ESRS S1
EU topical standard on own workforce, under the CSRD.
DR (EU) 2026/1563, Annex I.EU reporting · the own-workforce standard
ESRS S1: the own-workforce standard, disclosure by disclosure
ESRS S1 Own Workforce is the EU standard for reporting on employees and other people in an undertaking’s own workforce, with sixteen disclosure requirements in its revised form.
It applies to financial years beginning on or after 1 January 2027, and only where own workforce relates to material impacts, risks or opportunities.
It is not UK SRS S1, which is the UK’s general requirements standard; the two share a short name only.
A name clash
ESRS S1 and UK SRS S1 are different standards
Searches for “S1” mix two unrelated documents.
ESRS S1 is the EU’s own-workforce standard; UK SRS S1 is the UK’s general requirements standard for sustainability-related financial disclosures.
Read why the difference matters
UK SRS S1 sets the architecture for all UK SRS reporting on single (financial) materiality; it has no workforce metrics of its own.
ESRS S1 is one of ten topical standards that a double materiality assessment may or may not bring into scope.
A UK group may meet both, through a UK listing and an EU subsidiary, and they answer different questions.
Own workforce
Who ESRS S1 covers, and who it leaves to S2
¶7 defines own workforce as employees plus “non-employees”: self-employed people contracted to supply labour and people provided by employment-activities undertakings.
Workers in the upstream or downstream value chain are covered by ESRS S2, not S1.
Read the definitions
¶7 adds that information about non-employees “shall not affect their status under applicable labour law.”
¶8 says the definitions of self-employed people and of people from employment-activities undertakings are based on national legislation, and gives examples.
Own workforceExplore
Module 03 / 04
Agency workers
People provided by undertakings primarily engaged in employment activities, NACE 78 (¶7(ii)).
Module 04 / 04
Value chain
Workers upstream and downstream are covered by ESRS S2, not S1 (¶7).
Is S1 compulsory?
ESRS S1 follows the materiality assessment, with two exceptions
S1 is reported where own workforce relates to material impacts, risks or opportunities, and only the material sub-topics are reported (ESRS 1 ¶30).
¶1 makes two exceptions: S1-5 applies whenever own workforce is reported, and S1-6 whenever non-employees are connected to material matters.
Read ¶1 as printed
¶1(a) reads, as printed, that S1-5 applies “if it concludes that its own workforce is to be reported following the materiality assessment material”; the sense is that S1-5 follows a conclusion that own workforce is material.
¶1 ends: “The filter of materiality of information defined in ESRS 1 General Requirements, paragraph 23, remains applicable also to these two DRs.”
The assessment itself is set out on the double materiality assessment, and the stakeholders it draws on on stakeholder engagement.
When S1 appliesExplore
Module 01 / 04
The rule
Reported where own workforce relates to material impacts, risks or opportunities (¶2).
Module 04 / 04
The filter
Information materiality (ESRS 1 ¶23) still applies to S1-5 and S1-6.
Sub-topics
The six ESRS S1 sub-topics
¶6 lists six sub-topics: working conditions; social dialogue and collective bargaining; health and safety; training and skills development; diversity and equal treatment; and other labour-related human rights.
Each can be material or not on its own, which is why ESRS 1 ¶30 matters so much in S1.
Read ¶6 in full
“(a) working conditions (including adequate wages, work-life balance, working time, secure employment, social protection); (b) social dialogue, freedom of association, works councils, participation rights of workers and collective bargaining; (c) health and safety; (d) training and skills development; (e) diversity and equal treatment (including gender equality, equal pay for work of equal value, employment and inclusion of people with disabilities, non-discrimination, anti-harassment); and (f) other labour-related human rights (including child labour, forced labour, privacy and adequate housing).”
Six sub-topicsExplore
Module 01 / 04
Working conditions
Adequate wages, work-life balance, working time, secure employment, social protection.
Module 02 / 04
Social dialogue
Freedom of association, works councils, participation rights, collective bargaining.
Module 04 / 04
Equal treatment
And other labour-related human rights: child labour, forced labour, privacy, adequate housing.
The disclosure requirements
All sixteen ESRS S1 disclosures, one by one
Titles are as published; paragraph numbers are those of the revised S1.
