This page sets out how the 2024 WDI survey overlaps with, complements and exceeds the CSRD in Europe as the legislation becomes mandatory. Specifically, it covers areas of alignment and shared metrics between the WDI survey and the first European Sustainability Reporting Standards (ESRS).
The WDI is supportive of the development of standardised mandatory corporate disclosures, which will play a critical role in driving positive change for investors, companies, and their workers. However, these standards – at least in the short term – are unlikely to provide enough comprehensive social data to truly help companies understand their own social impact and take steps to improve it. This is because mandatory disclosures are designed to set a baseline minimum for what sustainability factors companies must report, whereas voluntary initiatives (like WDI) offer more comprehensive and ambitious data points, pushing companies to demonstrate complete oversight over their social activities. Alignment and interoperability between these mandatory and voluntary disclosure initiatives, therefore, is key to ensure the two complement each other effectively.
This page has been developed as a supporting tool to help organisations understand the commonalities between the WDI and CSRD frameworks. It should also be a useful tool for WDI investors engaging companies, as awaiting mandatory reporting requirements has been a leading reason for companies not to participate in the WDI survey. This page aims to reassure European companies that WDI participation provides them with the best possible preparation for upcoming mandatory reporting.
This page provides generalised context for the role of voluntary disclosure initiatives amid rising mandatory reporting. More specifically, it maps the WDI survey against the disclosure standards set out by the ESRS. This follows a columnar format mapping the WDI survey questions against the relevant European sustainability standards.
As WDI is a workforce disclosure framework, ESRS crossover is limited to ESRS 1, ESRS2, ESRS S1, ESRS S2, and ESRS S3. It is important to note that the document does not list out the ESRS in full, but rather, sets out the ESRS topics and maps it to the relevant WDI data points.
The WDI is an investor-backed project to improve the quality and quantity of corporate workforce data, via an annual survey and engagement process. Each year, on behalf of our investor signatories, the WDI requests global companies from all over the world submit an answer to our comprehensive survey that covers their social activities across both their direct operations and value chains.
The WDI is an annal survey with a disclosure window that takes place between July and October each year. It is a voluntary initiative, meaning companies choose to partake each year.
In 2023, 166 companies submitted responses to the WDI. These companies had a combined market capitalisation of US$10 trillion and represented all economic sectors. Submissions covered over 10 million employees in companies’ direct operations and many more in supply chains.
The survey consists of over 130 questions and more than 200 datapoints. It is split into 13 sections covering everything from governance, risk analysis and assessment, to a breakdown of employees by demographic, how companies train and engage their colleagues, how they ensure responsible sourcing and what their supply chain looks like.
| Section 1 – Governance | Section 8 – Health, safety and wellbeing |
| Section 2 – Risk assessment and human rights due diligence | Section 9 – Worker voice and representation |
| Section 3 – Workforce composition | Section 10 – Grievance mechanisms |
| Section 4 – Diversity and inclusion | Section 11 – Value chain transparency |
| Section 5 – Workforce wage levels and pay gaps | Section 12 – Responsible sourcing |
| Section 6 – Stability | Section 13 – Value chain working conditions |
The survey is sector agnostic. It does not apply a sector lens and each question has been designed so that every company can provide some information, irrespective of what industry they are from.
The WDI is supporting industry efforts to deliver greater interoperability between frameworks as part of a mission to generate more comparable and comprehensive social data. To help achieve this, the WDI team has supported various standard setting initiatives – both mandatory and voluntary. The team participated in the European Financial Reporting Advisory Group’s Project Taskforce, helping to develop the technical reporting standards for the CSRD. The WDI also regularly engages with other reporting frameworks and standard setters, including the International Sustainability Standards Board (ISSB).
The data points in the WDI survey are mapped against:
| Corporate Human Rights Benchmark | UN Principles for Responsible Investment |
| Committee on Workers’ Capital | UN Sustainable Development Goals/Global Goals for Sustainable Development |
| Dow Jones Sustainability Indices | Securities and Exchange Board of India Core Business Responsibility and Sustainability Reporting |
| European Sustainability Reporting Standards | Sustainable Finance Disclosure Regulation |
| Ethical Trading Initiative Reporting Framework | UN Universal Declaration of Human Rights |
| Global Reporting Initiative | United Nation Global Compact |
| International Labour Organization | United Nations Guiding Principles |
| ISO 26000: Social Responsibility | UN Guiding Principles Reporting Framework |
| ISO 30414: Human Resource Management | World Benchmarking Alliance |
| KnowTheChain | Workplace Gender Equality Agency |
| Organisation for Economic Co-operation and Development |
The granularity of the data points is unique to the WDI due to the comprehensiveness of the survey. 49 WDI questions are directly aligned to the ESRS.
