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Regulation & frameworks

ESRS S1, own workforce

The fourth chapter of the CSRD Summer Workbook: this week, I am focusing on ESRS S1, the standard covering a company's own workforce, and the practical changes brought about by the revision adopted on July 3rd.

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Sommaire

ESRS S1 covers the company's own workforce: working conditions, health and safety, equal treatment, and social dialogue. It is one of the most comprehensive social standards in the current CSRD , and one of those most revised by the simplification adopted on July 3rd.

What S1 requires today

Today, S1 requires the disclosure of, among other things, the rate of work-related accidents and occupational illnesses, coverage by a health and safetysystem, thegender pay gap , and the percentage of employees covered by a collective bargaining agreement.

What changes with the July 3rd revision

The July 3rd revision significantly reduces the number of mandatory data points: a reduction of over 60% across all ESRS, and over 70% when including voluntary data points. The topics covered by S1 remain in place; it is their granularity that is being reduced.

One rule specific to S1 remains: a total exemption from this standard only exists for companies with fewer than 750 employees. However, since the Omnibus, only companies with more than 1,000 employees and 450 million euros in turnover remain subject to the CSRD starting in 2027.

Any company still affected therefore already exceeds the 750-employee threshold: the total S1 exemption does not apply to any of them. What remains for them are targeted omissions for the first year—data excluding employees, disability inclusion, certain health and safety indicators, work-life balance, social dialogue outside the European Economic Area, social protection coverage, and training.

These data points are not disappearing from the framework: they are deferred, not deleted. After the first year, they become mandatory again.

What remains to be decided

This text remains subject to review by the Council and the European Parliament for a period of two months, renewable once. Implementation is still scheduled for financial years beginning on or after January 1, 2027, with the possibility of early adoption starting in 2026.

What this means in practical terms

If you are preparing your first report on your own workforce, it is best to collect all the currently listed data now, regardless of any exemptions. 

A first-year exemption delays reporting, but it does not eliminate the need to know where to find the data when it is eventually requested.