workforce, with the method set out in our working papers.Assurer will test whether the pay inputs were defined consistently, whether the same pay components were used across the dataset, and whether the method was applied in a way that could distort the result.['Calculation methodology note', 'Source payroll data showing gross hourly pay inputs', 'List of pay components included in the model', 'Sample recalculation or spreadsheet audit trail']

We disclosed the gap figure together with the contextual split by employee group and/or country where that helped explain the result, and we kept the underlying breakdowns that support the published numbers.Assurer will check whether the contextual breakdowns match the reported figure, whether the grouping logic was applied consistently, and whether the supporting detail can be traced back to source data.['Segmented calculation outputs by employee group and/or country', 'Source data mapping to each segment', 'Narrative explaining why the contextual split was used', 'Reconciliation from segment totals to the published figure']

We calculated the annual pay ratio using the full employee population in scope, the base salary element, and the cash, benefits-in-kind and long-term incentive items covered by our pay policy, then checked the result against the source records before sign-off.Assurer will probe whether the pay elements were selected correctly, whether the employee population was complete, and whether the ratio was recalculated accurately from the underlying records.['Remuneration policy extracts showing included pay elements', 'Employee population listing used in the ratio', 'Source payroll and reward data for each component', 'Independent recalculation or review sign-off']

We published the ratio between the top earner and the middle employee after confirming the ranking method, the treatment of the top earner, and the exclusion of that individual from the median population.Assurer will test whether the ranking and median approach were applied correctly, whether the highest-paid person was handled consistently, and whether the disclosed ratio can be reproduced from the source data.['Ranking and median calculation worksheet', 'Employee pay dataset used for the ratio', 'Explanation of how the top earner was identified and excluded from the median set', 'Reperformance check or internal review evidence']

Before publication, we documented the approach used to compile both pay metrics, including the data sources, the calculation steps, and the main judgement calls made in the process.Assurer will probe whether the methodology was sufficiently clear to reproduce the figures, whether key assumptions were disclosed, and whether the process was applied consistently across both metrics.['Methodology paper covering both metrics', 'Data lineage from source systems to final disclosure', 'List of assumptions, judgements and exclusions', 'Approval record showing review before publication']

Evidence pack to prepare

The governing policy or written commitment behind this disclosureA methodology / definition note setting out how the disclosure was scoped and preparedSource-system exports the figures or facts were drawn fromThe internal approval / sign-off record for the disclosure before publicationMinutes or records evidencing the relevant engagement or consultation

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 owner

The team asks the wrong pay or HR contact, so the figures come from someone who does not hold the source records.

Framework language first

People ask for the data using disclosure jargon instead of the organisation’s own payroll terms, which slows down the handover and creates confusion.

Scope not pinned down

The request does not state which worker groups, entities, or locations are in scope, so different teams pull different populations.

Wrong period basis

The data is gathered for the wrong reporting window or cut-off date, so the numbers do not match the period being reported.

Mixed counting method

One team uses headcount while another uses full-time equivalent or another basis, so the pay gap and pay ratio are built from unlike measures.

Source labels lost

The original payroll or HR file names and field labels are stripped out during collection, making it hard to trace each figure back to its source.

Separate groups merged

People combine groups that should stay apart, such as different worker categories or pay populations, and the result no longer reflects the underlying records.

Evidence trail missing

The pack is assembled without the supporting file details, version history, or sign-off record, so no one can show how the numbers were checked.

＋ Show 5 more− Show fewer

Where judgement is often needed

Choose one pay-gap basis and keep it consistent

Decide whether the gap is built from base pay, total cash, or another internal pay measure, then explain the basis used and keep it stable unless you clearly explain a change.

Set the comparison group at the same point in time

Use one clear cut-off date for the workforce and the comparator group, and disclose that date so readers can see who was in scope for the calculation.

Handle joiners, leavers, and people with partial-year service consistently

State whether people who were hired, left, or worked only part of the year are included, excluded, or time-adjusted, and apply the same rule across the calculation.

Define the worker population where local labels differ

If job titles or employment categories vary by country, map them to one internal grouping rule and explain the mapping so similar roles are treated the same way.

Decide how to treat acquisitions and disposals in the reporting boundary

Explain whether newly acquired or sold entities are included from the transaction date or from the full reporting period, and note any boundary change that affects comparability.

Choose between actual payroll data and estimates where records are incomplete

If some pay elements are missing, say which figures are measured and which are estimated, describe the method used, and flag the parts of the result that are less precise.

