Workers who are not employees
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 GRI source.
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This disclosure asks an organisation to explain how many people work for it but are not on its payroll as employees. In practice, that means identifying the main groups of non-employee workers it relies on, such as contractors, agency workers, or other outsourced labour, and describing their role in the business. The point is to show the scale and nature of this workforce, not just the headcount of direct employees.
The practical focus is on coverage across the organisation’s operations, not only at flagship sites or headquarters. A useful report should reflect where non-employee workers are used, how significant they are in different parts of the business, and whether the organisation’s picture is complete across sites, functions, and geographies. If the workforce mix varies materially, that variation should be made clear rather than averaged away.
* This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official GRI source.
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
| Datapoint | What to capture | Evidence hint | Owner |
|---|---|---|---|
| Non-employee worker mix | The total count of non-employee workers whose day-to-day work is directed by the organisation, plus a plain description of the main worker types and how each is engaged contractually. | Contractor/vendor workforce schedules, agency labour reports, procurement or HR records showing worker categories and engagement terms. | HR / Procurement |
| Non-employee work types | The total count of non-employee workers whose day-to-day work is directed by the organisation, plus a plain description of the kinds of tasks or roles they carry out. | Workforce listings, project rosters, service descriptions, and manager attestations on the activities performed by external workers. | HR / Operations |
| Counting method used | A clear note on how the figure was built, including whether it is a simple person count, an FTE-style measure, or another approach used for non-employee workers. | Methodology note, reporting workbook, and any calculation logic showing the counting basis applied across the population. | Finance / HRIS |
| Timing basis used | A clear note on whether the figure reflects the position at period end, an average over the period, or another timing basis used for non-employee workers. | Reporting methodology, period snapshots, and calculation files showing whether the number comes from a closing point-in-time or an average across the period. | Finance / HRIS |
| Worker count swings | A short explanation of any material rises or falls in non-employee worker numbers during the period and compared with the prior period. | Month-by-month workforce trend reports, contract start and end logs, and commentary from HR, procurement, or operations on the drivers of change. | HR / Procurement |
Show GRI 2-8 sub-elements (LRA working checklist)
- Flag any material rise or fall in non-employee worker numbers during the period, and explain how that compares with earlier periods.
- State the counting approach and any key assumptions, including whether you used a year-end figure, a period average, or another basis.
- State the counting approach and any key assumptions, including whether you used a simple headcount, FTEs, or another basis.
- Give the total number of non-employee workers whose work is directed by the organisation, and outline the main worker types plus how they are engaged.
- Give the total number of non-employee workers whose work is directed by the organisation, and outline the kinds of tasks they carry out.
LRA working checklist - paraphrased; see official source
- Set the boundary first: decide which non-employee workers fall within the organisation’s control for this disclosure, so you are counting the right population before you start gathering figures.
- Build the worker profile from your records: capture the total number, then note the main worker categories and the kind of contractual arrangement each group has with the organisation.
- Add the work-content detail: for the same controlled non-employee population, record the main kinds of tasks or roles they carry out.
- Choose and state your counting method clearly: explain whether you used a simple headcount, a full-time equivalent approach, or another method, and say whether the figure reflects the period-end position, an average for the period, or a different timing basis.
- Check for movement in the numbers: look for notable rises, falls, or other changes in the non-employee workforce during the year and compared with earlier periods, then prepare a short explanation of the drivers.
- Before finalising, compare your draft against the official source and your underlying evidence, and document any exclusions, assumptions, or changes in approach so the reported information can be traced and understood.
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Use your organisation’s own labels first, then map them to the reporting disclosure. For example, if you say contractors, agency staff, casual labour, outsourced site teams or contingent labour internally, use those terms in the request and only translate them later for reporting. Check the official source before sign-off.
Please provide the GRI 2-8 data on workers who are not employees, including methodology and fluctuations.
Please send the non-payroll worker numbers for [period] for [site/business unit], using your own category names. Include the total count, the kinds of work they did, how you counted them, whether the figure is a snapshot or an average, the source file/system, and any major rises or falls with the reasons. We will map your terms to the reporting disclosure after review.
