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Biodiversity and real estate: why some ESG projects become non-consolidable

Biodiversity and real estate: why some ESG projects become non-consolidable

Wednesday, May 7, 2025

While biodiversity is becoming increasingly important in the extra-financial criteria of many real estate groups, a subtle but consequential flaw is emerging in certain decision-making processes. Some projects, despite being presented as committed to sustainability, are becoming ineligible to meet the expectations of sustainable investors, Article 9 funds, or SFDR compliance audits. Why? Because the right approach wasn't taken when choosing the biodiversity assessment or certification method. And this seemingly minor technical decision can be enough to exclude the project from the scope of consolidable ESG criteria.

🟦 1. Biodiversity: an ESG criterion that has become strategic

  • The inclusion of biodiversity in ESG analysis frameworks is now structural.
  • AMF (doctrine article 29), SFDR (European regulation), SRI or Greenfin labels: all reference schemes expect evidence of measurable, traceable, comparable environmental actions.
  • Real estate, as a sector that both generates and occupies land, is directly exposed to this requirement.

🟦 2. A silent flaw in the governance chains

  • Many developers or project owners are showing a sincere willingness to take biodiversity into account.
  • But on the ground, the choice of framework or approach is often delegated to the MOEX, to an AMO or to a technical partner, without validation of real ESG compliance.
  • The result: projects outside the established framework without the CSR management being aware of it.

🟦 3. What ESG funders and auditors actually check

A biodiversity framework is considered ESG-compliant if it meets the following conditions:

  • It is backed by an independent third-party organization
  • It is based on a transparent and reproducible method,
  • It allows for public verification (audit, independent evaluation)
  • It is recognized by the relevant institutions (ADEME, CDC, public labels, Article 8/9 funds)
  • It can be documented within the framework of the SFDR (PAI criteria, biodiversity indicators).

Any tool that does not meet these conditions cannot be consolidated into serious ESG reporting.

🟦 4. The risks of a bad choice

  • ❌ Inconsistency between corporate CSR report and project practices
  • ❌ Loss of credibility with institutional partners
  • ❌ Blocking or withdrawal of sustainable financing
  • ❌ Questioning of the project in the investment committees
  • ❌ AMF non-compliance in the event of a group audit

🟦 5. Effinature: a framework designed for ESG requirements

  • Developed and supported by IRICE, an independent certification body, Effinature is the only biodiversity certification framework designed to meet ESG criteria in the real estate sector.
  • Defined in 4 operational frameworks (New Construction, Evolution, High Ecological Value, Horizon), it allows: rigorous evaluation, complete traceability, institutional compliance, readability for investors.
  • a rigorous evaluation,
  • complete traceability,
  • institutional compliance,
  • clarity for investors.
  • Each certified project can be integrated into a consolidated ESG report under article 8 or 9.

🟨 Conclusion: a decision that affects the entire chain

Biodiversity is no longer a mere environmental embellishment. It has become a key criterion for ESG compliance. Choosing a non-independent method, without a recognized framework, exposes an entire project – and sometimes an entire group – to regulatory and financial vulnerability.

Effinature is not an alternative. It is a foundation. Those who are seriously committed to biodiversity can no longer do without a certification framework.

Research