In March 2026, the Omnibus I Directive entered into force, raising the CSRD threshold to more than 1,000 employees. The result: around 80% of companies originally targeted by the second wave fall outside the mandatory scope. For mid-sized companies between 250 and 999 employees, it’s a relief. For the large organisations that remain in scope, it’s a clear signal that compliance is now non-negotiable.
Within the social pillar of CSRD, the central challenge is ESRS S1. This standard covers a company’s own workforce: headcount, working conditions, compensation, training, health and safety, diversity. Almost all of these data points live in your HR module or HRIS. The question being asked by CHROs, CIOs, and CFOs of large in-scope organisations is no longer “do we have to do this?” but “is our HRIS actually capable of producing this data with the level of reliability an external auditor demands?”
This guide provides an honest assessment: what the revised ESRS S1 specifically requires, what leading HRIS platforms can already produce, what is systematically missing, and the concrete steps to close the gaps before the first FY 2026/2027 reports.
ESRS S1 After Omnibus: Who Is Still in Scope and What Does the Revised Standard Require?
The Scope After the Omnibus I Directive
The Omnibus I Directive, published on 26 February 2026 and effective from 18 March 2026, raised the CSRD threshold to two cumulative criteria: more than 1,000 employees on average over the financial year AND net turnover exceeding €50 million or a balance sheet total exceeding €25 million. Companies meeting both conditions remain subject to mandatory reporting.
First-wave companies (already subject to NFRD, 500+ listed employees) have been publishing ESRS reports since FY 2024. Entities newly entering the Omnibus scope publish their first report for FY 2027 (report filed in 2028), with the option of voluntary early application from FY 2026.
For in-scope companies, ESRS S1 remains one of the most demanding standards in terms of the volume of HR data to produce.
The July 2026 Revised ESRS S1: Fewer Data Points, But the Core Remains
On 3 July 2026, the European Commission adopted the revised ESRS based on EFRAG’s work. The revision reduces the number of mandatory data points by approximately 63% compared to the original 2023 ESRS, bringing the total to 292 “shall” data points across all standards. ESRS S1, E1, and ESRS 2 (general requirements) together account for roughly 65% of these remaining data points—a disproportionate share of the overall reporting burden.
What this revision means in practice for HR leaders:
- Many detailed narrative indicators (employee consultation processes, risk mapping by personnel category) become voluntary, moving to the non-mandatory implementation guidance (NMIG).
- Key quantitative indicators remain mandatory: headcount by gender, unadjusted gender pay gap, accident frequency rate, training hours.
- The “unadjusted” gender pay gap remains confirmed as a mandatory indicator in the revised ESRS—going further than most existing national pay equity reporting requirements.
ESRS S1 Versus ESRS S2: Two Distinct Exercises
ESRS S1 covers a company’s own employees (permanent and fixed-term contracts, agency workers counted within the company’s workforce, non-employees working primarily for it). ESRS S2 covers workers in the value chain: subcontractors, suppliers, workers in subsidiaries outside the consolidation scope.
This guide focuses on ESRS S1. S2 data falls primarily under the procurement and supplier management module, covered in our article on ESG supplier data and scope 3.
What Data Must Your HRIS Produce for ESRS S1?
The ESRS S1 standard comprises 16 disclosure requirements (S1-1 to S1-16). Below are the key quantitative indicators and their natural source within a typical HRIS.
Key Indicators and Their HRIS Source
| ESRS S1 Indicator | Requirement | Typical HRIS Source |
|---|---|---|
| Total headcount (S1-6) | Number of employees by gender, country (if 50+ employees), contract type | HR module — Workforce management |
| Turnover (S1-6) | Rate of entries and exits over the reporting period | HR module — Movements |
| Part-time rate by gender (S1-6) | % of part-time employees by gender | HR module — Contracts |
| Non-employees (S1-7) | Number of non-employee workers in scope | HR module — typically absent |
| Absenteeism rate (S1-8) | Days absent / theoretical working days | HR module — Absence/Leave |
| Unadjusted gender pay gap (S1-9) | Ratio of median female / median male compensation | Payroll module — requires configuration |
| Training hours per employee (S1-13) | Total training hours / headcount | Training module — often partial |
| Work accident frequency rate (S1-14) | Accidents with lost time / hours worked × 1,000,000 | HSE or HR module — often external |
| Collective agreement coverage (S1-8) | % of employees covered by a collective agreement | HR — rarely populated |
What Most HRIS Platforms Already Produce
Data that modern HRIS platforms have managed natively for years: headcount by gender and contract type, absenteeism rates, entry/exit movements. Across the EU and UK, equal pay reporting requirements—mandatory for large employers in most member states—have pushed HRIS vendors to structure compensation data by gender. This creates a solid foundation for the S1-9 indicator, though the ESRS calculation goes further: it requires the “unadjusted” pay gap (overall median across all roles and grades), whereas most national frameworks use adjusted methodologies that control for job level and category.