Formal email template
Subject: Request for non-employee worker data and notes for [reporting period] Hi [name/team], We are preparing the sustainability reporting pack for [reporting period] and need your help with the non-employee workforce information for [business unit / site / country]. Please send: - the total number of people in scope under our control who are not on payroll, for [reporting period] - the main categories you use internally for these workers - the kinds of work they carried out - the way the figure was compiled (for example, headcount, FTE, period average, or end-date snapshot) - the date point or averaging approach used - any notable rises or falls during the period, and the main reasons for them - the source system or file used, plus any assumptions or exclusions Please use your own operational terms in the response first, then we will map them to the reporting disclosure. A simple table and a short note are fine. Please also include the person who can confirm the figures. If helpful, I can send a template. Please check the official source before sign-off. Thanks, [preparer name]
Short Teams / Slack version
Hi [name] — could you share the non-payroll worker numbers for [period] for [site/business unit]? Please include your internal worker categories, what work they did, how you counted them (headcount/FTE/average/end date), any big changes and why, plus the source file/system. Use your own terms first; we’ll map them later. Thanks.
Construction
Context. A project-based business uses labour agencies, subcontractors and self-employed trades on active sites.
Adapted request. Please share the site-level count of non-payroll labour for [period], split by your internal labels such as agency labour, subcontract trades and self-employed operatives. Include the work they carried out, whether you counted them by headcount or average presence, the source register, and any spikes linked to project start-up, peak activity or demobilisation.
Example response. For [period], Site A recorded 120 agency labourers, 85 subcontract trades and 15 self-employed operatives. The team counted by weekly average from site access records and labour booking sheets. The main increase was in Q2 during concrete and fit-out works; numbers fell in Q4 after handover.
Retail / Logistics
Context. A distribution network relies on temporary warehouse staff, agency pickers and seasonal delivery support.
Adapted request. Please provide the non-payroll workforce figures for [period] across the distribution centres, using your internal terms for temporary, agency and seasonal staff. Include the type of work they did, whether the number is an end-date snapshot or an average, the system used to compile it, and any seasonal peaks or contract changes.
Example response. For [period], the network used 310 temporary warehouse staff, 140 agency pickers and 60 seasonal delivery workers. The figures are an average across the period, compiled from the workforce planning system and agency invoices. The main rise was in November and December due to peak trading demand.
The full request pack — response form, data table, evidence metadata and sign-off — is in the Download Centre.
LRA training templates — adapt them to your organisation, and check the official source before sign-off.
State how you counted the controlled non-employee workforce, including the unit used for the figure and whether it reflects a point in time, an average, or another basis, together with any key assumptions.
Explain what the total means in practice by naming the main worker groups, their contractual set-up, and the kinds of work they carry out for the organisation.
Describe any material rises or falls in the number of controlled non-employee workers during the year, and compare the period with the previous one where that helps explain the movement.
GRI 2-8 Workers who are not employees — [location / page] / [notes]
Professional preparation tools and forms for GRI 2-8. Each download includes a concise “How to use” guide.
| Claim | Risk | Evidence to check |
|---|---|---|
| The information reported for this disclosure reconciles to the underlying source records. | What is reported cannot be traced back to the systems or documents it was drawn from, or does not tie out to them. | calculation_workbook reconciling the reported value to source_system_export |
| The information reported for this disclosure is current as at the reporting date. | The disclosure reflects a different period, a cut-off before the reporting date, or stale data carried over from a prior period. | approval_record showing the data cut-off date and the period covered |
| The scope behind the information reported for this disclosure is applied consistently. | Parts of the organisation are silently in or out of scope, or the scope differs from the prior period without that change being explained. | methodology defining the scope and a site_register of what it covers |
| Everything in scope is included in the information reported for this disclosure — nothing material is left out. | Parts of the population that should be reported are omitted, understating or overstating the disclosure. | site_register of the full population vs the calculation_workbook of what was actually included |
- The governing policy or written commitment behind this disclosure
- A methodology / definition note setting out how the disclosure was scoped and prepared
- Source-system exports the figures or facts were drawn from
- The internal approval / sign-off record for the disclosure before publication
- Minutes or records evidencing the relevant engagement or consultation
- 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.
- Ask the wrong owner
The count is requested from HR alone, even though the live records sit with procurement, site managers, or the agency lead.
- Use framework language too early
The data request is sent in reporting jargon instead of the organisation’s own terms for contractors, agency staff, or outsourced labour.
