How Do I Report Work-Related Accidents and Fatalities?

What are you actually being asked to report?

When completing the health and safety section of your sustainability report, a practical question quickly comes up: which incidents should actually be included?

An accident at the office may seem straightforward. But what about an employee injured while working from home, an incident during a business trip, or a health condition that develops over time?

B9 – Workforce – Health and safety addresses information about your company’s employees. It asks for:

• The number of recordable work-related accidents.
• The rate of recordable work-related accidents.
• Subject to legal restrictions, the total number of fatalities resulting from recordable work-related accidents and recordable work-related ill health.

These figures serve different purposes. The accident count tells readers how many accidents occurred. The accident rate relates that count to hours worked, making the figure more useful when comparing companies of different sizes or tracking changes over time.

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Step 1: Identify which accidents should be included

Start with the records your company already maintains, such as incident reports and occupational health and safety records.

For each incident, establish whether it qualifies as a recordable work-related accident under the national legislation and reporting obligations that apply.

EFRAG’s guidance points to national rules for this assessment. An incident should not automatically be included simply because it happened during working hours, and the location alone does not determine whether it is work-related.

A practical review should establish:

• What happened and when.
• Whether the person involved was an employee covered by the reporting.
• Whether the incident was related to their work.
• Whether it is recordable under the applicable national rules.
• What documentation supports the classification.

If your company operates in several countries, check the rules that apply to the employees concerned rather than assuming one national definition covers every location.

Count the qualifying accidents for the reporting period. Do not substitute sick days, days lost, or the number of employees who took sickness absence for the accident count.

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Step 2: Check incidents during remote work and travel

Work-related incidents can occur away from your company’s premises. The guidance specifically addresses remote work and travel.

Working from home

For remote work, the relevant distinction is whether the injury or illness is directly related to performing the work, rather than to the general home environment. Applicable national legislation still governs the assessment.

For example, an injury connected to carrying out a work task at home needs to be assessed for its connection to that task. An unrelated household accident should not automatically be treated as work-related because it happened during the working day.

Business travel

An accident or illness occurring during business travel is considered work-related when the employee was performing activities in the employer’s interest at the time.

The fact that an employee is away on a business trip does not, by itself, establish that every incident during the trip is work-related. Review what the employee was doing when the incident occurred.

Travel to and from work

For ordinary commuting, follow applicable national legislation. The guidance does not establish one universal rule that all commuting accidents must be included or excluded.

Document how you reached the classification, particularly where the circumstances require judgment.

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Step 3: Calculate the accident rate

Once you have the accident count, calculate the rate using the employees’ total hours worked during the same reporting period.

The calculation is:

Accident rate = (Number of recordable work-related accidents ÷ Total hours worked) × Reference hours

The reference hours can be either:

• 200,000 hours, representing the annual hours of approximately 100 full-time workers when each works 2,000 hours.
• 1,000,000 hours, representing approximately 500 full-time workers on the same assumption.

State which basis you use. A rate of 7.5 per 200,000 hours and a rate of 37.5 per 1,000,000 hours can describe exactly the same accident record.

A practical example

Company A recorded three work-related accidents during the reporting year. Its employees worked a total of 80,000 hours.

Using 200,000 reference hours:

(3 ÷ 80,000) × 200,000 = 7.5

Using 1,000,000 reference hours:

(3 ÷ 80,000) × 1,000,000 = 37.5

Company A would therefore report three accidents and either:

• An accident rate of 7.5 per 200,000 hours worked, or
• An accident rate of 37.5 per 1,000,000 hours worked.

Choose a basis and apply it consistently so readers can compare your results over time.

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Step 4: Estimate working hours if actual figures are unavailable

If you cannot calculate hours worked directly, the guidance allows you to estimate them using normal or standard working hours.

For example, 40 full-time employees working an assumed 2,000 hours each would represent:

40 × 2,000 = 80,000 hours

The 2,000-hour figure is an assumption used in the guidance, rather than a fixed figure every company must use.

Your estimate should reflect your workforce and reporting period. Account for part-time employees and employees who worked for only part of the year, rather than multiplying year-end headcount by a full year’s hours.

Record the assumptions behind the estimate and explain that the hours were estimated.

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Step 5: Report fatalities from accidents and work-related ill health

The fatality disclosure covers deaths resulting from both recordable work-related accidents and recordable work-related ill health, subject to legal restrictions.

Work-related ill health includes cases the company has been informed about by:

• The affected person.
• Compensation agencies.
• Healthcare professionals.

It also includes cases identified through medical surveillance during the reporting period.

The guidance explicitly places work-related musculoskeletal disorders within work-related ill health, rather than work-related accidents. Keep that distinction when preparing your figures.

B9 does not ask you to add every case of work-related illness to the accident count. The fatality disclosure, however, includes deaths resulting from qualifying work-related illness as well as accidents.

You may present the two fatality categories separately alongside their combined total.

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Keep the reasoning behind your figures

A useful reporting record contains more than the final numbers. It should make it possible to understand how those numbers were prepared.

As a practical approach, retain:

• The accident count and supporting classifications.
• The total hours worked and whether they were measured or estimated.
• The reference hours used for the accident rate.
• The calculation and any estimation assumptions.
• The basis for including fatalities in the relevant category.

Keep personal incident records appropriately protected. The sustainability disclosure concerns aggregate figures; it does not require publishing employees’ names or individual medical histories.

If your review confirms there were no qualifying accidents or fatalities, report zero in the relevant fields. Missing information should not automatically be recorded as zero.

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Preparing your information for Wardn

Before completing the B9 questions in Wardn, prepare the accident count, working hours, calculation basis, and fatality figures for the same reporting period.

Having these figures ready makes it easier to enter consistent information and explain the result if a customer, bank, or other stakeholder asks how it was calculated.

Where you have estimated hours or made a classification judgment, keep a short explanation with your supporting reporting documentation.

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Frequently asked questions

Does every accident at the workplace count?

No. Assess whether it is a recordable work-related accident under applicable national legislation and reporting obligations. The location alone does not settle the classification.

Should accidents during remote work be included?

They should be assessed for their direct connection to performing work, subject to applicable national legislation. An accident related only to the general home environment is not automatically work-related.

Do commuting accidents count?

Follow applicable national legislation. The guidance leaves the classification of ordinary commuting accidents to national rules.

Should we use 200,000 or 1,000,000 hours?

The guidance allows either basis. State which one you use and apply it consistently. Both describe the same underlying accident record when calculated correctly.

Can we estimate hours worked?

Yes. If actual hours cannot be calculated directly, use normal or standard working hours to make a reasonable estimate and document your assumptions.

Should work-related illnesses be included in the accident count?

Keep them separate. The guidance distinguishes work-related ill health, including work-related musculoskeletal disorders, from work-related accidents. Fatalities resulting from either category are covered by the fatality disclosure.

Where can we find the original guidance?

See EFRAG’s Voluntary Standard Guidance, under B9 – Workforce – Health and safety, paragraphs 112–120.

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