21. The objective of this DR is to enable an understanding of how much the undertaking relies on non-employees as part of its own workforce.

22. The undertaking shall disclose the total number of non-employees in the undertaking's own workforce.

AR 12 for para. 22 (Materiality considerations for non-employees)
This DR is applicable if non-employees within the undertaking’s own workforce are connected to material impacts, risks and opportunities related to own workforce. This situation arises if non-employees are critical to undertaking’s business model, for example if they are used to provide flexible labour or if they are used in core processes. Dependencies on non-employees due to the business model can be a risk for the undertaking, particularly if the reliance on non-employees is increasing, for example due to changes in labour market regulations. The use of non-employees can also be connected to material negative impacts if non-employees make up a substantial proportion of the undertaking’s own workforce or if potential or actual negative impacts are material in relation to non-employees.

AR 13 for para. 22 (Calculation method and use of estimates)
The total number of non-employees shall be calculated either in terms of headcount or full-time equivalents (FTE), and it shall be reported either as of the end of the reporting period or as an average over the entire reporting period. Explaining which of these options the undertaking has chosen may constitute material contextual information.
If the undertaking cannot report exact figures, it shall apply the provisions in ESRS 1 General Requirements regarding estimates.

Information on the point in time at which the number of non-employees is recorded: