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ESRS S1: Own Workforce · 2026-5010-final

Disclosure Requirement S1-6

Non-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 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

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

Disclosure focus

This disclosure asks an organisation to explain how it identifies and reports on people who work for it but are not its employees, such as contractors, agency workers or other non-employee labour. The focus is on showing which groups are included, how they are counted or described, and what information the organisation has gathered about them in relation to its own workforce and activities.

In practice, the main question is coverage: whether the reporting looks only at a few visible sites or flagship operations, or whether it covers the organisation’s wider operations and relevant parts of the value chain where non-employees are used. The organisation should be clear about the scope, the basis used to define these workers, and any limits in the information available.

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 settled which non-staff groups count for this figure, and which ones stay out of scope? Will you use a headcount or a full-time equivalent basis, and keep that basis the same throughout? Is the number taken from a source you can trace back and explain, rather than from an estimate with no audit trail? Have you fixed the period-end date or averaging point you will use for the count? For the workforce share, have you agreed what total workforce figure it will be compared against?

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner

Non-employee total Capture the total number of people working for the organisation who are not on its payroll, using the same population definition used in workforce reporting. Contractor register, agency labour reports, vendor invoices, site access lists, or a consolidated workforce count that excludes employees. HR / People Operations

Workforce measure basis State whether the figure is a headcount or an FTE-style measure, and keep that basis consistent with the underlying source data and reporting period. Reporting methodology note, HRIS extract, payroll summary, or workforce dashboard showing the chosen counting basis. HR Reporting / Finance

Workforce share Capture the percentage that this group represents within the relevant workforce total, using the same period and denominator used for the workforce count. Calculation workbook, workforce denominator schedule, or reporting pack showing the numerator, denominator and percentage formula. HR Reporting / ESG Reporting

＋ Show S1-6 sub-elements (LRA working checklist)

State the figure using either full-time equivalent or headcount. Show the share as a percentage of the workforce. Give the total number of non-employees.

How to prepare it

1Set the reporting boundary first: decide which non-employee population you are counting for this disclosure, and keep that scope consistent across the figures you will report.

2Choose the counting basis you will use for the workforce measure, then apply it consistently as either a full-time equivalent approach or a simple headcount approach, as required by your source data.

3Gather the underlying records that support the total number, the workforce measure, and the share of workforce reported, so each figure can be traced back to a reliable internal source.

4Prepare the reported outputs in the format needed for each datapoint: the total non-employee figure, the workforce measure expressed on the chosen basis, and the percentage of workforce.

5Record any exclusions, scope changes, or methodological adjustments that affect the numbers, so readers can understand what was left out and why the reported figures changed.

6Check the final disclosure against the official source before publishing, confirming that the scope, counting basis, and reported figures align with the requirement and that nothing has been omitted or misstated.

Request the data

Request the non-employee population count and workforce share

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

How many non-employees did we have in the reporting period, and what share of the wider workforce did they represent?

Use your organisation’s own labels first, then map them to the disclosure. For example, ask for contractors, agency staff, consultants, gig workers, or other external labour categories only if those are the terms your business already uses internally. Keep the request in operational language and check the source data definitions before sign-off.

Weak request

Please provide the ESRS S1:S1-6 non-employee data for the disclosure.

Why it fails: It uses framework language only, gives no boundary, no counting basis, no internal category terms, and does not tell the owner what source or method to use. That makes the return hard to reconcile and hard to evidence.

Better request

Please send the external labour figures for [reporting period] and [boundary]: total count, whether the number is headcount or FTE, the internal category names included, the source system or file, the reference date or averaging method, and the workforce total used to calculate the share. Please add any inclusion or exclusion notes and use your organisation’s own terms.

Formal email template

Subject: Data request – non-employee count and workforce share for [reporting period]

Hello [name/team],

We are preparing the sustainability reporting pack and need the latest figures for our external labour population for [reporting period] and [boundary].

Please send:
- the total number of non-employees;
- the basis used to count them (headcount or FTE);
- the share they represent of the wider workforce;
- the internal category names included in the extract;
- the source system or file used;
- any inclusion/exclusion rules applied;
- the reference date or averaging method used;
- the denominator used for the workforce share.

If helpful, please return the information in the table format below and add any notes needed to explain the figures. Please adapt this to your organisation’s own terms, and check the source definitions before sign-off.

Many thanks,
[preparer name]
[team]
[contact details]

Short Teams / Slack version

Hi [name/team] — could you share the latest external labour figures for [reporting period] and [boundary]?

We need:
- total count
- headcount or FTE basis
- workforce share
- category names used internally
- source system/file
- any inclusion/exclusion rules
- reference date or averaging method
- denominator used for the share

Please use your usual internal terms and add any notes on the method. Thanks, [preparer name]

Industry examples

Manufacturing

Context. A plant uses agency staff, maintenance contractors, and specialist installers alongside direct staff.

