CSRD for HR Managers: Workforce and Diversity Reporting

Introduction

Under the Corporate Sustainability Reporting Directive (CSRD), HR managers now play a crucial role in sustainability reporting. The workforce is not just a cost centre — it’s a core ESG topic under the European Sustainability Reporting Standards (ESRS), specifically ESRS S1: Own Workforce.

This means HR data on employment, diversity, working conditions, and training now feeds directly into the company’s sustainability disclosures.

This guide explains how HR teams can collect, manage, and report people data for CSRD or VSME (Voluntary SME Standard) compliance — using a practical, proportionate approach that fits small and growing business (SME) resources.

For broader data coordination tips, see CSRD for Operations Managers: Data Collection Best Practices.

1. Why Workforce Reporting Matters Under CSRD

The CSRD links social sustainability to business performance. Workforce-related disclosures show how a company manages its most valuable resource — its people — across four key areas:

1. Employment – headcount, employment type, turnover, and benefits.
2. Working conditions – pay, working hours, health, and safety.
3. Equal opportunity – gender balance, diversity, and inclusion.
4. Training and development – skills, learning hours, and career growth.

For HR managers, this is an opportunity to demonstrate fair employment practices, workforce stability, and employee wellbeing — all factors that influence talent retention and reputation.

2. What HR Data You Need to Collect

Below is a summary of typical workforce metrics aligned with ESRS S1 and VSME social disclosures:

Not all metrics will apply equally to small and growing businesses (SMEs). The VSME Standard allows proportional reporting, focusing on what’s relevant and feasible.

3. How to Collect and Prepare Workforce Data

Step 1: Use existing systems

Leverage data from payroll, HRIS, or time-tracking tools rather than starting from scratch.

Step 2: Standardise definitions

Agree on consistent units — e.g. “headcount = average annual FTEs” or “training = structured hours per person per year.”

Step 3: Check coverage

Ensure data covers all employees, including part-time, temporary, and remote workers. For guidance on this, see Do Remote Workers Count Toward CSRD Workforce Metrics?.

Step 4: Document your sources

Keep a record of where data came from (HRIS, spreadsheets, surveys). This is critical for audit traceability.

Step 5: Review and approve

HR should review data internally before passing it to the sustainability or finance team for consolidation.

4. Reporting Workforce Data Under CSRD

Under ESRS S1, HR-related disclosures appear under several required sections:

For small and growing businesses (SMEs) using VSME Module B2 (Own Workforce), simplified templates can be used — e.g. “Total FTEs: 58 (45% women), Average training hours: 12 per employee.”

Example small business disclosure:

“The company employs 62 people (48% women, 3 apprentices). Average training hours per employee were 10 in 2025, with 85% of staff completing at least one development activity. The company recorded no workplace accidents during the year.”

5. Ensuring Data Quality and Consistency

To make HR data audit-ready:

• Reconcile headcount with financial payroll records.
• Apply year-end cut-off (data should match reporting year).
• Review gender and age data for completeness (no blanks).
• Document assumptions for estimated data, e.g. training participation.
• Protect personal data — comply with GDPR when handling employee information.

From FY2025, HR data may be sampled during limited assurance reviews. Keeping clear documentation will help avoid rework or delays.

For more on preparing for review, see How to Prepare for Your First CSRD Audit or Review.

6. Linking Workforce Metrics to Business Strategy

CSRD encourages linking workforce disclosures to strategic goals and financial performance. HR can connect data to:

• Retention costs and recruitment efficiency.
• Training investments and productivity improvements.
• Diversity and innovation outcomes.
• Health and wellbeing programmes and reduced absenteeism.

These connections demonstrate that HR metrics are not just compliance indicators — they reflect long-term business resilience.

Frequently Asked Questions

Do we need to include contractors or agency staff?

Include them if they are part of your regular workforce or under your operational control, following ESRS S1 guidance.

How detailed should diversity data be?

At minimum, report gender and age breakdowns. Additional dimensions (e.g. disability, nationality) are optional for small and growing businesses (SMEs).

What if we can’t track all training hours?

Estimate averages based on sample departments or budgets and note your method transparently.

How do we handle personal data under GDPR?

Aggregate data (e.g. by age group or gender) and anonymise where individual identification is possible.

Key Terms

• ESRS S1 – Own Workforce – Standard covering employment, diversity, and training disclosures.
• VSME B2 – Voluntary SME disclosure module for workforce topics.
• Limited assurance – Moderate-level audit verifying data plausibility.
• Materiality – Significance of workforce impacts on business or stakeholders.
• HRIS (Human Resource Information System) – Digital system managing HR data.

Conclusion

HR managers are key to delivering credible, human-centred CSRD reports. By standardising data collection, safeguarding personal data, and linking workforce metrics to strategy, HR can turn compliance into a story of engagement and growth.

Start small, document your process, and build data quality over time — that’s the CSRD approach to continuous improvement.

To plan data updates and reporting milestones, consult our Annual CSRD Reporting Calendar.

To help you organise all the HR data you need to collect, use our checklist generator to create a customised checklist for workforce reporting:

This tool will help you identify all the metrics you need to track for headcount, diversity, training, and other workforce disclosures.