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Basic Module

B10: Workforce – Remuneration, Collective Bargaining and Training

Disclosure requirements for minimum wage, gender pay gap, collective bargaining coverage and training hours.

VSME Standard Reference

The following content is extracted from the official EFRAG Voluntary Sustainability Reporting Standard for non-listed SMEs (VSME), December 2024.

View original VSME Standard (PDF)

Selko Insights

Methodology

Headcount Reporting Timing

For all B10 disclosures, Selko Report instructs users to base reporting on headcount at fiscal period end. This ensures consistency across all workforce-related metrics and enables meaningful year-over-year comparisons.

Interpretation

Understanding the Unadjusted Gender Pay Gap

The unadjusted gender pay gap compares average pay between all male and female employees without accounting for factors like job role, experience, or working hours. While useful as a high-level indicator of structural pay discrepancies across economies or industries, it can be misleading for individual companies. A small business with few employees in different roles may show a significant gap that doesn’t reflect unequal pay for equal work. This metric is primarily designed to reveal systemic patterns rather than company-specific discrimination.

Regulation

EU Pay Transparency Directive & Thresholds

The EU Pay Transparency Directive (2023/970) requires companies to report on gender pay gaps and take corrective action when gaps exceed 5%. The VSME standard aligns with this directive by setting employee thresholds for mandatory reporting: currently 150 employees, reducing to 100 employees from June 7, 2031. Companies below these thresholds may omit gender pay gap disclosure, though voluntary reporting is encouraged.

Definition

What Counts as Training Hours

The VSME standard does not explicitly define what constitutes training hours. In Selko Report, we interpret this broadly to include all forms of training and education—both formal and informal. This includes structured courses, workshops, certifications, on-the-job training, mentoring programs, e-learning, conferences, and other professional development activities.

Data Quality

First-Time Training Data Collection

If your organization has not previously collected annual training hour data broken down by gender, or if the available data is based on estimations, Selko Report accepts this for the current reporting period. We recommend clearly noting this in your report and establishing more robust data collection processes for subsequent reporting periods to improve accuracy and comparability.

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