S1-1 to S1-4 run through the general disclosure requirements in ESRS 2; S1-5 to S1-16 are metrics.
| DR | Title | What it asks |
|---|---|---|
| S1-1 | Policies related to own workforce | ¶¶10–11, through GDR-P; whether policies address trafficking, forced or compulsory labour and child labour. |
| S1-2 | Engagement with own workforce and workers’ representatives, existence of channels for own workforce to raise concerns or needs and approaches to remedy | ¶¶12–15: engagement, grievance mechanism, remedy. |
| S1-3 | Actions and resources related to own workforce | ¶¶16–17, through GDR-A. |
| S1-4 | Targets related to own workforce | ¶18, through GDR-T. |
| S1-5 | Characteristics of the undertaking’s employees | ¶20 headcount by gender, top ten countries with 50+ employees, permanent/temporary/non-guaranteed hours, turnover. |
| S1-6 | Characteristics of non-employees in the undertaking’s own workforce | ¶22 total number of non-employees. |
| S1-7 | Collective bargaining coverage and social dialogue | ¶¶24–25 coverage overall, per EEA country, by region outside the EEA; works councils. |
| S1-8 | Gender diversity in top management | ¶27 headcount and percentage by gender. |
| S1-9 | Adequate wages | ¶29 whether employees are paid an adequate wage, and the benchmark. |
| S1-10 | Social protection | ¶31 countries without cover for sickness, unemployment, employment injury and disability, or maternity leave. |
| S1-11 | Persons with disabilities | ¶33 percentage among employees, subject to legal restrictions. |
| S1-12 | Training and skills development metrics | ¶35 review participation and average training hours. |
| S1-13 | Health and safety metrics | ¶37 coverage, fatalities, accidents, ill health, days lost. |
| S1-14 | Work-life balance metrics | ¶39 percentage entitled to family-related leave. |
| S1-15 | Remuneration metrics | ¶41 gender pay gap and total remuneration ratio. |
| S1-16 | Incidents of discrimination and other human rights incidents | ¶43 for material sub-topics: substantiated incidents and related fines. |
Pay and wages
The ESRS S1 pay metrics, as defined
¶41(a) defines the gender pay gap as “the difference in average pay levels between female and male employees, expressed as a percentage of the average pay level of male employees.”
¶41(b) asks for “the annual total remuneration ratio of the highest-paid individual to the median annual total remuneration for all employees (excluding the highest-paid individual).”
Read the wage and diversity metrics
¶29 asks “whether or not its employees are paid an adequate wage and the benchmark or benchmarks it uses”, with the countries each benchmark covers, and, if not, “the countries and the percentage of employees concerned.”
¶27 asks for “the gender distribution in number (headcount) and percentage at top management level.”
¶33 asks for the percentage of persons with disabilities among employees, “subject to legal restrictions on the collection of data.”
Pay metricsExplore
Module 01 / 04
Gender pay gap
Difference in average pay, female and male, as a percentage of male average pay (¶41(a)).
Module 03 / 04
Adequate wages
Whether paid, the benchmark used and, if not, where and for whom (¶29).
Headcount, bargaining, safety
Employees, collective bargaining and health and safety
S1-5 is the base for the other metrics: total headcount by gender, the ten largest countries with 50 or more employees, contract types and turnover.
S1-7 asks for collective bargaining coverage, with country detail inside the EEA and regional detail outside it.
Read the health and safety paragraph
¶37 asks for the percentage covered by the occupational safety and health management system, fatalities from work-related accidents and ill health, the number and rate of recordable accidents, cases of recordable work-related ill health and days lost.
If S1-6 is material, the accident and fatality figures include non-employees, broken down where applicable.
¶20(e) asks for an explanation where headcount is inconsistent with the most representative number in the financial statements.
- 1
S1-5 employees
Headcount by gender; top ten countries with 50 or more; permanent, temporary, non-guaranteed hours; turnover (¶20).
- 2
S1-7 bargaining
Coverage overall, per EEA country of significant employment, by region elsewhere; EEA works councils (¶¶24–25).
- 3
S1-13 safety
OSH coverage, fatalities, accidents, ill health, days lost (¶37).
- 4
S1-12 and S1-14
Reviews and training hours; family-related leave entitlement (¶¶35, 39).
Phase-ins
Which ESRS S1 disclosures can wait a year
ESRS 1 ¶127(f) lets an undertaking first reporting from FY2027 omit a set of S1 datapoints for its first year of reporting.
Wave-one undertakings have the same relief for financial years before 2027 (¶¶125(f), 126(f)).
Read the phase-in wording
The relief covers “ESRS S1-6, S1-7 for own employees in non-EEA countries, S1-10, S1-11, S1-12, S1-13 datapoints in paragraph 37(d), (e) and non-employees datapoints, and S1-14”.
Everything else in S1 that is material is reported from the first year.
¶124 also relieves first-year comparatives in specified cases.
Phased-in S1 itemsExplore
Module 04 / 04
S1-13 parts
Ill-health cases, days lost and non-employee datapoints (¶37(d), (e)).
