ESRS S1 Own Workforce: Disclosure requirements, key metrics and what organisations need to know

Last updated: June 1, 2026

ESRS S1 is the European Sustainability Reporting Standard that governs how organisations report on their own workforce, as defined in the EU delegated act (ESRS, 2023). It sits within the Corporate Sustainability Reporting Directive (CSRD) and covers everything from employee characteristics and working conditions to training, health and safety, and pay equity.

If your organisation is in scope for CSRD reporting, ESRS S1 is almost certainly material. Most workforce-related topics pass the double materiality threshold – meaning they affect both your business and your employees – which means they need to be disclosed.

This guide sets out what ESRS S1 requires, how the disclosure requirements are structured, what changed following the 2025 Omnibus reforms, and where workforce skills data fits into the picture.

What is ESRS S1?

ESRS S1 – Own Workforce is one of four social standards within the European Sustainability Reporting Standards framework. It requires organisations to report on how they manage and develop their direct workforce: their policies, their actions, their risks, and their measurable outcomes.

The standard applies when own workforce is determined to be a material topic following a double materiality assessment. In practice, for most large organisations, it will be material. Workforce-related impacts – on working conditions, pay, health, and development – are difficult to argue away as immaterial.

ESRS S1 covers two categories of disclosure: impacts, risks and opportunities management (the qualitative picture – policies, processes, actions), and metrics and targets (the quantitative picture – the data that proves the policies are working).

The 2025 Omnibus reforms: What changed

Before going through the requirements in detail, it is worth understanding where the standard stands in 2026.

In February 2025, the European Commission published the Omnibus Simplification Package, which proposed significant changes to the CSRD framework. EFRAG was tasked with simplifying the ESRS standards in response, and published a draft revised set of standards in November 2025. The reformed standards reduce mandatory datapoints by approximately 61% – from around 1,100 to roughly 430 – and eliminate all voluntary disclosures.

The simplified ESRS are expected to be formally adopted as a delegated act in Q4 2026, with mandatory application from financial years beginning 1 January 2027. Voluntary early adoption for FY2026 is possible.

The Omnibus reforms also narrowed the scope of which organisations are subject to CSRD. The revised thresholds apply primarily to companies with more than 1,000 employees and more than €450 million in turnover. Wave 1 companies – those already reporting under the original NFRD – continue to report under the current standards for FY2024 through FY2026, before transitioning to the simplified ESRS from FY2027.

For organisations currently in scope: the core disclosure requirements of ESRS S1 remain in place. The Omnibus reforms have streamlined what needs to be reported, but the underlying framework – workforce policies, competence data, training metrics, pay equity – is unchanged.

ESRS S1 disclosure requirements

The current standard includes 17 disclosure requirements across two categories: impacts, risks and opportunities management, and metrics and targets. The text below reflects the requirements as set out in the EU delegated act (ESRS, 2023).

Impacts, risks and opportunities management

Disclosure requirement S1-1 – Policies related to own workforce The undertaking shall describe its policies adopted to manage its material impacts on its own workforce, as well as associated material risks and opportunities.

Disclosure requirement S1-2 – Processes for engaging with own workforce and workers' representatives about impacts The undertaking shall disclose its general processes for engaging with people in its own workforce and workers' representatives about actual and potential impacts on its own workforce.

Disclosure requirement S1-3 – Processes to remediate negative impacts and channels for own workforce to raise concerns The undertaking shall describe the processes it has in place to provide for or cooperate in the remediation of negative impacts on people in its own workforce that the undertaking is connected with, as well as channels available to its own workforce to raise concerns and have them addressed.

Disclosure requirement S1-4 – Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions The undertaking shall disclose how it takes action to address material negative and positive impacts, and to manage material risks and pursue material opportunities related to its own workforce, and the effectiveness of those actions.

Metrics and Targets

Disclosure requirement S1-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities The undertaking shall disclose the time-bound and outcome-oriented targets it may have set related to: (a) reducing negative impacts on its own workforce; and/or (b) advancing positive impacts on its own workforce; and/or (c) managing material risks and opportunities related to its own workforce.

Disclosure requirement S1-6 – Characteristics of the undertaking's employees The undertaking shall describe key characteristics of employees in its own workforce.

Disclosure requirement S1-7 – Characteristics of non-employees in the undertaking's own workforce The undertaking shall describe key characteristics of non-employees in its own workforce.

Disclosure requirement S1-8 – Collective bargaining coverage and social dialogue The undertaking shall disclose information on the extent to which the working conditions and terms of employment of its employees are determined or influenced by collective bargaining agreements and on the extent to which its employees are represented in social dialogue in the European Economic Area (EEA) at the establishment and European level.

Disclosure requirement S1-9 – Diversity metrics The undertaking shall disclose the gender distribution at top management and the age distribution amongst its employees.

Disclosure requirement S1-10 – Adequate wages The undertaking shall disclose whether or not its employees are paid an adequate wage, and if they are not all paid an adequate wage, the countries and percentage of employees concerned.

Disclosure requirement S1-11 – Social protection The undertaking shall disclose whether its employees are covered by social protection against loss of income due to major life events, and, if not, the countries where this is not the case.

