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ESRS S1: Own Workforce · 2026-5010-final

Disclosure Requirement S1-10

Social Protection

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↓ 4claims to verify↓ 5evidence areas↓ 3report examples↓

Disclosure focus

This disclosure asks an organisation to explain how it covers its own workforce with social protection arrangements. In practice, that means describing whether employees and other workers in the workforce have access to protections such as social security or equivalent benefits, and whether that coverage is provided consistently across the organisation’s operations and locations.

The practical focus is not just on whether a policy exists, but on how far it reaches in reality. Report whether coverage applies to the whole workforce or only certain groups, countries, sites, or contract types, and make clear any gaps, exclusions, or differences in treatment that affect who is protected and where.

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 decided whether you are counting only people covered by a social safety arrangement, or also those covered through another arrangement you provide or fund? Have you fixed which life events you will treat as in scope for this check — for example illness, job loss, work injury, or maternity-related leave? Have you agreed the country list you will use to spot where people are not covered, and whether that list is based on the reporting period or a different cut-off date? Can you trace each yes/no and country entry back to a source you can show later, such as policy records, payroll data, or insurer information? Have you settled the definition you will use for “covered” so the same rule is applied across all locations and employee groups?

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner

Coverage status Record whether the workforce is covered by the relevant protection arrangement, using a simple yes/no answer for the reporting period. Policy schedule, benefits register, insurer or scheme confirmation, and HR/benefits records showing who is enrolled. HR / Benefits

Covered event types List the kinds of events the arrangement protects against, limited to the events actually provided for in the source record for the period. Plan terms, policy wording, insurer certificate, or scheme summary showing the event categories included. HR / Benefits

Uncovered countries Identify the countries where the arrangement does not apply, based on the current coverage map for the reporting period. Territory schedule, insurer exclusions, local plan matrix, or country-by-country benefits register. HR / Benefits

＋ Show S1-10 sub-elements (LRA working checklist)

How to prepare it

1Set the reporting boundary first: decide which workforce locations and arrangements are in scope for this check, so you can answer the coverage question consistently across the group.

2Define the benefit events you will treat as covered for this disclosure, using the same practical categories each time and keeping the list aligned to the events named in the source data point.

3Gather the underlying proof from the relevant HR, payroll, benefits, or local policy records, so you can support both the yes/no coverage answer and any country-level exceptions.

4Prepare the reported output in two parts: the coverage flag, and a clear note on which event types are included, plus the countries where that protection is not available.

5Record any exclusions, gaps, or changes in approach, including where coverage differs by country, so the final disclosure explains the limits of the information rather than implying full uniformity.

6Check the draft against the official source data points before sign-off, confirming that the boundary, event list, and country exceptions match the underlying records and that nothing material has been omitted or added.

Request the data

Request the social protection coverage data from People Operations

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

Which parts of our workforce are covered by social protection arrangements, what types of life events or risks are included, and where do we still have no coverage in place?

Use your organisation’s own terms first, then map them to the disclosure. For example, if you talk about benefits, welfare cover, statutory schemes, or local insurance arrangements internally, use those labels in the request and only translate them afterwards for reporting. This is a possible LRA training template; adapt it to your organisation and check the official source before sign-off.

Weak request

Can you fill in the ESRS S1 social protection disclosure for us, including coverage, events covered, and countries without coverage?

Why it fails: It uses framework language that many operational teams will not recognise, and it does not say which people, countries, systems, or internal labels to use. That makes it harder to pull the right records and increases the risk of inconsistent answers.

Better request

Please send the workforce protection summary for [reporting period] for [population boundary]. For each country or worker group, tell us whether cover exists, what it includes in your own team’s terms, and where there is no cover. If the data comes from more than one system, include the source for each line and flag any gaps or assumptions.

Formal email template

Subject: Data request for social protection coverage review

Hi [Name],

I’m preparing our year-end sustainability reporting pack and need your help with the workforce protection data for [reporting period].

Please share the information for [population boundary] across [countries/sites], using the terms your team normally uses internally. I’m looking for:
- whether each location or worker group has cover in place;
- which types of events or risks are included, such as sickness, unemployment, injury, or maternity-related support;
- where there is no cover in place, by country.

If the information sits across more than one system, please include the source for each line and note any assumptions or gaps.

A possible format is attached below. Please adapt this to your organisation’s own language, and please check the official source before sign-off.

