Under the EU's ESRS S1 (Own Workforce) standard, HR reports ESG on headcount, turnover, gender pay gap, training hours, health and safety, diversity, adequate wages, collective bargaining coverage, family leave, and discrimination incidents. After the Omnibus I simplification (February 2026), only companies with 1,000 or more employees and EUR 450 million or more in net annual turnover must report.
Who must report after Omnibus I
- In scope: companies with 1,000+ employees and EUR 450M+ in net turnover
- Wave 1 (large listed companies with 500+ employees): already reporting on FY 2024 data, unchanged
- Wave 2 (large unlisted companies): delayed by two years, now reporting from FY 2027
- Listed SMEs: obligation removed
- Mandatory datapoints fell by roughly 61%, from around 1,100 to around 430
- Limited assurance applies (in place since FY 2024). With Omnibus I, the planned step-up to reasonable assurance was taken away.
What data HR owns under ESRS S1
- S1-6 Employee characteristics: headcount by gender, country (where 50+ employees), and contract type
- S1-7 Non-employees: contractors, agency workers, and other non-employee workers
- S1-8 Collective bargaining coverage, and S1-11 social protection gaps by country
- S1-9 Diversity: gender across management levels, age, and disability representation
- S1-10 Adequate wages: benchmark used
- S1-13 Training: average hours per employee by gender, and percentage with performance reviews
- S1-14 Health and safety: fatalities, recordable injuries, lost-time injury frequency rate, and days lost
- S1-15 Work-life balance: family-leave entitlement and uptake by gender
- S1-16 Remuneration: unadjusted gender pay gap (gross hourly) and highest-paid-to-median ratio
- S1-17 Incidents: discrimination cases, human rights complaints, and fines
Data typically handled by finance or operations includes carbon emissions, EU Taxonomy alignment, supply chain due diligence, and environmental impact. A typical starting point for companies is setting up their employee records and mapping them against the list.
Disclaimer:
This article informs. It does not advise on the law. Omnibus I recently changed the rules. Thresholds and rules may shift.
TL;DR
- ESRS S1 covers headcount, turnover, pay gap, training, health and safety, diversity, wages, collective bargaining, family leave, and discrimination incidents.
- After Omnibus I, only companies with 1,000+ employees and EUR 450M+ turnover must report. Wave 2 delayed to FY 2027; listed SMEs out.
- A common starting point is an audit of current employee records against the S1 list.