Questions & Answers
ESRS S1-16 talks about employees but does not specify if it is only those that meet the inclusion criteria (at least 50 employees and 10% of total employment).
- Employees
- gender pay gap
- significant employees
Background
ESRS S1 Disclosure Requirement S1-16 paragraph 95 states: ‘The undertaking shall disclose the percentage gap in pay between its female and male employees and the ratio between the remuneration of its highest paid individual and the median remuneration for its employees.’
The key characteristics of the undertaking’s employees are to be reported on in ESRS S1 Disclosure Requirement S1-6, which serves as a basis for information required by other disclosure requirements. ESRS S1 paragraph 50 (a) requires the disclosure of ‘the total number of employees by head count’ as well as ‘breakdowns by gender and by country for countries in which the undertaking has 50 or more employees representing at least 10% of its total number of employees;’.
Answer
ESRS S1 Disclosure Requirement S1-16 and AR 98-102 specifically refer to including all employees by head count in the calculation. Undertakings may report additional information based on differentiating the pay gap by specific employee groups or country/segment, as specified in paragraph 98; however, there is no employment threshold specified for the voluntary reporting of this additional information.