- Leave the boundary vague
Teams mix people from different entities, sites, or service lines because no one has fixed which parts of the business are in scope.
- Use the wrong time basis
A year-end snapshot is taken when the source system only supports an average over the period, or the reverse.
- Mix counting methods
Headcount and FTE figures are blended in one extract, so the total no longer matches the method used to build it.
- Lose the source labels
The original category names from the operational system are stripped out, so it is no longer clear which worker type each number came from.
- Combine separate groups
Different kinds of non-employee workers are rolled into one pool before the data is checked, which hides the split needed for the narrative.
- Miss the evidence trail
The file is saved without the notes, extracts, and version history needed to show where the figures came from and who checked them.
- Skip sign-off
The draft numbers are passed on without a named reviewer confirming the scope, method, and source data before disclosure drafting starts.
- Set the boundary for outsourced and agency labour
Decide which non-staff people are under your control for this disclosure, explain the rule you used, and keep it consistent unless a boundary change is needed and then explain the change.
- Handle country-by-country worker labels carefully
Where local labour categories do not map neatly onto your group’s own labels, use a clear internal mapping, explain the basis, and note any material differences in how the same role is classified across locations.
- Choose one counting basis and say why
If you could present the population as a simple count, a full-time equivalent view, or another basis, pick the method that best fits your data, state it plainly, and avoid mixing bases without explanation.
- Fix the timing point for the figure
If your systems can show an end-date snapshot, a period average, or another timing view, disclose which one you used and make sure readers can tell how that choice affects the number.
- Decide how to treat people on the edge of scope
For workers whose status changes during the year, or who sit partly inside and partly outside your control, explain the inclusion rule you applied and whether they are counted once, by period, or not at all.
- Explain acquisition and disposal effects
If buying or selling operations changes the pool of non-staff workers, say whether the current year includes the new or exited operations for the full period or only from the transaction date, and describe the impact on comparability.
- Use estimates only with a clear basis
When exact records are not available, use a reasonable estimate, state the source and method behind it, and distinguish estimated figures from directly recorded ones where that matters.
- Round numbers without hiding the method
If you round the total or any breakdown, apply the same approach across the disclosure, and make sure the published figure still aligns with the underlying data and any totals shown.
- Protect privacy when the workforce is small
If a detailed split could identify individuals, aggregate the data to a safer level, explain that the presentation has been grouped for privacy reasons, and keep the total understandable.
- Explain unusual swings between periods
If the number changes sharply during the year or versus the prior year, describe the operational reason in plain language so readers can see whether the movement is due to hiring, contract changes, project timing, or another driver.
Synthetic, written by LRA — not from a company report, not text from any standard.
| Worker type / contract form | Agency cleaners | Maintenance technicians | Reception cover staff | Total |
|---|---|---|---|---|
| Short-term service contract | 96 | 24 | 18 | 138 |
| Longer assignment contract | 12 | 22 | 8 | 42 |
We counted 180 non-employee workers whose day-to-day work we direct, using a headcount taken at the period end. Most were agency cleaners and maintenance technicians on short-term service contracts, and the main work involved site cleaning, basic repairs, and reception cover. The number rose sharply in the final quarter because of a new contract win, then eased slightly after the mobilisation phase.
| Worker type / contract form | Labour-hire packers | Seasonal line operatives | Quality check support | Total |
|---|---|---|---|---|
| Assignment-based contract | 38 | 20 | 6 | 64 |
| Seasonal contract | 4 | 4 | 2 | 10 |
Our year-end headcount for controlled non-employee workers was 74, made up mainly of labour-hire packers and seasonal line operatives on assignment-based contracts. They mainly handled packing, pallet movement, and quality checks; the total was lower than the prior year because the summer peak was shorter, although it still climbed above the quarterly average during harvest processing.
How to turn the collected data into a draft disclosure. The charts below are drawn from the illustrative figures above — swap in your own data.
Other views you could build
- Non-employee workforce by worker type — stacked bar: How the controlled non-employee workforce is split across the main worker categories, so readers can see which types make up the total.
- Non-employee workforce by contract relationship — bar: The number of controlled non-employee workers grouped by the kind of contractual arrangement they have with the organisation.
- Work performed by non-employee workers — stacked bar: The main kinds of tasks or roles carried out by controlled non-employee workers, with each work type shown as part of the overall total.
