ESRS S1-13 Training & Skills Development
ESRS S1-13 requires companies to disclose average training hours per employee and the percentage receiving regular performance reviews. As automation and AI reshape workforce requirements, skills development has become a material sustainability topic — and S1-13 makes training investment transparent for the first time under mandatory reporting.
ESRS S1-13 requires companies to disclose average training hours per employee and the percentage receiving regular performance reviews. ESRS S1-13 requires two core disclosures:.
What ESRS S1-13 requires
ESRS S1-13 requires two core disclosures:
Average training hours per employee per year: Total training hours delivered during the reporting period divided by total average employee headcount during the year. Broken down by gender and employee category (management, professional, administrative, production — or your company's specific categorisation).
Percentage of employees receiving regular performance and career development reviews: The proportion of employees who received at least one formal performance review during the reporting period. Broken down by gender and employee category.
Additionally: a description of the training and skills development programmes in place — what types of training are offered, how training needs are identified, and how training investment aligns with the company's strategy and transition plan.
The two metrics together tell a skills development story: training hours shows the quantity of learning investment; performance review coverage shows whether career development conversations are happening. A company with high training hours but low performance review coverage is investing in training without structured career development; a company with high review coverage but low training hours has the conversation framework but limited development investment.
For ESRS E1 transition plan alignment: companies with climate transition plans that require workforce reskilling (for example, automotive companies transitioning from ICE to EV production) should link S1-13 training investment to the transition plan — showing investors that the workforce capability for the transition is being built.
Calculating average training hours accurately
Average training hours is one of the most variable metrics in ESRS S1 — calculation choices can produce significantly different results, and inconsistencies between years and peer companies undermine comparability.
Training hours definition: Total hours of training content received by employees — not time in the training room including breaks, travel, and administration. A one-day training course delivers approximately 6 hours of training content (8-hour day minus breaks). Online learning modules are measured by their stated duration. On-the-job training is measured by hours of structured mentoring or supervised practice.
Types of training to include: Formal classroom training (internal and external); e-learning and digital courses; on-the-job training where structured and documented; professional development programmes; language and cultural training; compliance and mandatory training (H&S, data protection, anti-corruption); leadership development programmes; and technical skills training. Exclude: general team meetings, unstructured observation periods, and informal conversations.
Average calculation: (Total training hours delivered) ÷ (Average employee headcount during the year). Use average headcount (beginning of year + end of year ÷ 2) rather than year-end headcount — this avoids distortion from significant workforce changes during the year.
Breakdown accuracy: Training hours often concentrated in certain employee categories (managers receive more leadership training; production workers receive more H&S training). The breakdown by employee category reveals investment patterns. Verify that category-level averages are calculated correctly — total hours per category ÷ average headcount per category, not the overall average applied to each category.
Performance review coverage — design and data collection
Performance review coverage is a binary metric — did the employee receive a formal review during the year — but the governance of performance management processes makes data collection more complex than it appears.
What counts as a 'regular performance and career development review': A structured conversation between manager and employee covering: assessment of performance against objectives; identification of development needs; career development discussion; objective-setting for the next period. This must be documented — a documented review is verifiable; an undocumented conversation is not.
Systems and data: Most large companies manage performance reviews through an HRIS or dedicated performance management system (Workday, SAP SuccessFactors, Oracle HCM). The system tracks completion status for each employee. Year-end completion rate from the system provides the S1-13 metric directly.
Completion vs quality: A 95% performance review completion rate is a positive metric — but completion does not guarantee quality. Assurers accept completion rate as the metric; they do not assess review quality. However, the qualitative S1-13 narrative on training and development programmes should contextualise the review process — explaining how reviews are structured, how outcomes feed into development plans, and how the process has evolved.
For companies without formal review systems: if performance reviews are conducted informally without a system, estimate coverage from manager confirmation or HR records. Acknowledge the limitation and commit to implementing a systematic process. A 0% disclosed rate for performance reviews — if accurate — creates reputational and investor questions about workforce management culture.
Frequently asked questions
Do we include mandatory compliance training (H&S, data protection) in training hours?
Yes — mandatory compliance training counts as training hours. H&S induction, annual anti-corruption e-learning, GDPR refresher training, and fire safety training all represent time invested in employee development (albeit compliance-driven). Include in the total training hours. Where compliance training represents an unusually high proportion of total training hours, contextualise in the qualitative narrative.
We use external training providers — how do we capture their training hours?
Request annual training completion certificates from external providers listing: employee names, course titles, dates, and duration. Alternatively, track external training through your expense management system (training invoices specify courses and participants) or through the individual employee's training record in HRIS. For conference attendance counted as training, use the official programme duration as the training hours.
Our manufacturing workers receive significant on-the-job skills training — how do we measure it?
Structured on-the-job training — where a supervisor follows a documented training plan with a specific learning objective and records completion — counts as training hours. Use the training plan duration as the hours. Unstructured observation and informal learning do not count. To capture on-the-job training in S1-13, formalise the process: create training plans for each role, track supervisor-guided training completion, and record hours in the HRIS.