How much is in S1
ESRS S1 datapoints, on EFRAG’s draft count
EFRAG’s draft list of 28 August 2026 counts 49 “shall” datapoints in S1, on its own definition.
It is a draft, non-authoritative count, and every datapoint is subject to materiality.
Read what the count does and does not mean
The same draft gives 127 datapoints in the 2023 S1 on that basis, and 57 in EFRAG’s December 2025 advice.
EFRAG says the list “must not be used as a checklist”; comments on it close on 23 October 2026, as at 11 October 2026.
S1 in numbersExplore
Module 02 / 04
49 “shall” datapoints
EFRAG Secretariat’s draft count for S1, excluding ESRS 2 policy, action, target and metric datapoints.
Module 03 / 04
9 tied to EU law
Of those, the draft counts 9 related to other EU legislation.
Module 04 / 04
All subject to materiality
No datapoint is reported irrespective of the materiality assessment (¶68).
Engagement
Workers’ representatives and engagement under ESRS S1
S1-2 asks how the undertaking engages with its own workforce or workers’ representatives and how their perspectives inform its decisions.
ESRS 1 AR 25 adds that management shall inform workers’ representatives and discuss with them the relevant information and the means of obtaining and verifying it.
Read how this feeds the assessment
ESRS 1 ¶42 makes engagement with affected stakeholders in ongoing due diligence a key input to impact materiality, and AR 24 of ESRS 1 says no separate engagement process is needed for the assessment.
Own workforce is one of the categories of affected stakeholders in ESRS 1 AR 23.
Engagement dutiesExplore
Module 01 / 04
S1-2
How the undertaking engages with its own workforce and workers’ representatives (¶13).
Module 02 / 04
Grievance
Whether a grievance mechanism is in place, and how channels are assessed (¶14).
Module 03 / 04
ESRS 1 AR 25
Inform workers’ representatives and discuss the information and how it is obtained and verified.
Module 04 / 04
ESRS 1 ¶42
Due-diligence engagement with affected stakeholders is a key input to impact materiality.
When
ESRS S1 dates, from adoption to first reports
The revised S1 sits in a published regulation not yet in force on 11 October 2026.
- 31 July 202301
- 3 July 202602
- 21 September 202603
- 10 November 202604
- FY202705
Illustrative example
An ESRS S1 first year, in outline
An invented EU distribution subsidiary of a UK group, in CSRD scope from FY2027, with employees and agency drivers, which found health and safety and working conditions material.
Illustrative only; not a finding about any company.
- 01 / Materiality01
Conclude on sub-topics
Health and safety and working conditions material; the conclusions recorded for ESRS 2 IRO-1 and IRO-2. - 02 / S1-5, S1-602
Characteristics
S1-5 follows because own workforce is reported; S1-6 because agency drivers are connected to material matters, though first-year relief is available. - 03 / S1-1303
Safety metrics
Coverage, fatalities and accidents in year one; ¶37(d), (e) may wait a year. - 04 / S1-1 to S1-404
Policies, actions, targets
Through ESRS 2 GDR-P, GDR-A and GDR-T for the material sub-topics. - 05 / Engagement05
Representatives
Inform and discuss with workers’ representatives (ESRS 1 AR 25); describe engagement under S1-2.
Datapoints in scope
EFRAG’s draft list counts 49 “shall” datapoints in S1, all subject to materiality; see ESRS datapoints.
For the UK parent
Workforce matters enter UK SRS only as risks or opportunities to the company, on single (financial) materiality.
What goes wrong
Six ESRS S1 mistakes
Confusing the two S1s
ESRS S1 is own workforce; UK SRS S1 is general requirements.
Counting value-chain workers
They belong to ESRS S2 (¶7).
Skipping S1-5
It applies whenever own workforce is reported (¶1(a)).
Reporting every sub-topic
Only material sub-topics are reported (ESRS 1 ¶30).
A different pay-gap formula
¶41(a) uses average pay, as a percentage of male average pay.
Missing the phase-in limits
Only the listed datapoints wait, and only for the first year.
Related reading
The climate counterpart is ESRS E1; who reports and when is on CSRD thresholds and the CSRD timeline; and the assurer’s role is on assurance under the CSRD.
The twelve standards together are on the ESRS guide, and scope after Omnibus I on the CSRD after Omnibus I.
Frequently asked
Questions people ask
What is ESRS S1?
ESRS S1 Own Workforce is the EU’s topical standard for disclosures about an undertaking’s own workforce under the CSRD.
In its revised form, published as Delegated Regulation (EU) 2026/1563, it has sixteen disclosure requirements, S1-1 to S1-16.
Is ESRS S1 the same as UK SRS S1?
No. ESRS S1 is the EU standard on own workforce.