What Is Systematically Missing
Three categories of data create problems in almost every HRIS audited for ESRS S1:
1. Training hours broken down by sub-category. Many HRIS platforms record a total volume of training hours, but not the breakdown by type (regulatory training vs. skills development vs. management training), or by gender or occupational category at the granularity required by S1-13. Separate Learning Management System (LMS) platforms disconnected from the HRIS make this worse: the data exists, but in a silo that isn’t integrated.
2. Work accidents linked to actual hours worked. The ESRS S1-14 frequency rate requires actual hours worked as the denominator—not headcount. This data requires integration between the HR time management module and the HSE module (health, safety and environment), two modules that are often independent or managed on entirely separate systems (external HSE software such as Intelex, Cority, or Ideagen).
3. Non-employee workers. ESRS S1-7 requires companies to account for non-employee workers who work primarily for the organisation (regular freelancers, long-term sole traders). These individuals appear in no standard HR module: they exist in procurement or accounts payable. Collecting this data requires a manual process or a custom procurement/HR interface.
Auditing Your HR Module: Are You ESRS S1-Ready?
Before launching a configuration project, a quick audit precisely identifies the gaps. Here is an operational checklist to validate against your current HRIS.
ESRS S1 Checklist for Your HRIS
- Headcount: the “headcount as of 31 December by gender, contract type, country” export is available in under an hour of manipulation, without manual consolidation.
- Turnover: the entry and exit rate is calculated automatically, distinguishing voluntary from involuntary departures.
- Part-time: the gender split of part-time contracts is directly accessible.
- Compensation: the unadjusted median gender pay gap can be extracted (not just a national pay equity index calculation).
- Training: training hours per employee, by gender and occupational category, are consolidated in a single system (HRIS or connected LMS).
- Absenteeism: the absenteeism rate is automatically calculated with the correct denominator (theoretical working days, not calendar days).
- Work accidents: the frequency rate is calculable from internal data, without relying solely on national workplace injury authority reporting.
- Non-employees: a list of regular contractors (more than X days/year) exists somewhere in the information system (procurement, accounts) and can be cross-referenced with HR.
- Audit trail: modifications to HR data used for ESRS are traceable (change log, no silent edits).
- Multi-entity consolidation: data from multiple legal entities can be consolidated without an intermediate spreadsheet.
Typical Gaps by HRIS Type
SAP HCM / SuccessFactors: solid coverage of headcount and payroll. Common gaps on training hours (often in a separate LMS) and actual hours worked for the accident frequency rate. The connection with SAP Sustainability Control Tower (see next section) closes these gaps for S/4HANA customers.
Workday: strong structuring of HR and payroll data. The Workforce Planning module includes pre-configured dashboards for several ESRS S1 indicators. The Belong functionality covers diversity and inclusion. Weak point: consolidating multi-country data across distinct legal entities often requires specific configuration.
Mid-market payroll platforms (e.g. Sage Business Cloud Payroll, ADP Celergo, SD Worx for European operations): these cover compensation data and standard pay equity metrics well. However, they are not full HRIS platforms—training, absence management, and time tracking are often in separate tools, fragmenting ESRS S1 data collection.
Broader HR suites (e.g. ADP Workforce Now, Ceridian Dayforce, Cegid HR): wider HRIS coverage with integrated time and absence management. Main gap: ESG/ESRS indicators are not native in most versions currently in production, and extracting data in the correct format for an ESRS report requires parameterisation work or an interface to a dedicated ESG tool.
Configuring and Enriching Your HR Module for ESRS S1
Once gaps are identified, three types of action can address them without a full HRIS overhaul.
1. Create Custom Fields for Missing Indicators
Most HRIS platforms allow custom fields to be added to employee records or HR events. The priority fields to create for ESRS S1:
- Training type (regulatory / skills / management) on training actions.
- Actual hours worked (if the time management module does not automatically export an annual cumulative).
- “Regular non-employee” status on contractor records in the procurement module, with a transfer flag to HR for S1-7 consolidation.
2. Manager Data Collection Workflows
Some ESRS S1 data is not transactional: it requires qualitative judgment or active input. For example, collective agreement coverage by site, or tracking social dialogue commitments. Configure annual collection workflows in the HRIS (online forms assigned to local HR business partners by entity, with central validation) rather than distributing Excel spreadsheets.