Round in a way that does not distort the result

Use one rounding rule for the percentages and the ratio, apply it consistently, and make sure the rounded figures still reflect the underlying calculation.

Protect personal data by grouping small populations

Where the workforce slice is too small to show safely, aggregate it into a broader group, explain the privacy-driven suppression or grouping approach, and keep the method consistent.

＋ Show 5 more− Show fewer

Examples

Illustrative examples

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

Illustrative (synthetic) example — Manufacturing

: we show a simple pay comparison for our workforce, split by women and men, using average pay and a like-for-like pay comparison. The figures below are illustrative and internally consistent.

Illustrative disclosure showing a workforce pay gap percentage and a pay comparison ratio for a manufacturing reporter.

Illustrative pay comparison for our workforce (people / %)

Average pay4852

Headcount240260

Illustrative (synthetic) example — Financial services

: we present a second, different workforce pay comparison for our group, again split by women and men. The numbers are illustrative and internally consistent.

Illustrative disclosure showing a workforce pay gap percentage and a pay comparison ratio for a financial services reporter.

Illustrative pay comparison for our group (people / %)

Average pay5743

Headcount180120

Company reportsReal published reports

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How companies report S1-15 in practice

Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

Sanoma Oyj

Education Services · Finland · 2025

Open report →

Sanoma Oyj's 2025 Annual Report provides a covered datapoint on the gender pay gap, reporting a 16% gap for 2025 compared to 17% in 2024, along with annual total remuneration figures on page 115. Additional gender-related data include employee gender distribution on page 112 and gender ratios in learning and performance reviews on page 114, but these do not directly address pay gap or remuneration ratios. There is no quotable evidence found elsewhere in the report specifically addressing remuneration ratios beyond the gender pay gap, indicating some gaps in comprehensive disclosure on this topic.

EDP, S.A.

Electric Utilities / IPP / Energy Traders · Portugal · 2025

Open report →

EDP, S.A.'s 2025 Integrated Annual Report provides several data points related to pay ratios and gender pay gaps, including the ratio of the highest-paid individual’s compensation to the median (p.137, p.529) and pay ratios by gender across different professional categories such as technicians, specialists, and supervisors (p.530). The report also references pay equity mechanisms like the Gender Equality Plan aimed at mitigating pay disparities (p.136) and includes additional social and employee indicators related to pay ratios and human rights (p.555, p.585). However, no comprehensive narrative explanation or detailed analysis of these pay ratio figures was found in the report.

Indra Sistemas, S.A.

Software and Services · Spain · 2025

Open report →

Indra Sistemas, S.A.'s Sustainability Report 2025 provides data on gender diversity in senior management, showing a predominantly male composition with percentages rising from 75.0% in 2021 to 88.2% in 2025 (p.109). The report also includes employee metrics by gender over several years (p.92) and mentions the gender pay gap and remuneration for similar jobs, though the disclosure on pay gap specifics is unclear or partial (p.91, p.117). Notably, there is no clear, detailed disclosure of the gender pay gap figures or a comprehensive narrative on this topic, leaving some aspects of the pay equity disclosure incomplete or ambiguous.

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Check your understanding

Scenarios to work through

A preparer has the latest payroll extract for the year-end workforce and a separate file for the chief executive’s total pay. The team can calculate the gap between average worker pay and the leader’s pay, but they have not yet checked whether the same basis is used for both figures.

QWhat should the preparer verify before finalising the pay-gap figure?

Reveal model answer →Hide answer ↑

They should confirm that both sides of the comparison are built on the same measurement basis and cover the same reporting period, so the gap is not distorted by mismatched inputs. If the underlying data are not aligned, the figure should be recalculated before it is used in the disclosure.

Why this matters · A pay-gap figure is only useful if the two pay amounts being compared are prepared on a consistent basis.

A company has a large bonus accrual for senior staff, while most other employees receive only fixed salary and a small allowance. The preparer is unsure whether to compare total pay or only base salary when preparing the remuneration disclosure.

QHow should the preparer decide what to compare for the remuneration gap and ratio information?

Reveal model answer →Hide answer ↑

They should use the pay measure that reflects the organisation’s chosen remuneration basis consistently across the comparison, rather than mixing salary-only data for one group with full pay for another. The aim is to make the gap and ratio meaningful and comparable within the same reporting set.

Why this matters · Use one consistent pay basis across the comparison so the result is not misleading.

The finance team has calculated a pay ratio of 18:1 using the chief executive’s annual pay and the median employee’s annual pay. A reviewer asks whether the ratio alone is enough, or whether the underlying pay-gap information also needs to be prepared.