Many thanks,
[Your name]

Short Teams / Slack version

Hi [Name] — could you send over the workforce protection data for [reporting period] for [population boundary]? Please use your usual internal terms, and include: whether cover exists, what events/risks are included, and which countries have no cover. If it’s split across systems, just note the source for each line. Thanks — [Your name]

Industry examples

Manufacturing

Context. A group with plants in several countries and a mix of direct employees and local site workers.

Adapted request. Please share the site-level workforce protection summary for [reporting period] across [plant locations]. Use the labels your benefits or payroll teams already use. For each site, confirm whether cover is in place, what events it includes, and which countries have no cover for any worker group.

Example response. Country / site: Poland plant | Worker group: direct employees | Coverage in place: Y | Included event or risk: sickness, injury, maternity support | Coverage basis: company scheme plus statutory arrangements | No-cover reason / gap note: none | Source reference: benefits register v3

Professional services

Context. A firm with office-based staff in multiple jurisdictions and locally managed benefits packages.

Adapted request. Please send the benefits coverage summary for [reporting period] across [countries]. Use your normal benefits names, and show whether each office population has cover, what it includes, and where any country has no arrangement in place.

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 defined the protection package, which employee groups were included in the count, and how you identified the listed protection types and any countries without that cover.

Context note

Explain what the figures say about the organisation’s employee protection arrangements, including whether cover is available at all, which risks are included, and where gaps remain by country.

Fluctuation statement

If the position changed from the prior period, point to changes in the number of countries without cover, shifts in the protection types offered, or a move from partial to broader coverage.

Content index entry

S1-10 Social Protection — [location / page] / [notes]

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Preparation tools & forms

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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 · S1-10

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.

Explore the ESRS / CSRD course →

Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check

We built the coverage figure from our own employee records and payroll files, then checked which people were in scope at the reporting date and which locations were included. For the countries we operate in, we mapped where social protection arrangements were in place and where they were not, using a documented country-by-country review.An assurer will probe whether the scope was set consistently, whether all relevant countries and worker groups were included, and whether the coverage figure could be overstated or understated because of missing entities, duplicate records, or inconsistent cut-off dates.Population extracts used for the calculation; payroll and HR source files; the scope memo showing which entities, countries and worker categories were included or excluded; the country-by-country mapping of social protection arrangements; version control or sign-off showing the final cut-off date and any adjustments.

We separated the disclosed figure from any estimates by tracing it back to underlying records and by documenting where local data had to be normalised before consolidation. Where a country used a different scheme or classification, we recorded the basis for treating it as covered or not covered so the same rule was applied across the group.An assurer will test whether the data was comparable across countries, whether local classifications were translated consistently, and whether management judgement was applied in a way that could bias the result.Data transformation notes; mapping tables between local categories and group reporting categories; reconciliation between local submissions and the consolidated figure; documented judgement papers for any ambiguous cases; review evidence showing the same rule was applied across locations.

Before publication, we checked the figure against headcount totals, reviewed exceptions, and investigated any unusual movements from the prior period. We also had the underlying working papers reviewed by a second person so that the final disclosure matched the supporting files.An assurer will look for evidence that the final number was independently checked, that anomalies were investigated, and that the published disclosure agrees to the source workings without unexplained differences.Reconciliation to headcount and other control totals; exception logs and follow-up notes; prior-period comparison analysis; reviewer sign-off or evidence of independent review; final working paper pack and the published disclosure showing consistency with the support.

For the part of the disclosure dealing with gaps in protection, we used a documented list of major life events and checked each country against that list using local policy documents and benefit summaries. Where a gap existed, we kept the supporting note showing why the event was treated as not covered.An assurer will probe whether the list of events was complete and applied consistently, whether local documents actually support the coverage conclusion, and whether any gaps were omitted or described too narrowly.The approved list of major life events used for the assessment; local policy documents, employee handbooks or benefit summaries; the country-by-country assessment matrix; notes explaining any gaps identified; evidence of management review of the final wording.

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 request goes to HR or payroll in framework language, so the team that actually tracks social cover in each country never confirms the figures.

Unclear population boundary

The data pull mixes employees, contractors, and other groups because nobody first states which workforce population is in scope for the count.

No country split

Records are gathered at group level only, so countries with no cover are not separated from countries where cover exists.