Adapted request. Please share the plant’s external labour figures for [reporting period] and [site/boundary]: total number of agency staff, contractors, and other external workers; whether the figure is headcount or FTE; the workforce total used for the share; the source file or system; and any rules used to include or exclude people.

Example response. Agency staff: 42; contractors: 18; specialist installers: 6; total external labour: 66; basis: headcount; workforce total used for share: 1,320; share of workforce: 5.0%; source: site labour tracker; notes: excludes visitors and delivery drivers.

Retail / Logistics

Context. A distribution business uses temporary warehouse workers and outsourced security staff across multiple depots.

Adapted request. Please provide the external worker numbers for [reporting period] across [depots/region]: total count, headcount or FTE basis, internal labels used for temporary warehouse workers and outsourced services, the denominator used for the workforce share, and the source report used to compile the figures.

Example response. Temporary warehouse workers: 95; outsourced security staff: 14; total external workers: 109; basis: FTE; workforce total used for share: 2,180; share of workforce: 5.0%; source: workforce planning dashboard; notes: figures are averaged across the quarter and exclude agency office cover.

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 whether the non-employee figure is built on full-time equivalent or headcount, and make clear that the percentage is calculated against the overall workforce total.

Context note

Explain what the numbers show about reliance on people outside the payroll, both in absolute terms and as a share of the wider workforce.

Fluctuation statement

If the figures move from one period to the next, link the change to shifts in the number of non-employees, the workforce total, or the measurement basis used.

Content index entry

S1-6 Non-employees — [location / page] / [notes]

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Preparation tools & forms

Professional preparation tools for S1-6 — 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.

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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 · S1-6

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 used a clear basis to estimate the non-staff count where direct counting was not possible, and we can show how that estimate was built.The assurer will test whether the estimate is supportable, whether assumptions were reasonable, and whether the method could have materially changed the figure.Working papers showing the estimation method, assumptions, source data, calculation steps, management review notes, and any sensitivity or reasonableness checks.

We explained the calculation choices and reporting approach because they affect how the figure should be read.The assurer will probe whether the chosen approach was applied consistently, whether alternative options were considered, and whether the explanation is enough for a user to understand the number.Draft and final disclosure wording, internal accounting or reporting policy, decision papers on the selected approach, and evidence of review by the preparer and approver.

We stated what share of our own workforce this group represents, and we can trace that percentage back to the underlying counts.The assurer will check whether the percentage is arithmetically correct, whether the denominator is appropriate, and whether the same population was used throughout.Calculation file showing numerator and denominator, source population data, reconciliation to the workforce base, and sign-off on the final percentage.

We disclosed the total number for this group and retained the records used to build that total.The assurer will test completeness, duplication, and whether the total includes the right people and excludes the wrong ones.Population listing, source registers or system extracts, inclusion and exclusion rules, reconciliations, and evidence of management review of the final total.

We chose a headcount-style approach or a full-time-equivalent approach for the total, and we can show why that approach was used.The assurer will examine whether the chosen basis matches the underlying data and whether it was applied consistently across the reporting period.Methodology note, policy or reporting guidance, calculation workbook, source data fields used for the chosen basis, and evidence of consistency checks.

We reported the figure using either a period-end snapshot or an average across the period, and we can show how that timing basis was applied.The assurer will test whether the timing basis is clearly defined, consistently applied, and suitable for the disclosed number.Reporting methodology, period-end or averaging calculations, source extracts for the relevant dates or periods, and review evidence confirming the selected timing basis.

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

Figures are stated without the supporting narrative, or narrative without figures.Scope is inconsistent between the text and the numbers.The reporting boundary is left undefined.Material changes since the previous period are not disclosed.Estimates and measured values are not distinguished.Source records for the figures are not identified.

Common gaps

Mistakes to avoid when collecting the data

Wrong owner

The count gets chased from the wrong team, so the person who actually tracks agency staff, contractors or other non-payroll workers is never asked.

Framework language instead of business terms

The request is sent using ESRS-style labels, which confuses local teams that only recognise their own job titles, supplier categories or site-level headcount reports.

Scope not pinned down

People start collecting figures before agreeing which non-payroll workers are in scope, so different teams include different groups and the final number cannot be reconciled.

Wrong timing basis

The data is pulled for the wrong date or period, so the figure reflects a different point in time from the one being reported.

Mixed counting method

One source uses full-time equivalent logic while another uses simple person counts, and the two are merged without converting them to the same basis.

Source labels stripped out

The original names from payroll, vendor or site reports are lost during consolidation, making it impossible to trace each figure back to the starting record.