QWhat should the preparer do with the two remuneration data points?

Reveal model answer →Hide answer ↑

They should prepare both pieces of information, because the disclosure covers a percentage gap and a pay ratio as separate data points. Each tells a different part of the story, so both need to be available and checked before sign-off.

Why this matters · Treat the pay gap and the pay ratio as distinct outputs, not as substitutes for one another.

A group prepares its sustainability report centrally, but payroll data sit in several country systems. One subsidiary has not yet confirmed its year-end figures, and the group team is considering using an estimate so the report can be issued on time.

QCan the preparer finalise the remuneration disclosure without the missing subsidiary data?

Reveal model answer →Hide answer ↑

Not safely. The preparer should first obtain or validate the missing input needed for the comparison, because the remuneration figures depend on complete and aligned data. If an estimate is used, it should be clearly controlled and reviewed before the disclosure is signed off.

Why this matters · Complete and checked source data are needed before the remuneration comparison is finalised.

Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

ESRS

S1-15

within ESRS S1: Own Workforce

Open official source →

Primary

Related & explore

Policies (Own Workforce) → Guide ✓Social Protection → Guide ✓Disabilities → Guide ✓Training →Health & Safety → Guide ✓Work-life Balance → Guide ✓Show all 15 related disclosures →

More in ESRS S1 →Browse full catalogue →Disclosure Library home →Search all disclosures →

Go deeper · S1-15

Learn to prepare this disclosure end-to-end

Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.

Explore the ESRS / CSRD course →

FAQ

Questions this page answers

For S1-15 Own Workforce, what data do I need to prepare the pay gap figure and pay ratio figure on this page?+−

The page says the two datapoints to prepare are the pay gap figure and the pay ratio figure. Use the plain-language explainer and the step-by-step preparation section to confirm what you need before drafting the disclosure.

How do I use the step-by-step 'how to prepare' section for S1-15 Own Workforce?+−

Use it as a practical checklist to move from understanding the disclosure to gathering the right inputs and shaping a draft. The page is designed to help you prepare the disclosure rather than to act as an official source.

What should I include in the evidence pack for S1-15 Own Workforce assurance readiness?+−

The page includes an evidence pack with five items to support assurance readiness. Use those items alongside the six assurance claims to verify so you can show how the figures were built and checked.

What are the six assurance claims to verify for S1-15 Own Workforce, and how do I use them?+−

The page lists six assurance claims in a claim/risk/evidence format. Use them to test whether your data, method and supporting documents are strong enough for review before you finalise the disclosure.

What common reporting gaps or mistakes should I watch for when drafting S1-15 Own Workforce?+−

The page includes a list of common reporting gaps and mistakes to help you avoid weak or incomplete reporting. Use that section as a pre-submission check against your draft, data and evidence pack.

How can I use the synthetic illustrative example disclosures on the S1-15 Own Workforce page?+−

They are there to show what a draft disclosure can look like, including a quantitative table. Treat them as examples only and use them to shape your own wording, layout and data presentation.

What is in the S1-15 Own Workforce Prep & Assurance workbook, and when should I use it?+−

The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it while preparing the disclosure and building your assurance evidence so you can track inputs, checks and draft outputs in one place.

How do I use the printable Library Card PDF for S1-15 Own Workforce?+−

The Download Centre includes a printable Library Card in PDF format. It is a practical companion for working through the page content and keeping the key preparation and assurance points to hand.

How do I turn the S1-15 Own Workforce data into a draft disclosure?+−

The page has a draft-output section with visualisation ideas, narrative starters and a content-index line. Use those elements to turn your prepared figures and evidence into a clear first draft.

Can I use the 'From company reports' table to find real examples of S1-15 Own Workforce reporting?+−

Yes. The page includes a table linking to real published reports at the pages where the topic is disclosed, which can help you see how others present similar information in practice.

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Datapoint 1	✓ p.213	unclear	✓ p.87
Datapoint 2	✓ p.214	—	✓ p.90

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Remuneration

Key datapoints to prepare

How to prepare it

Request the pay gap and pay ratio data from Reward / Pay Analytics

Notes that turn data into a disclosure

Preparation tools & forms

For each claim, check the evidence

Evidence pack to prepare

Common reporting gaps

Mistakes to avoid when collecting the data

Where judgement is often needed

Illustrative examples

How companies report S1-15 in practice

Scenarios to work through

Related framework references

Questions this page answers

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