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do self-employed workers and temporary workers count in personnel questions ESG list

Self-employed contractors and temporary workers: own personnel counts according to contract, not by choice

Usually you only count employees with an employment contract in your headcount, and count self-employed contractors and temporary workers separately or not at all in those basic data. VSME makes a distinction between "own personnel" (employees on the payroll) and "non-own employees" (self-employed contractors, temporary workers, seconded employees). For headcount, turnover, gender distribution and training hours, the basic module focuses on own personnel. If you fill in a list that asks about the male-female distribution within the workforce, that in principle does not concern the temporary worker who is on the floor three days a week.

Where it does count again is in health and safety. Work accidents and policies about them are often asked about more broadly, including people who work under your actual authority but are not on your payroll. So check per question what is precisely meant before you enter a figure — for the question about work accidents with absence it is the same as for health and safety at work policy. If your chain file does not have a separate figure for non-own employees, it is better to leave it blank than to present an estimate as fact.

Where this is stated: VSME basic module, own personnel definitions

The VSME standard of EFRAG distinguishes explicitly in the basic module between "own personnel" (employees with an employment contract) and "non-own employees" (self-employed contractors, temporary workers and seconded employees), and links the quantitative indicators on headcount, turnover and diversity to the first category. Directive (EU) 2022/2464 (CSRD) is the basis on which this reporting logic for SMEs is built, but the concrete definitions and scope are set out in the VSME itself, not in the directive.

What this is based on

The regulation itself is on EUR-Lex. We refer for each claim; you do not have to take our word for it.

What you concretely need to do

The implementation of each obligation, with the deadlines involved and the templates for recording it, is included in the subscription.

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This is not legal advice. This page provides general information on the regulations this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, checked by a human on 2026-09-05. Is something incorrect? Let us know — corrections receive priority.