- Counting basis used for the workforce figure — table: Whether the figure is based on individual people, full-time equivalent, or another counting approach, alongside the basis used for the period covered.
- Period basis for the workforce figure — table: Whether the number reflects the position at period end, an average over the period, or another timing basis, and any related assumptions.
What separates a figure from a disclosure.
We used 120 non-employee workers.
We used 120 non-employee workers, mainly agency operatives and contractors doing warehouse and delivery work, counted as headcount at the period end.
We used 120 non-employee workers at the year end, mainly agency operatives and contractors doing warehouse and delivery work, counted as headcount; the total was 20 higher than last year because we added a seasonal fulfilment shift.
Real reports where this topic is disclosed. The confidence label shows how closely each match maps to GRI 2-8 — these are report practice, not exact disclosure examples.
| Company | Sector · Country | Year | Match | Page | Report | Assurance | |||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Interconexión Eléctrica S.A. E.S.P. | Electric Utilities / IPP / Energy Traders · Colombia | 2024 | Partial | p. 146 →p. 132 →p. 150 → | ISA Integrated Management Report 2024 → | ey | |||||||||||||||||||
Evidence in Interconexión Eléctrica S.A. E.S.P.’s reportWhat the report shows Interconexión Eléctrica S.A. E.S.P.'s 2024 Integrated Management Report provides data on volunteer employees and trees planted by country, with a total of 425 volunteers and 2,450.75 trees planted in Colombia alone (p.109). The report also states there were no significant changes relevant to the disclosure (p.131). However, there is no clear information on methodology or narrative for certain narrative items (b-i and b-ii), and some expected data points such as narrative item (a-ii) are not found in the report.
Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict. Datapoint coverage
Source trail
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| REN - Redes Energéticas Nacionais, SGPS, S.A. | Water Utilities · Portugal | 2025 | Partial | p. 276 →p. 275 →p. 245 → | REN Integrated Report 2025 → | bsi | |||||||||||||||||||
Evidence in REN - Redes Energéticas Nacionais, SGPS, S.A.’s reportWhat the report shows REN’s 2025 Integrated Report provides a covered datapoint on the number of full-time equivalent employees, reported as 1,511, detailing the most common types of workers and their contractual relationships (p.647). The report also includes consolidated and individual financial statements relevant to the disclosure (p.464). However, there is no quotable evidence found for narrative items (a-ii) and (c), and the methodology or narrative for item (b-ii) remains unclear, indicating gaps in the completeness of the disclosure.
Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict. Datapoint coverage
Source trail
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| ASE Technology Holding Co., Ltd. | Semiconductors · Taiwan | 2024 | Partial | p. 262 →p. 51 →p. 28 → | 2024 CSR Report → | Deloitte | |||||||||||||||||||
Evidence in ASE Technology Holding Co., Ltd.’s reportWhat the report shows ASE Technology Holding Co., Ltd.'s 2024 CSR Report provides detailed data on workforce composition, including the percentage of regular and contract employees in the Semiconductor Assembly, Testing and Materials business unit (19.96% regular, 0.01% contract) on page 249, and a gender breakdown showing 81.7% male and 18.3% female employees on page 165. The report also includes a calculation related to human capital return on investment on page 253, linking total revenue, operating expenses, and employee-related expenses. However, there is no clear narrative or methodology provided for some disclosure items (b-i and b-ii), and no information was found for narrative item (c).
Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict. Datapoint coverage
Source trail
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A facilities team uses 48 agency cleaners and 12 security contractors at year end. The cleaners work under site supervisors, while the security staff are engaged through a service provider with different shift patterns.What should you decide to include in the narrative about these non-staff workers, and how should you describe them?
A logistics business has 30 temporary warehouse pickers and 20 outsourced maintenance technicians. The pickers are counted as headcount, but the technicians are scheduled through a contractor and are only present on certain days.How should you explain the basis used to compile the figures so a reader understands what the total means?
A retailer reports 90 non-staff workers at the year end, but the number ranged from 60 to 140 during the year because of a seasonal peak. The draft note only gives the year-end figure.What extra explanation is needed so the reported number is not misleading?
A manufacturing site used 70 contract workers in the first half of the year and 25 in the second half after automation reduced the need for labour. Last year the site used 40 throughout the year, so the movement is material.What should you say about the change in numbers across the year and compared with the prior year?