The WDI is an investor-focused initiative which operates a financial materiality model. This means an issue is deemed material if it affects, or has the potential to affect, the cash flow and financial value creation for a company.
The CSRD enhances the reporting requirements under the Non-Financial Reporting Directive (2014/95/EU) (NFRD) and extends non-financial reporting to significantly more organisations. It was ratified by the EU Council in 2022 and legally requires companies to report on their material impacts, risks, and opportunities in relation to environmental, social and governance sustainability matters, both within their direct operations and across their value chains.
The CSRD sets out the mandate and framework for sustainability reporting. It is supported by the European Sustainability Reporting Standards (ESRS), which are the disclosure standards companies must report to comply with the CSRD.
In tangent with the CSRD, EU Parliament has also voted to adopt the CSDDD, another pivotal piece of sustainability reporting legislation. It aims to foster sustainable and responsible corporate behaviour throughout global value chains by implementing due diligence obligations related to human rights and environmental standards. Unlike the CSRD, which mandates the disclosure of sustainability information, the CSDDD requires companies to identify, prevent, and mitigate adverse human and environmental impacts in their operations and value chains. It covers large EU companies, non-EU companies active in the EU, and high-risk sectors. Together, the CSRD and CSDDD make up complementary pillars of the EU’s sustainability framework.
In December 2023, the European Commission published its first set of European Sustainability Reporting Standards under the CSRD ((EU) 2022/2464). This was developed by the European Financial Reporting Advisory Group (EFRAG) to improve ESG reporting within the EU, generating more accurate, comparable, and standardised data. The ESRS came into force on 1 January 2024 for financial years beginning on or after 1 January 2024.[1]
The application of these sustainability reporting standards will be progressive and will be enforced between 2024 and 2028 in the following format:
The ESRS is mandatory for all companies which fall under the scope of the CSRD, including all large companies and publicly listed SMEs (except micro companies) that cover at least two of the following three:
It also covers non-EU companies if they have securities listed in the EU, have significant activity in the EU, or are parent companies of in-scope EU subsidiaries. It is estimated that nearly 50,000 EU companies should publish sustainability information under ESRS.
The ESRS are a set of 12 standards: two cross-cutting standards (ESRS 1 and ESRS 2) that provide general reporting concepts and overarching disclosure requirements; and ten topical standards with specific disclosure requirements for ESG matters (bold metrics overlap with the WDI):
| ESRS 1 (cross-cutting) – General Requirements | ESRS E5 (environment) – Resource use and circular economy |
| ESRS 2 (cross-cutting) – General Disclosures | ESRS S1 (social) – Own workforce |
| ESRS E1 (environment) – Climate | ESRS S2 (social) – Workers in the value chain |
| ESRS E2 (environment) – Pollution | ESRS S3 (social) – Affected communities |
| ESRS E3 (environment) – Water and marine resources | ESRS S4 (social) – Consumers and end users |
| ESRS E4 (environment) – Biodiversity and ecosystems | ESRS G1 (governance) – Business conduct |
The social standards include data points on employee rights, health and safety standards, gender equality and pay equity. They also cover a company’s relationship with other stakeholders, including customers, value chain workers and affected communities.
As with the WDI survey, these European sustainability standards are sector agnostic.
Throughout the drafting process, the ESRS have been amended to closer align with other frameworks and regulations, including the Sustainable Finance Disclosure Regulation (SFDR), the International Sustainability Standards Board (ISSB), and Task Force on Climate-Related Financial Disclosures (TCFD) standards. To better specifically align, EFRAG divided the standards into four similar pillars Governance; Strategy; Impact, Risk and Opportunity Management; and Data and Objectives.[3]
ESRS interoperability guidance has been released by various standard setting bodies, including the ISSB, GRI, and CDP.