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Where judgement is often needed

Define the reporting perimeter after a deal closes

If a business is bought or sold during the period, state the cut-off you used for including people and explain whether the answer reflects the group at period end or a time-weighted view.

Choose one country rule where local schemes differ

Where national systems describe protected events differently, map them to one internal list for sickness, job loss, injury and maternity, then explain the mapping so readers can see how the comparison was made.

Decide how to treat workers just outside the core population

Set out whether you included or excluded people such as agency staff, contractors or part-year joiners, and explain the practical rule used to place them inside or outside the count.

＋ Show 6 more

Examples

Illustrative examples

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

Illustrative (synthetic) example — Food manufacturing

We say our workforce is covered by our employee protection arrangements, and those arrangements include support for illness, job loss, workplace harm and parental leave. In the countries where we operate, there are 2 where some staff are not covered by one or more of those protections. - Coverage: yes - Protections included: sickness, unemployment, injury and maternity - Countries with gaps: 2

This example shows a simple narrative way to state whether the company’s own arrangements apply, which kinds of life events they address, and how many countries still have gaps.

Illustrative (synthetic) example — Retail logistics

Our group does not yet provide full protection across every location, so the answer on coverage is no. The package we do have covers illness, unemployment, injury and maternity, and there are 5 countries where at least one of those protections is missing. - Coverage: no - Protections included: sickness, unemployment, injury and maternity - Countries with gaps: 5

This example shows how to report a partial position: state the overall yes/no outcome, list the life events addressed by the arrangements, and give the number of countries where coverage is incomplete.

Company reportsReal published reports

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How companies report S1-10 in practice

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

Hera S.p.A.

Water Utilities · Italy · 2024

Open report →

Hera S.p.A.'s 2024 Consolidated Financial Statements include references to social protection, diversity, and training, with specific data points noted on pages 264 and 245, such as social protection (p.264), diversity metrics (p.264), and economic activities related to climate change mitigation and adaptation (p.245). The report also mentions employment relationships and remuneration alongside diversity metrics on page 264, and employee characteristics on page 263. However, no direct quotable narrative evidence was found in the report to provide detailed disclosure on these topics.

Aena S.M.E., S.A.

Air Transportation — Airport Services · Spain · 2025

Open report →

Aena S.M.E., S.A.'s 2025 sustainability report provides detailed information on social protection coverage for salaried employees, stating that the group complements 100% of state sickness benefits and that 95.95% of employees were covered by social protection in 2025, with 99.85% covered by collective bargaining agreements (p.220, p.218). The report also references diversity metrics and adequate wages related to social protection (p.70). However, no specific data on other aspects of social protection or related narrative items were found in the report.

GEA Group Aktiengesellschaft

Electrical Equipment and Machinery · Germany · 2025

Open report →

GEA Group Aktiengesellschaft’s 2025 Annual Report provides some data related to workforce metrics, including collective bargaining coverage and diversity (p.233), as well as injury frequency and severity rates under a strict zero-tolerance policy (p.233). The report also references incidents of discrimination and non-respect of UN Guiding Principles (p.228), and notes that 100% of employees are covered by a health and safety management system (p.178). However, no clear or quotable narrative evidence was found in the report to elaborate on these points or provide further context.

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Check your understanding

Scenarios to work through

A group of 120 employees is split across three countries. In two countries, the company pays into public or private schemes that cover illness, job loss, workplace injury and parental leave; in the third country, only 18 of 40 workers have any such cover through the employer.

QHow should the preparer decide whether to mark the coverage field as yes or no, and what should be captured about the third country?

Reveal model answer →

A preparer is drafting the note for a multinational group and finds that one subsidiary offers sickness and injury cover, while another only provides injury cover and no support for unemployment or maternity-related absence. The team is unsure whether to list every event separately or use a broad label.

QWhat level of detail should be given for the kinds of events covered?

Reveal model answer →

A company has operations in five countries. Four countries have employee social insurance arrangements, but in one country the local labour market is informal and the employer has no scheme in place for its 15 staff there. The draft note currently says only that the group has ‘broad coverage globally’.

QWhat should the preparer do about the country with no cover?

Reveal model answer →

A preparer has data showing that 78 of 90 workers in Country A are covered, 50 of 50 in Country B are covered, and 0 of 12 in Country C are covered. The team wants to report only the two countries with cover because the third one is sensitive.

QShould the country with no cover be left out, or included in the disclosure?

Reveal model answer →

Framework references