Separate groups merged too early

Contractors, agency workers and other non-payroll groups are combined before collection is complete, even though they should stay distinct until the final roll-up.

No evidence trail

The team keeps the number but not the supporting file details, so the date, owner and source version cannot be checked later.

No sign-off record

The draft total is passed on without a clear approval trail, leaving no proof of who reviewed the inputs and accepted the final dataset.

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Where judgement is often needed

Choose one counting basis and keep it consistent

Decide whether to count people as individual workers or convert them into full-time equivalents, explain the basis used, and keep the same approach across periods unless a change is clearly described.

Set a clear cut-off date for the population

Use one reporting date or period-end snapshot for the count, and if you include people who were in scope only for part of the year, say how they were brought into the total.

Define who sits inside the non-employee group

Where local labour practices or contract types differ by country, explain the practical rule used to decide which external workers are included and which are left out.

Handle acquisitions and disposals with a stated boundary rule

If the business changes during the year, disclose whether the count reflects the organisation as held at period end or includes bought-in or sold-off operations for part of the year, and explain any restatement or non-restatement.

Decide how to treat borderline workers

State how you deal with people close to the boundary, such as agency staff, contractors, consultants, or outsourced teams, so readers can see the inclusion rule you applied.

Use estimates where direct records are incomplete

If the number is built from payroll, supplier records, site logs, or sampling rather than a direct headcount, say so and explain the estimation method and any main assumptions.

Explain any privacy-driven grouping

When individual-level detail cannot be shown because of data protection or small numbers, disclose the level of grouping used and make clear that the published figure is an aggregate.

Round in a way that does not distort the total

If you round the count or the share of the workforce, state the rounding approach and check that the rounded figures still reconcile sensibly to the underlying totals.

＋ 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 — Food manufacturing

: we report the number of people who are not on our payroll and show how they sit within our wider workforce. In this example, they are 48 out of 320 workers, which is 15% of the total.

Illustrative only; figures are internally consistent and shown as a share of the wider workforce.

Non-payroll workers within the workforce (people)

Non-payroll workers48

Other workers272

Illustrative (synthetic) example — Logistics and warehousing

: we set out the count of people working for us but not directly employed, alongside the size of the whole workforce. Here, 126 out of 840 workers are in that group, equal to 15% of our workforce.

Illustrative only; figures are internally consistent and shown as a share of the wider workforce.

Non-payroll workers within the workforce (people)

Non-payroll workers126

Other workers714

Company reportsReal published reports

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How companies report S1-6 in practice

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

Indra Sistemas, S.A.

Software and Services · Spain · 2025

Open report →

Indra Sistemas, S.A.'s Sustainability Report 2025 provides detailed employee metrics, including total workforce numbers from 2021 to 2025 (p.92) and breakdowns by contract type for 2024 and 2025, showing 60,907 and 62,396 employees respectively (p.94). The report also includes data on full-time employees by category and gender, indicating near 100% full-time employment in middle management across the years (p.265), as well as workforce distribution by country, with figures for Spain and Europe from 2021 to 2025 (p.259). However, no numeric or narrative evidence specifically addressing other aspects of the disclosure was found in the report.

Snam S.p.A.

Gas Utilities · Italy · 2025

Open report →

Snam S.p.A.'s 2025 Annual Report provides a numeric value for the total number of non-employee workers, reporting 135 and 105 respectively on page 366. The report also mentions workforce details such as total employees and some employment practices, including remuneration aligned with European standards (pp. 362, 365, 367, 481). However, there is no quotable narrative specifically addressing the disclosure beyond these datapoints, leaving some narrative elements unclear or missing.

Iberdrola, S.A.

Electric Utilities / IPP / Energy Traders · Spain · 2025

Open report →

Iberdrola’s 2025 Sustainability Report provides numeric data on total headcount expressed in full-time equivalents, with figures such as 45,400 and 42,208 reported on page 98. The report also includes employee coverage by representatives in Spain at 98% (p.89) and details on training and skills development metrics (p.90). However, no narrative explanations or qualitative descriptions related to these workforce disclosures were found in the report.

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Check your understanding

Scenarios to work through

Your people data team has counted 18 agency workers and 7 contractors who worked on site during the reporting period. The HR file also shows 120 employees on the payroll at year-end.

QHow should you present the non-employee figure, and what extra context do you need to add so the number is understandable?

Reveal model answer →Hide answer ↑

Report the total number of non-employees as 25, because both agency workers and contractors are part of that count. Then add the basis used to express the figure — for example, whether you are presenting it as full-time equivalent or as a headcount — and show what share this group represents compared with the wider workforce, using the same population basis consistently.

Why this matters · Count all non-employee labour in one total, then explain the measurement basis and its share of the workforce so readers can interpret the figure correctly.