ESRS is based on double materiality, meaning it includes disclosures that are relevant both because the information relates to possible financial impacts on a company (financial materiality) and/or a business’s impact on people and planet (impact materiality).
The rise of mandatory sustainability reporting has been impeded by significant industry pushback from company leaders concerned about a reporting burden. In Europe, this resulted in some aspects of the ESRS being “watered down”, including phasing-in reliefs (particularly for smaller companies with fewer than 750 employees), increased flexibility in determining materiality and the option to adopt certain requirements voluntarily.[4] This generates inevitable data gaps. In the first year, for example, companies with fewer than 750 employees may omit data on own workforce (S1), companies in the first two years, with fewer than 750 employees can omit the disclosure requirements on value-chain workers (S2), affected communities (S3), and consumers and end-users (S4).[5]
With its comprehensive social data points, the WDI survey plugs these data gaps, providing the investment community with the consistent, comparable, and reliable information necessary for investors to allocate capital in alignment with sustainability objectives.
The WDI survey is designed to be complimentary and interoperable with other reporting frameworks, meaning participating companies can use it to refine and improve their workforce reporting ahead of mandatory disclosures. Notably, companies responding to the WDI survey for the first time provided on average 36 percent of answers. This is nearly double the data collated from non-responders’ reports and websites which resulted in an average completion rate of 20 per cent.
The reason companies find it challenging to complete the WDI survey, even by those who have participated for seven years in a row, is that the questions are designed to stretch companies and push them to improve their oversight of workforce data, especially on emerging topics. It exists as a “gold star” disclosure level to strive for, pushing companies to go above and beyond the typical disclosure levels required by mandatory reporting frameworks.
Results show the longer companies take part in the WD survey, the more data they can provide. Third year responders provided more than double the data submitted by first-time responders, and more than three times as much as information non-responders are publishing. Meanwhile those who have participated for seven years running provided 74 percent of the data, double first-time responders and nearly three times more than non-responders. The survey is designed to help companies identify data gaps, as well as providing investors with the level of detail they need to truly understand how a company is managing its workforce. It is therefore not expected that companies will have all the answers but through the iterative nature of the WDI process, they can add more information to their response, learn more about their business and communicate directly with investors.
The delays, dilutions, and modifications to the ESRS cast doubt over the robustness of the social information they will provide, which is concerning for some businesses. In the current economic climate, the financial materiality of a company’s social activities is becoming increasingly clear. A CIPD survey of 1,500 UK business leaders, for example, found that the biggest issues facing organisations were related to inflation, recruitment, retention, and pay/reward. Four in 10 (42%) leaders said skills and/or labour shortages were one of the main challenges facing their business, while a similar percentage (40%) cited inflation in the general cost base and 35% specified wage inflation.[6] As the “gold standard” of social reporting, the WDI can support companies in genuinely understanding their impact on their workforce. The social data generated by the WDI outstrips that of the ESRS in its current form, and helps companies understand what steps they need to undertake to provide better working conditions and protect their staff.
Mandatory disclosure frameworks like the CSRD will be critical in generating social data for investors which is comparable across companies, countries, and sectors. However, they will not provide the same level of tailored workforce information as the WDI, which collates, compares and benchmarks the data provided by participating companies, drawing out wider workforce trends.
The data submitted in response to the WDI survey is provided directly to the group of around 50 investor signatories from all over the world who use the data in various interesting ways. Beyond that group, providing such detailed workforce information in a standardised, comparable format means other potential investors can fully understand how an organisation is managing its most important asset: its people.
WDI goes on step further than mandatory standards by providing all responding companies with a “Disclosure Scorecard” and individualised feedback so they can benchmark their data collection. This resource enables companies to discover best practise from other participating companies and ultimately supports them in improving their own disclosure year on year.
ESRS is based on double materiality, meaning it includes disclosures that are relevant both because the information relates to possible financial impacts on a company (financial materiality) and/or a business’s impact on people and planet (impact materiality).
This document shows a list of shared metrics & areas of alignment (ESRS 2, S1, S2, S3)
NOTE: WDI shares 49 social data points with the ESRS.
This list of WDI data points is not exhaustive, rather it covers a sample of relevant WDI data points with a high level of crossover with the ESRS.