CSRD and the Health Sector: How to Capture Workforce and Diversity Data

The health and social care sector is people-centred — your workforce is not only your biggest asset, but also the heart of your sustainability performance. Under the Corporate Sustainability Reporting Directive (CSRD) and the Voluntary Sustainability Reporting Standard for SMEs (VSME), care homes, clinics, and health service providers are expected to include key information on workforce structure, diversity, wellbeing, and development in their sustainability disclosures.

This guide explains how SME healthcare organisations can collect and report this information effectively, using simple HR data and existing staff records — no consultant or software system required. For related guidance, see the CSRD guide for care homes and clinics and how to calculate gender pay gap.

Why Workforce and Diversity Reporting Matters

The CSRD expands sustainability reporting beyond environmental data. For health and care organisations, social indicators are especially important because they reflect:

• Employee welfare and retention
• Equality, diversity, and inclusion in caregiving roles
• Staff training and career progression
• Organisational values and reputation

The VSME Standard mirrors this emphasis in its Social Modules (S1–S4):

• S1: Working conditions and employment
• S2: Equal treatment and opportunities
• S3: Health, safety, and wellbeing
• S4: Training and skills development

Together, these provide a compact but powerful framework for people-focused sustainability reporting.

Step-by-Step: Capturing Workforce Data

Step 1 – Gather Core Employment Data

Start with information you already hold in your HR or payroll system. Typical data points include:

• Total employees (headcount and full-time equivalents)
• Employment type (full-time, part-time, temporary, agency)
• Gender balance
• Age profile (optional but useful)
• Staff turnover and absenteeism rates

Example:

80 employees (65 FTEs), 78% female, 22% male, 15% part-time, 12% annual turnover.

Step 2 – Identify Key Workforce Indicators

These can be compiled annually using your existing HR reporting schedule.

Step 3 – Report in VSME Format (S1 – Working Conditions)

Narrative:

“Staff turnover decreased through improved working conditions and flexible scheduling. The organisation maintains gender balance reflective of the sector and invests in continuous staff wellbeing programmes.”

Step-by-Step: Capturing Diversity and Inclusion Data

Step 1 – Define What Diversity Means for Your Organisation

Under VSME S2 (Equal Treatment and Opportunities), SMEs are encouraged to consider diversity broadly — not just gender, but also:

• Age distribution
• Nationality or ethnic background (where legally collectable)
• Disability and accessibility
• Representation in management roles

You don’t need to collect sensitive personal data. Instead, focus on:

• Policies in place (e.g. equal opportunities, anti-discrimination)
• Outcomes you can measure (e.g. % of women in leadership roles)

Step 2 – Use Anonymous and Voluntary Data Collection

You can collect diversity data through:

• Anonymous staff surveys (simple, voluntary, and GDPR-compliant)
• HR onboarding forms (where appropriate)
• Regular policy reviews and training participation records

Always explain why the data is being collected and how it supports fair treatment.

Step 3 – Report Diversity and Inclusion Data (S2)

Narrative:

“Diversity and inclusion are central to our care culture. Women represent 62% of management positions, and all employees receive equality and inclusion training.”

Step-by-Step: Capturing Health, Safety, and Wellbeing Data

Step 1 – Track Existing Safety Metrics

The VSME S3 (Health, Safety, and Wellbeing) section expects SMEs to disclose basic safety data such as:

• Reported workplace incidents
• Lost-time injuries
• Absence due to work-related stress or illness

Example:

“Two minor workplace incidents were recorded in 2024, with zero lost-time injuries. Monthly wellbeing check-ins introduced for all staff.”

Step 2 – Include Preventive Measures

You can describe your approach qualitatively:

“Staff receive annual manual-handling training and mental health support. An internal safety committee meets quarterly to review incidents.”

Step-by-Step: Capturing Training and Development Data

Step 1 – Identify What You Already Track

Most care organisations already track training for compliance (e.g. first aid, safeguarding, infection control). Include this as part of VSME S4 – Training and Skills.

Narrative:

“Each employee receives at least 10 hours of training annually. A new mentorship scheme supports early-career carers and nurses.”

Integrating Workforce and Diversity into One Disclosure

These disclosures can be added as one short section in your annual CSRD or sustainability statement.

Practical Tips for Care SMEs

• Use existing HR tools: Payroll or rota systems already capture most data you need.
• Keep reporting light: One annual snapshot is enough.
• Respect privacy: Collect demographic data anonymously and voluntarily.
• Show action: Describe diversity or wellbeing initiatives, not just numbers.
• Compare year-on-year: Highlight improvements to demonstrate progress.

How It Aligns with CSRD and VSME

These disclosures demonstrate that health and care SMEs uphold fair, inclusive, and safe working conditions in line with EU sustainability goals.

Example: Care Clinic Workforce Summary

Organisation: WellLife Community Clinic Size: 65 employees Highlights:

• 78% female staff
• 15% turnover (down from 20%)
• 12 training hours per employee
• 0 lost-time injuries
• 95% of staff completed equality training

Narrative:

“The clinic prioritises staff wellbeing, equality, and professional growth. Enhanced training and flexible schedules reduced turnover by 25% while maintaining excellent patient care.”

Frequently Asked Questions

Do health and care SMEs need to report workforce diversity for CSRD?

Most small health and care providers are not directly required to report under CSRD, but they may need to provide workforce diversity data to funding bodies, accreditation organisations, or corporate partners who are CSRD-compliant. Under VSME B8-B10, workforce diversity reporting is encouraged for all SMEs. It demonstrates your commitment to inclusion and helps meet stakeholder expectations.

Check if CSRD applies to your organisation →

How do I collect gender and diversity data if I don’t have it in HR systems?

Start by adding gender and diversity fields to your HR or payroll systems. For existing employees, you can collect this data through a voluntary survey or during annual reviews. Be transparent about why you’re collecting the data (for CSRD/VSME reporting) and ensure privacy. The VSME allows flexibility — you can aggregate data where detailed breakdowns would risk privacy or are not available.

See the complete care home guide →

What if I have fewer than 50 employees - do I still need to report diversity?

Yes, but you can simplify your reporting. For organisations with fewer than 50 employees, you can report only total headcount and overall gender ratio, rather than detailed breakdowns by function or leadership. This keeps reporting proportionate while still demonstrating your commitment to diversity and inclusion. As you grow, you can expand your reporting to include more detailed metrics.

Can I use existing HR or accreditation data for CSRD reporting?

Yes! You can reuse data from HR systems, payroll records, accreditation reports, and any existing diversity initiatives. The VSME Standard is designed to work with data you’re already collecting for operational or regulatory purposes. Just organize your existing HR data into the VSME Basic Module format (B8-B10) for your sustainability report.

Key Terms

• CSRD: Corporate Sustainability Reporting Directive (EU 2022/2464)
• VSME: Voluntary Sustainability Reporting Standard for SMEs (EFRAG, 2024)
• S1–S4: VSME social modules covering workforce, diversity, health, and training
• Double materiality: Considering both how sustainability affects the business and how the business affects people
• FTE: Full-time equivalent
• Inclusion policy: A statement committing to fair and equal treatment of all employees