UK SRS S1 is the UK’s general requirements standard for sustainability-related financial disclosures, based on IFRS S1.
They share a short name and nothing else.
Is ESRS S1 mandatory?
Only where own workforce relates to material impacts, risks or opportunities (¶2).
If it is reported, S1-5 on employee characteristics applies, and S1-6 applies where non-employees are connected to material matters (¶1).
Who counts as own workforce under ESRS S1?
Employees, and non-employees: self-employed people contracted to supply labour and people provided by undertakings primarily engaged in employment activities (NACE 78) (¶7).
Workers in the value chain are covered by ESRS S2, not S1.
What are the ESRS S1 sub-topics?
Working conditions; social dialogue and collective bargaining; health and safety; training and skills development; diversity and equal treatment; and other labour-related human rights, including child labour, forced labour, privacy and adequate housing (¶6).
How is the gender pay gap defined in ESRS S1?
¶41(a): the difference in average pay levels between female and male employees, expressed as a percentage of the average pay level of male employees.
What remuneration ratio does ESRS S1 ask for?
¶41(b): the annual total remuneration ratio of the highest-paid individual to the median annual total remuneration for all employees, excluding the highest-paid individual.
What does ESRS S1 ask about adequate wages?
¶29: whether employees are paid an adequate wage and the benchmark or benchmarks used, with the countries each benchmark covers; if not, the countries and the percentage of employees concerned.
What health and safety metrics are in ESRS S1?
S1-13 (¶37): coverage of the occupational safety and health management system, fatalities, the number and rate of recordable work-related accidents, cases of recordable work-related ill health and days lost.
Some of these are phased in.
Which ESRS S1 disclosures are phased in?
ESRS 1 ¶127 lets a first-time reporter from FY2027 omit S1-6, S1-7 for non-EEA employees, S1-10, S1-11, S1-12, the S1-13 datapoints in ¶37(d) and (e) and non-employee datapoints, and S1-14 for its first year.
Wave-one undertakings have the same relief for financial years before 2027.
Does ESRS S1 require engagement with workers’ representatives?
S1-2 asks how the undertaking engages with its own workforce and workers’ representatives.
Separately, ESRS 1 AR 25 says management shall inform workers’ representatives and discuss with them the relevant information and the means of obtaining and verifying sustainability information.
How many datapoints does ESRS S1 have?
EFRAG’s draft list of 28 August 2026 counts 49 “shall” datapoints in S1, excluding ESRS 2’s policy, action, target and metric datapoints.
Every one is subject to materiality; it is a draft, non-authoritative count.
When does the revised ESRS S1 apply?
To financial years beginning on or after 1 January 2027.
For financial years starting in 2026 an undertaking may use the 2023 ESRS as amended, those with eight reliefs, or the revised ESRS in full, and must say which.
Does a UK company report under ESRS S1?
Only through an EU entity or listing in CSRD scope.
There is no UK equivalent own-workforce standard; UK SRS covers sustainability-related risks and opportunities to the company, on single (financial) materiality.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
Checked against 11 sources fromEUR-LexCouncil of the EUEuropean CommissionEFRAGDepartment for Business and Trade
- EUR-LexCommission Delegated Regulation (EU) 2026/1563 — Annex I, ESRS S1 ¶¶1–43; ESRS 1 ¶¶42, 125–127, AR 23–AR 25
The published standard; applies to financial years beginning on or after 1 January 2027.
- EUR-LexCommission Delegated Regulation (EU) 2023/2772 — the first set of ESRS
The 2023 S1, still one of the FY2026 options.
- Council of the EUC(2026) 5010 final, Annex I — the revised ESRS as transmitted
The same text before publication.
- EUR-LexDirective 2013/34/EU, consolidated 18 March 2026 — Art 19a and Art 29a
Who reports from FY2027: above €450 million net turnover and 1,000 employees.
- EUR-LexDirective (EU) 2026/470 (Omnibus I)
The scope change in force since 18 March 2026.
- European CommissionCommission adopts revised sustainability reporting standards, 3 July 2026
The adoption announcement.
- EFRAGESRS Knowledge Hub — revised ESRS 2 (IRO-1, IRO-2, SBM-3)
Where the materiality conclusion on own workforce is disclosed.
- EFRAG2026 Draft List of Datapoints — Explanatory Note, Figures 1 and 2
EFRAG’s draft count: 49 “shall” datapoints in S1, all subject to materiality.
- EFRAGESRS simplification project page
How the revised standards were developed.
- EFRAGIG 1: Materiality Assessment Implementation Guidance
Non-authoritative; written for the 2023 ESRS.
- Department for Business and TradeUK SRS S1 General Requirements
A different standard with the same short name: general requirements, not own workforce.
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