A facilities contract covers 12 cleaners, but only 9 of them worked at your sites during the reporting period; the other 3 were assigned elsewhere by the supplier. Your draft table currently includes all 12.

QShould the disclosure include all 12 people, or only the 9 who actually worked for you during the period?

Reveal model answer →Hide answer ↑

Include only the 9 who actually provided labour for your organisation in the reporting period. The point is to capture the non-employee population connected to your own operations, not everyone employed by the supplier under a broader contract.

Why this matters · Use the people who actually supported your operations in the period, not the full supplier roster.

You have 80 employees and 20 non-employees. A draft note says the non-employee group is '20% of staff' because 20 divided by 100 equals 20%.

QIs that percentage basis acceptable, and what should you check before finalising it?

Reveal model answer →Hide answer ↑

The percentage is acceptable only if the denominator is the total workforce you are using for the disclosure and that basis is applied consistently. Here, 20 non-employees out of 100 total workers gives 20%, but you should make clear whether the workforce total is headcount or another measure, and keep the same basis across the disclosure.

Why this matters · State the share using one clear workforce denominator and keep the calculation basis consistent throughout.

Your group has 45 non-employees in total. Of these, 30 are agency workers and 15 are self-employed contractors. The draft narrative mentions only the total and leaves out the measurement basis.

QWhat should you add so the disclosure is complete enough for a reader to understand the number?

Reveal model answer →Hide answer ↑

Keep the total at 45, and add whether that total is shown as headcount or as full-time equivalent. If you use FTE, make sure the method is applied to the whole non-employee population in the same way; if you use headcount, say so plainly. Also show the non-employee share of the workforce on the same basis.

Why this matters · A total alone is not enough; readers also need the counting method and the workforce share to interpret the figure.

Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

ESRS

S1-6

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 · S1-6

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 S1-6 (ESRS S1: Own Workforce), what data do I need to prepare before I start drafting the disclosure?+−

The page says to prepare three datapoints: non-employee total, workforce measure basis, and workforce share. Use the plain-language explainer and the step-by-step preparation section to turn those into a draft disclosure.

How do I work out the workforce measure basis for S1-6 on this page?+−

The page tells you that workforce measure basis is one of the datapoints to prepare, and the step-by-step section is there to help you set the basis consistently before drafting. It does not add extra rules beyond that, so use the page as a practical guide rather than a formal source.

What does the page mean by non-employee total for S1-6, and how should I collect it?+−

Non-employee total is listed as a datapoint to prepare for the disclosure. The page is designed to help you identify the right source data and then use the workbook and evidence pack to support the figure you report.

How should I calculate or present workforce share for S1-6 using this page?+−

Workforce share is one of the datapoints the page tells you to prepare, and the illustrative example shows how the disclosure can be turned into a simple quantitative table. Use the example as a synthetic guide only and keep the numbers internally consistent.

What is the step-by-step process on the S1-6 page for preparing the disclosure?+−

The page includes a step-by-step 'how to prepare' section that walks you through turning the disclosure topic into draft content. It is meant to help you organise the data, evidence and narrative before you finalise the output.

What evidence do I need to keep for S1-6 if I want the disclosure to be assurance-ready?+−

The page includes an evidence pack with five items and also lists six assurance claims to verify, each with a claim, risk and evidence angle. Use those together to build a file that shows how the numbers and narrative were prepared.

How do I use the six assurance claims on the S1-6 page in practice?+−

The six assurance claims are there to help you check what could go wrong, what the risk is, and what evidence would support the disclosure. They are a practical review tool for the ESG manager, HR owner or assurance reviewer.

What are the common reporting gaps or mistakes for S1-6 that I should avoid?+−

The page lists common reporting gaps and mistakes so you can spot weak points before you publish. Use that section as a pre-submission check against your data, scope, evidence and draft wording.

How can I use the Prep & Assurance workbook for S1-6?+−

The Download Centre includes a Prep & Assurance workbook in .xlsx format. It is there to help you organise the disclosure preparation and assurance checks in a working file before you turn the data into a draft.

What should I take from the printable Library Card PDF for S1-6?+−

The Download Centre also includes a printable Library Card in .pdf format. Use it as a quick reference alongside the page content when you are preparing the disclosure or checking the evidence pack.

How do I turn the S1-6 data into a draft disclosure on this page?+−

The page has a draft-output section with visualisation ideas, narrative starters and a content-index line. That section is meant to help you convert the prepared data into a first draft that is easier to review and refine.

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	Report A	Report B	Report C
Datapoint 1	✓ p.213	unclear	✓ p.87
Datapoint 2	✓ p.214	—	✓ p.90

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Non-employees

Key datapoints to prepare

How to prepare it

Request the non-employee population count and workforce share

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 S1-6 in practice

Scenarios to work through

Related framework references

Questions this page answers

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