Disclosure requirement S1-12 – Persons with disabilities The undertaking shall disclose the percentage of its own employees with disabilities.

Disclosure requirement S1-13 – Training and skills development metrics The undertaking shall disclose the extent to which training and skills development is provided to its employees. This includes: (a) the percentage of employees that participated in regular performance and career development reviews, broken down by gender; and (b) the average number of training hours per employee, broken down by gender.

Disclosure requirement S1-14 – Health and safety metrics The undertaking shall disclose information on the extent to which its own workforce is covered by its health and safety management system and the number of incidents associated with work-related injuries, ill health and fatalities of its own workforce. In addition, it shall disclose the number of fatalities as a result of work-related injuries and work-related ill health of other workers working on the undertaking's sites.

Disclosure requirement S1-15 – Work-life balance metrics The undertaking shall disclose the extent to which employees are entitled to and make use of family-related leave.

Disclosure requirement S1-16 – Remuneration metrics (pay gap and total remuneration) The undertaking shall disclose the percentage gap in pay between its female and male employees and the ratio between the remuneration of its highest paid individual and the median remuneration for its employees.

Disclosure requirement S1-17 – Incidents, complaints and severe human rights impacts The undertaking shall disclose the number of work-related incidents and/or complaints and severe human rights impacts within its own workforce, and any related material fines, sanctions or compensation for the reporting period.

Where workforce skills data fits in

Several ESRS S1 requirements – particularly S1-6, S1-9, and S1-13 – depend on structured workforce data that standard HR systems were not designed to produce.

S1-6 asks for a detailed picture of the employee population by contract type, working pattern, and geography. S1-13 asks for training hours, training coverage, and development activity by employee group. S1-9 asks for age and gender distribution at management level. These are not headcount figures that come out of payroll – they require a connected view of who is in the organisation, what they have been trained on, and how their development is being tracked over time.

Most HRIS platforms hold the structural data: who works where, in what role, under what contract. What they typically do not hold is the competence layer – what each person can actually do, what they have been trained on, which certifications are current, and how capability has changed over time. That gap is where ESRS S1 reporting becomes difficult in practice.

Organisations that have built a live skills and competence infrastructure – mapping employee skills, tracking certification status, logging training activity, and measuring development over time – are significantly better positioned to produce the data S1-13 and S1-6 require. Not because they built it for CSRD, but because that infrastructure serves workforce planning, internal mobility, and resource allocation as well. The compliance output is a by-product of having good data.

MuchSkills tracks skills, certifications, training activity, and competence development across the workforce in a structured, auditable way. The platform integrates with HRIS systems including SAP SuccessFactors, Workday, BambooHR, and Personio – providing the competence layer that sits on top of structural HR data and makes S1-13 reporting measurable rather than approximate. The certification tracking feature tracks active, expiring, and expired certifications across the organisation, with automated renewal alerts and a full audit trail.

Frequently Asked Questions

What is ESRS S1?

ESRS S1 – Own Workforce is the European Sustainability Reporting Standard that governs how organisations disclose information about their employees and non-employee workers. It covers working conditions, diversity, training and development, health and safety, and pay equity. It applies to organisations in scope for CSRD reporting where own workforce has been determined to be a material topic.

How many disclosure requirements does ESRS S1 have?

The current ESRS S1 standard includes 17 disclosure requirements across two categories: impacts, risks and opportunities management (S1-1 to S1-4) and metrics and targets (S1-5 to S1-17). The simplified draft published by EFRAG in November 2025 reduces this to 16 requirements, with mandatory application expected from financial year 2027.

What does ESRS S1-13 require?

S1-13 requires organisations to disclose the extent to which training and skills development is provided to employees. Specifically, it asks for the percentage of employees who participated in regular performance and career development reviews (broken down by gender), and the average number of training hours per employee (also broken down by gender). It is one of the more data-intensive requirements and typically requires a structured competence tracking system beyond standard HRIS capability.

What changed under the 2025 Omnibus reforms for ESRS S1?

The Omnibus Simplification Package, published in February 2025, led to a simplified draft of the ESRS standards that reduces mandatory datapoints by approximately 61%. For ESRS S1 specifically, the simplified version limits human rights disclosures to significant incidents, makes non-employee disclosure conditional on materiality, and introduces country-specific wage benchmarks for the adequate wages requirement. The simplified standards are expected to apply from financial year 2027.

Preparing your workforce data for ESRS S1

The organisations that find ESRS S1 reporting most manageable are not necessarily those that prepared specifically for CSRD. They are the ones that already had structured, reliable workforce data – because they needed it for something else.

Skills visibility, certification tracking, development planning, and workforce reporting are operationally valuable regardless of the regulatory context. When ESRS S1 reporting requires training hours per employee or a breakdown of competence development by function, that data either exists in a structured system or it has to be reconstructed manually – an exercise that quickly becomes impractical at scale.

If your organisation is building or improving its workforce data infrastructure ahead of ESRS S1 reporting, explore how MuchSkills supports compliance and regulated industries – or read the related guides below.

Related reading:

• What Is the CSRD? A Comprehensive Guide
• Six Steps to Skills Compliance for ISO Standards
• Certification Tracking

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