Any company subject to the CSRD whose activity involves land—development, construction, land use—must consider the issue of biodiversity materiality. Here is the method to assess your eligibility for the ESRS E4 requirements.
Who is affected by the CSRD's biodiversity criteria?
The Corporate Sustainability Reporting Directive (CSRD) requires companies with more than 250 employees, listed companies, and eventually listed SMEs, to publish sustainability reports compliant with ESRS standards. Among these standards, ESRS E4 – Biodiversity and Ecosystems requires precise data on the company's impact on and dependence on living organisms.
The question isn't "Am I subject to the CSRD?" — that's often decided by size thresholds. The real question is: Does biodiversity emerge as a material issue in my dual materiality analysis?
For those involved in the real estate sector, the answer is almost always yes. Soil sealing, habitat fragmentation, impermeability, and stormwater management are all direct impacts documented by the scientific community.
Dual materiality: a mandatory entry point
Dual materiality analysis determines which ESRS standards are relevant to your organization. Two aspects:
Impact materiality : does your activity modify the state of biodiversity on your sites or in your value chain? For a developer building on agricultural land or brownfield land, the answer is documented even before the analysis.
Financial materiality : does the degradation of biodiversity create a financial risk for your business? Permit delays related to a protected species, ZAN litigation, devaluation of assets in coastal retreat zones — precedents exist.
If either axis is positive, ESRS E4 applies. In real estate, both axes are usually positive simultaneously.
Three questions to assess your eligibility
1. Does your company meet the CSRD thresholds?
The current thresholds are: more than 250 employees, or revenue exceeding €50 million, or total assets exceeding €25 million (two out of three criteria). Listed SMEs will be included in the scope from 2028. Subsidiaries of European groups are included through consolidation.
If you are below these thresholds, you are not directly subject to the regulations. However, you may be indirectly : your clients subject to the CSRD (Consumer Reporting Standard) will need your data to consolidate their own reporting. This is frequently the case for PropTech startups, engineering firms, and construction subcontractors.
2. Does your business have any connection with the soil or land?
Real estate development, construction, planning, operation of real estate portfolios, rental management of land holdings, transport infrastructure: any activity that transforms or occupies land has a direct link with biodiversity. Net land take is the first indicator required by ESRS E4.
3. Do you have the data to answer data points E4-4 and E4-5?
Quantitative E4 data points require precise metrics: artificial surfaces, restored natural surfaces, and ecological status indicators for each site. If you do not currently have this data, you must structure its collection before the first reporting exercise.
The specific case of start-ups and unlisted SMEs
Start-ups are not directly subject to the CSRD. They become indirectly subject to it when their clients — listed real estate companies, national developers, investors subject to Article 29 LEC or the SFDR — require biodiversity data that can be consolidated into their own ESRS E4 reporting.
In practical terms, a start-up that provides services to a promoter subject to the CSRD may be asked to:
— Indicators of biodiversity impact on the construction sites where it is involved.
— Proof of compliance with the DNSH (Do No Significant Harm) criteria of the European Taxonomy , objective 6.
— Data compatible with the PAI (Principal Adverse Impact) of the SFDR regulation.
Anticipating these demands by structuring the data now is a measurable competitive advantage: tenders are increasingly incorporating these criteria into technical scoring.
From diagnosis to certified data: the role of the BPS
The Biodiversity Performance Score (BPS) was designed to address this need for structuring. By evaluating more than 75 criteria per property asset, the BPS produces scores that can be directly used in ESRS E4-4 and E4-5 data points.
The BPS is not a CSRD report. It's the upstream stage: it provides the raw quantitative data that the reporting requires. The difference is the same as between a balance sheet and an audit of accounts—the former produces the figures, the latter certifies them.
For new construction or renovation projects, Effinature goes further: it attests, through a third-party assessment accredited by Cofrac (no. 5-0655), that the biodiversity measures implemented on a project meet a documented technical standard. This accredited certification constitutes the most robust evidence available for use in a CSRD report.
Construction carbon: an ESRS E1 supplement
Biodiversity is not the only material issue for real estate. Greenhouse gas emissions related to construction fall under ESRS E1 — Climate Change . The Efficarbone allows for measuring the construction site's carbon footprint (Ic construction) with a precision that the RE2020 standard values do not achieve.
Combining E1 and E4 in a single report provides a coherent view of the environmental performance of a real estate project. Both datasets are produced within the same scope—the project—and over the same timeframe—the construction lifecycle.
Summary grid: your eligibility profile
| Criteria | Result | Consequence |
|---|---|---|
| CSRD thresholds reached | Yes | Mandatory ESRS reporting — verify E4 materiality |
| CSRD thresholds reached | No, but subservient clients | Biodiversity data required by value chain |
| Land-related activity | Yes | Materiality E4 almost certain — structuring the collection |
| E4-4/E4-5 data available | No | BPS diagnosis recommended before the first report |
| Biodiversity certification in place | No | Effinature Certification = proof of accredited third party |
Next steps
If your company is affected — directly or through its value chain — here are three concrete actions:
1. Carry out the dual materiality analysis on the biodiversity aspect, identifying the impacts and dependencies by site.
2. Structure data collection with a BPS diagnostic on a pilot site, to calibrate the process before deployment to the entire portfolio.
3. Obtain accredited certification for the most exposed operations, in order to have third-party proof that meets the expectations of auditors and investors.
IRICE
Independent certification body — Cofrac accreditation no. 5-0655
IRICE is accredited by Cofrac (n°5-0655) for the certification of products, processes and services according to the ISO/IEC 17065 standard. Scope available on www.cofrac.fr .