Do Remote Workers Count Toward CSRD Workforce Metrics?

Introduction

Since the pandemic, remote and hybrid work have become a normal part of doing business — especially for SMEs. But when it comes to CSRD reporting, many companies are unsure whether remote employees should be counted in workforce disclosures.

The answer is simple: yes, they do. Under both the Corporate Sustainability Reporting Directive (CSRD) and the VSME Standard, all employees under a company’s employment contract are part of its “own workforce”, whether they work in an office, on-site, or from home.

This guide explains how to count remote workers correctly, how they fit into CSRD workforce metrics, and how to handle data collection challenges for hybrid teams.

1. How CSRD Defines “Own Workforce”

According to ESRS S1 (Own Workforce), your workforce includes:

• Employees (full-time, part-time, permanent, or temporary), and
• Non-employee workers who perform tasks under your direction (e.g. agency staff).

The definition is based on the employment relationship, not the location. This means that employees working remotely — fully or partially — must be included in your CSRD workforce metrics such as headcount, diversity, training, and wellbeing.

The same principle applies under the VSME Basic and Comprehensive Modules, which use the same workforce definition for proportional SME reporting.

2. Where Remote Workers Are Included in CSRD Disclosures

Remote workers affect several workforce-related disclosures, including:

The only difference is how you collect and report data — not who is included.

3. Data Collection Tips for Remote and Hybrid Teams

Tracking workforce data for hybrid or remote employees can be straightforward if you align it with your existing HR and payroll systems.

Best practices:

• Use HR software to calculate headcount and FTEs automatically.
• Record training hours for both in-person and online learning.
• Collect engagement or wellbeing data through digital surveys.
• Use consistent metrics across locations and working arrangements.

For environmental metrics such as energy use or commuting emissions, remote work should be treated separately. For example, remote workers may reduce commuting emissions (Scope 3), but may indirectly increase household energy use. You can find a full method in our guide on calculating employee commuting emissions for CSRD.

4. How to Disclose Remote Work Policies

Beyond data inclusion, the CSRD also encourages qualitative disclosures on working conditions and flexibility policies. You can describe:

• The share of your workforce with flexible or hybrid arrangements.
• Measures taken to support ergonomic and mental wellbeing.
• Digital inclusion and right-to-disconnect policies.

Example disclosure:

“As of 2025, 42% of employees work remotely at least two days per week. The company provides ergonomic guidance, online training, and annual wellbeing surveys to support hybrid working.”

This aligns with ESRS S1-12 (Working Conditions) and shows proactive management of workforce health and engagement.

5. Remote Workers and Assurance Requirements

When your CSRD data is reviewed under limited assurance, auditors will check that your workforce metrics — including remote workers — are:

• Derived from verifiable HR records, and
• Consistent with payroll or financial data.

The accuracy requirement is “reasonable and traceable,” not perfect. As long as remote staff are consistently included and methods are disclosed, your approach will meet assurance standards.

For details on data verification, see our guide on how accurate CSRD data needs to be.

Frequently Asked Questions

Do freelancers or contractors count?

Only if they work under your control and direction, similar to employees (e.g. agency staff). Independent contractors generally count under value chain (Scope 3) disclosures, not “own workforce.”

Should I separate remote workers in my metrics?

Not required, but optional. You can report a breakdown (e.g. 60% on-site, 40% remote) if it’s relevant to your workforce strategy or ESG goals.

How do I handle data for cross-border remote employees?

Include them if they are contracted by your EU entity. For payroll and HR metrics, use the same systems and definitions as domestic employees.

What if remote workers’ data is incomplete?

Use estimates based on HR averages and document assumptions — the CSRD and VSME allow proportional data quality for smaller businesses.

Key Terms

• Own workforce – All employees under contract, including remote and part-time staff.
• ESRS S1 – The European Sustainability Reporting Standard for workforce disclosures.
• Hybrid work – Employees splitting time between remote and on-site work.
• Limited assurance – Independent review of data accuracy and consistency under CSRD.
• VSME Standard – Simplified sustainability reporting standard for SMEs.

Conclusion

Remote workers are an integral part of your CSRD workforce metrics — counted the same way as office-based staff. The distinction lies not in who is included, but how you manage and disclose their data responsibly.

By aligning HR systems, documenting your assumptions, and reporting remote work policies transparently, your SME will meet both CSRD and VSME expectations with confidence.

For a broader overview of how to time your data collection, check out our annual CSRD reporting calendar.