3. Connect Your HRIS to a Dedicated ESG Platform
For companies whose HRIS does not natively offer an ESRS module, connecting to a specialised ESG tool is the most realistic path. Platforms such as Sweep, Greenomy, or Salesforce Net Zero Cloud offer HR data import APIs and produce ESRS S1 indicators in the format required for the report.
The standard configuration: weekly or monthly export of key HR data from the HRIS (via REST API or structured CSV) to the ESG platform, which aggregates, calculates ratios, and generates the report in the required format.
4. Multi-Entity and Multi-Country Consolidation
For large groups covering multiple countries, ESRS S1-6 requires a country breakdown for entities with more than 50 employees representing at least 10% of total headcount. If your group HRIS consolidates this data natively (Workday, SAP SuccessFactors, Oracle HCM), you have a solid foundation. Otherwise, an intermediate consolidation repository (Power BI, a dedicated ETL dashboard) is often necessary.
Integrated ERP/HRIS Solutions for ESRS S1 in 2026
SAP Sustainability Control Tower and ESRS S1
SAP has developed explicit ESRS S1 support in its Sustainability Control Tower (SCT) module. The H2-2025 SCT update includes pre-configured metrics aligned with ESRS disclosure requirements, notably S1-6 (workforce characteristics) as a natively supported indicator. S/4HANA Cloud customers can connect SAP HCM directly to the SCT to automate the collection of employee data into the sustainability report.
For companies on SAP ECC awaiting S/4HANA migration: HCM data is extractable to the SCT via interfaces, but full automation is only available in S/4HANA Cloud. The SCT module is an additional SAP licence.
Workday Workforce Planning and the Belong Module
Workday integrated ESRS indicators into its Workforce Planning and Belong modules from 2025, with pre-configured dashboards for diversity, pay equity, and training indicators. The platform allows ESRS S1 data to be extracted directly from the Workday Prism Analytics reporting interface, without third-party tools for customers whose full HRIS scope is within Workday.
Oracle HCM and the Oracle Fusion ESG Module
Oracle Fusion Cloud HCM includes ESG reporting capabilities allowing data from multiple source systems to be imported into a structured ESG data model aligned with ESRS, GRI, and IFRS. For ESRS S1 data specifically, Oracle HCM natively covers headcount, compensation, and training, with connectors to Oracle ESG Reporting for final report production.
Specialised ESG Tools as HRIS Supplements
For companies whose HRIS does not natively cover ESRS S1, specialised ESG platforms act as aggregators. Sweep offers API connectors to the leading HRIS platforms on the market and social data collection templates compliant with the July 2026 revised ESRS. Greenomy and Salesforce Net Zero Cloud offer similar approaches, with broader coverage of environmental standards (E1, E3, E5) alongside the social pillar.
Action Plan for Companies Still Behind
What You Need Configured Before January 2027
If your company falls within the post-Omnibus scope (1,000+ employees, financial thresholds exceeded) and plans a first report for FY 2026 or FY 2027, here are realistic milestones for Q4 2026 / Q1 2027:
October–November 2026: complete the HRIS audit against the ESRS S1 checklist above. Identify the three or four structurally missing data categories (typically: detailed training hours, work accidents with hours worked, recurring non-employees).
November–December 2026: configure missing fields in the HRIS and run first test extracts. Select the ESG tool if needed and run a pilot on one entity.
January–March 2027: produce a first complete dry run on FY 2026 data. Identify gaps, document assumptions and estimates. Consult your independent third-party assurance provider on methodology.
What Can Be Automated, What Will Remain Manual
Transactional data (headcount, payroll, absences, turnover) can be automated once the HRIS is correctly configured. Event-based data (work accidents with hours detail, training entries by category) requires active workflows with HR actors. Qualitative data (collective agreement coverage, social dialogue engagement tracking) will remain partially manual, in the form of annual collection forms.
What the External Auditor Will Verify
The independent third-party organisation (ITO) mandated for limited assurance will check three things on ESRS S1: completeness (all mandatory indicators are populated or have a documented omission explanation), consistency (ESRS report headcount matches statutory employment reports and group HR records), and traceability (every figure can be reconstructed from its source in the HRIS with a change log or audit trail). Companies that plan to extract their ESRS data from an Excel spreadsheet will not pass the reasonable assurance level envisaged going forward.
To go deeper on the overall regulatory landscape, read our CSRD and ERP guide covering all 12 ESRS standards and the ERP’s role in sustainability reporting. To understand the Omnibus Directive’s impact on your compliance perimeter, read our analysis of the EU Omnibus Directive. And if you are a supplier facing scope 3 pressure from your customers, our article on ESG supplier data for CSRD details what your procurement ERP must be able to produce.
