Disclosure focus
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.
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key datapoints to prepare
＋ 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.
How to prepare it
1Set 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.
2Build 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.
3Add the work-content detail: for the same controlled non-employee population, record the main kinds of tasks or roles they carry out.
4Choose 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.
5Check 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.
6Before 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.
Request the data
Request the non-employee worker count and supporting notes
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
How many non-employees worked under our control in the reporting period, what kinds of roles and contract arrangements did they have, and what method did we use to compile the figures and explain any major changes?
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.
Weak request
Please provide the GRI 2-8 data on workers who are not employees, including methodology and fluctuations.
Why it fails: It uses framework language that many operational teams will not recognise, and it does not say which internal records, categories, counting basis, or change explanations are needed. That makes it harder to answer quickly and increases the chance of an incomplete return.
Better request
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.
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
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.
Context note
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.
Fluctuation statement
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.
Content index entry
GRI 2-8 Workers who are not employees — [location / page] / [notes]
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Preparation tools & forms
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
The information is presented without a date or as-at point.The scope or boundary of the statement is left undefined.Key terms are used inconsistently across the report.Material changes since the previous period are not disclosed.Assertions are made without supporting detail or a source record.Boilerplate is used that does not actually answer what is asked.
Common gaps
Mistakes to avoid when collecting the data
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.
Where judgement is often needed
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.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Facilities services
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.
Synthetic illustration only. Shows how to explain the count basis, timing basis, worker mix, work performed, and the main movement in the period.
Illustrative (synthetic) example — Food manufacturing
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.
Synthetic illustration only. Shows how to describe the counting method, the point-in-time basis, the main worker groups and tasks, and the change versus the prior period.
How companies report GRI 2-8
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Interconexión Eléctrica S.A. E.S.P.
Electric Utilities / IPP / Energy Traders · Colombia · 2024
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.
REN - Redes Energéticas Nacionais, SGPS, S.A.
Water Utilities · Portugal · 2025
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.
ASE Technology Holding Co., Ltd.
Semiconductors · Taiwan · 2024
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).
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Check your understanding
Scenarios to work through
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.
QWhat should you decide to include in the narrative about these non-staff workers, and how should you describe them?
Reveal model answer →Hide answer ↑Include the total number of people whose day-to-day work is directed by the organisation, then explain the main kinds of worker involved and how each group is engaged. In this case, you would separate the agency cleaners from the security contractors and describe the contractual link for each group in plain terms.
Why this matters · Give both the overall count and a clear picture of the main worker groups and how they are engaged.
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.
QHow should you explain the basis used to compile the figures so a reader understands what the total means?
Reveal model answer →Hide answer ↑State the counting approach and the assumptions behind it, including whether you used simple headcount, a full-time equivalent basis, or another method. You should also make clear how the total was built so readers can tell whether the two groups were measured in the same way.
Why this matters · Always explain the counting method and any assumptions behind the number.
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.
QWhat extra explanation is needed so the reported number is not misleading?
Reveal model answer →Hide answer ↑Add the basis for timing as well as the number itself, for example whether the figure is taken at the period end, averaged over the year, or calculated another way. Because the workforce moved sharply during the year, you should also explain that the year-end figure does not show the seasonal high point.
Why this matters · Tell readers when the number was measured, not just how many there were.
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.
QWhat should you say about the change in numbers across the year and compared with the prior year?
Reveal model answer →Hide answer ↑Describe the material rise and fall in the number of non-staff workers during the year and explain the change from one reporting period to the next. Here, the note should link the higher first-half use and the later reduction to the automation change, so the movement is understandable.
Why this matters · Explain major swings in the workforce and the reasons behind them.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
Organizational details → Guide ✓Nomination and selection of the highest governance body → Guide ✓Chair of the highest governance body → Guide ✓Role of the highest governance body in overseeing the management of impacts → Guide ✓Delegation of responsibility for managing impacts → Guide ✓Role of the highest governance body in sustainability reporting → Guide ✓Show all 29 related disclosures →
FAQ
Questions this page answers
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
More questions this page can help with
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?
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