See how companies actually report GRI 2-8 — drawn from their own published reports, with the exact pages, and an LRA AI-assistant that works through it with you. Available to LRA Community members and to students throughout their platform access.
How this disclosure maps across the major reporting frameworks.
For GRI 2-8, what data do I need to gather before I start drafting the disclosure?
The page says to prepare five datapoints: the mix of non-employee workers, the types of work they do, the counting method, the timing basis, and any swings in worker counts. Use those as your starting checklist before you draft anything. ↑ section
How do I use the step-by-step 'how to prepare' section for GRI 2-8 in practice?
Use it as a working sequence for scoping, collecting the right inputs, and turning them into a draft disclosure. It is designed to help a sustainability, HR or data owner move from raw data to a report-ready narrative. ↑ section
What should I include in the scope for non-employee workers under GRI 2-8?
The page focuses on non-employee worker mix and non-employee work types, so scope should be set around which non-employees are included and how their work is grouped. Keep the scope clear enough that the counts and narrative can be traced back to the same population. ↑ section
How do I decide which counting method to use for GRI 2-8?
The page tells you to disclose the counting method used, so you need to choose a method that fits your data source and can be explained consistently. The key is to document it clearly and keep it aligned with the timing basis and any worker count swings. ↑ section
What does 'timing basis used' mean for the GRI 2-8 disclosure in this workbook?
The page flags timing basis as a datapoint to prepare, so you should record the point in time or period your counts relate to. Make sure the timing basis is stated clearly enough for a reviewer to understand how the numbers were produced. ↑ section
How should I explain swings in worker counts in the GRI 2-8 narrative?
The page says to prepare worker count swings, so you should identify any material changes and explain them in plain language. Keep the explanation tied to the same scope and counting approach used in the rest of the disclosure. ↑ section
Who should own the GRI 2-8 data collection and sign-off process?
The page is aimed at sustainability/ESG managers, HR and data owners, and assurance reviewers, so ownership should sit with the people who can source, check and explain the data. Assign clear responsibility for the numbers, the method, and the evidence pack. ↑ section
What evidence pack do I need to make GRI 2-8 assurance-ready?
The page includes an evidence pack with five items for assurance readiness, so you should assemble those supporting documents before finalising the disclosure. The aim is to make the data, method and claims easy to verify. ↑ section
What are the four assurance claims I need to verify for GRI 2-8?
The page says there are four assurance claims to check, each with a claim, risk and evidence point. Use them to test whether the disclosure is supported, consistent and ready for review. ↑ section
What are the common reporting gaps or mistakes to avoid in a GRI 2-8 disclosure?
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 scope detail, weak method explanation or unsupported numbers before the draft goes out. ↑ section
How do I use the Prep & Assurance workbook for GRI 2-8?
The workbook is a downloadable .xlsx designed to help you prepare the disclosure and get assurance-ready. Use it to organise the required datapoints, evidence and checks before you draft the final text. ↑ section
- GRI 2-8 non-employee workers: what should I collect before drafting the disclosure?
- GRI 2-8 non-employee worker mix: how do I structure the data table?
- GRI 2-8 non-employee work types: how do I describe the categories clearly?
- GRI 2-8 counting method used: what should I document for audit trail purposes?
- GRI 2-8 timing basis used: how do I make the reporting period clear?
- GRI 2-8 worker count swings: what explanation is useful for reviewers?
- GRI 2-8 evidence pack: what documents should I keep together?
- GRI 2-8 assurance claims: how do I test the disclosure before sign-off?
- GRI 2-8 common mistakes: what do people usually miss?
- GRI 2-8 draft output: how do I turn the data into narrative starters?
- GRI 2-8 content index line: what should I put in the index?
- GRI 2-8 printable Library Card PDF: when would I use it?
Get a practical answer for your reporting context. Your first answer is free — create a free account to continue the conversation.
Sources, status and disclaimer
This LRA assistance tool is designed for educational and internal data-collection purposes. It is not an official interpretation of the GRI Standards, IFRS Sustainability Disclosure Standards or EU CSRD/ESRS requirements. When applying these frameworks in professional practice, users should consult and double-check the official standards, guidance and applicable regulatory sources.