Introduction: a growing gap between discourse and data

The 2025 studies published by ASPIM and OID reveal a paradoxical situation. ESG integration has become mandatory for real estate funds, but the actual measure of sustainability remains weak, heterogeneous, and sometimes difficult to compare. Real estate thus finds itself in a landscape where communication is progressing faster than technical evidence.

IRICE, as an independent third-party organization accredited to ISO/IEC 17065, examines here what the figures reveal: where the measurable reality lies, and what tools make it possible to secure the credibility of the actors.

1. SFDR: Massive ESG display, stable classifications

90% of outstanding real estate loans are now classified under Article 8 or 9.

But this apparent move upmarket masks an essential point: the dynamics are stabilizing.

• 22% of outstanding amounts are in Article 9 (sustainable investment objective).
• 35% in hybrid Article 8 (sustainable investment share in the portfolio).
• 33% in Article 8 simple.
• 10% remain Article 6.

The rapid growth of 2021–2023 gives way to a period of consolidation, where managers secure existing positions more than they create new ones.

2. Taxonomy: very weak alignment, despite the volume of funds committed

This is one of the most significant findings of both studies.

Average actual alignment with the Taxonomy (all funds combined):

• Market value: 3.7%
• CapEx: 8.8%
• Revenue: 3.2%
• OpEx: 2.1%

Pre-contractual commitments remain very weak:

• 1% in Article 8 hybrid
• 6% in Article 9

This gap between commitment and reality is not a failure: it reflects the operational complexity of Taxonomic alignment — strict technical criteria, data difficult to collect, heterogeneous perimeters.

For IRICE, this confirms that measurable sustainability cannot be limited to SFDR reporting, which is a tool for transparency, not a tool for performance.

3. Biodiversity: an increasing importance in ESG frameworks, but methodological heterogeneity

Biodiversity is among the three most frequently cited environmental themes in Article 8 (59%) and hybrid Article 8 (31%) funds.

But the methods vary greatly:

• vegetation cover rate, artificialization, CBS
• ecological studies,
• labels or certifications that are very different from one another,
• internal indicators not harmonized.

Studies reveal a key reality:

Biodiversity indicators are among the least comparable between funds.

This is where accredited third-party bodies play a vital role: providing a stable, verifiable and independent framework, as the market multiplies approaches.

4. Real estate SRI label: a transition towards a maturity cycle

Key data for 2025:

• 101 labeled funds, representing 55% of the general public market.
• 28 renewals in 2024: the market is moving from a phase of expansion to a phase of consolidation.
• 49 criteria on average in the grids, down compared to 2024 (54) — a sign of a desire for rationalization.
• 86% of funds use the Best-In-Progress strategy.

The decrease in the number of indicators for biodiversity, water, waste or certification is not a regression: it reflects a clarification of the frameworks to facilitate measurement, and to align the approaches with the expectations of SFDR / Taxonomy.

5. Negative Impacts (PI): widespread but little differentiation in reporting

• 94% of funds carry forward their exposure to fossil fuels — almost always zero.
• 84% report EPC ratings of C or lower, with an average of 74% of assets concerned.
• Data on greenhouse gas emissions and consumption are more difficult to aggregate, especially outside the EU.

Studies highlight a low overall comparability of PAIs → a major issue for investors.

6. Impact finance: stricter requirements, very few funds actually eligible

The study identifies:

• Only 12 impact funds,
• including 10 classified under Article 9,
• representing 4.25 billion euros.

The impact criteria are demanding:

• intentionality,
• additionality,
• measurability,
• zero harm,
• independent monitoring.

The new IFD grid requires:

• 32 questions,
• 13 mandatory qualifying questions,
• a progressive minimum score (60/100 in 2025 → 70/100 in 2027).

This framework reinforces a central observation:

The impact requires an independent, rigorous, evidence-based assessment and cannot be reduced to the SFDR classification.

7. What this data implies for market credibility

The two documents converge on three major points:

A. The rise in maturity

The market is better integrating transparency obligations, SRI frameworks, and ESG data collection.

B. The technical evidence remains insufficient.

Taxonomy, biodiversity, negative impacts: methodological variability makes comparison difficult.

C. Actors seek stable and independent reference points

The study highlights the importance of third-party organizations (auditors, certifiers, external evaluators) to secure the processes and limit "regulatory noise".

This is exactly where IRICE fits in the ecosystem: an independent, accredited, evidence-based and method-driven assessment that distinguishes real performance from communication.

Conclusion: Towards a market where proof will make the difference

The real estate sector is going through a period of normalization:

• increased demands for transparency,
• consolidated SRI strategies,
• more structured indicators,
• fundraising Article 9,
• emergence of impact funds.

But the credibility of the market now depends on a single point: the ability of the players to produce verifiable, comparable and auditable evidence.

That is precisely the function of IRICE:

• to ensure the quality of the methods,
• stabilize the measurement,
• to secure investor confidence,
• to avoid the dilution of ESG indicators,
• and ensure that sustainability is based on facts, not intentions.