CSRD and climate
: what ESRS E1 requires for real estate

The ESRS E1 standard – Climate Change , published by EFRAG within the framework of the CSRD directive, structures climate reporting obligations into 9 disclosure requirements. For companies in the real estate sector, three points are particularly crucial: the complete GHG inventory (scopes 1, 2, 3), the climate transition plan, and reduction targets aligned with a 1.5°C trajectory.

For a developer, property company, or landlord, upstream scope 3 encompasses the bulk of the carbon footprint: materials, transport to the construction site, energy consumption, and waste production during the construction phase. These are precisely categories A4 and A5 of the EN 15978 standard — those measured by Efficarbone .

Most real estate companies already report their scope 1 (vehicles, office heating) and scope 2 (purchased electricity) expenses. Scope 3 is the grey area—and for real estate, the biggest expense.

Efficarbone fills this gap by measuring actual site emissions — energy consumed on site, transport of materials and personnel, production and treatment of waste — according to the EN 15978 methodology. The results feed directly into datapoint E1-6 (gross GHG emissions, upstream scope 3).

The property owner faces three regulatory frameworks that require carbon data, each with its own scope and requirements. They overlap on one point: construction site emissions.

An Efficarbone measurement on a construction site produces usable data in all four frameworks simultaneously. This is the principle of a single measurement with multiple applications : a field data collection campaign feeds into RE2020 compliance, BEGES scope 3, ESRS E1 reporting, and the Taxonomy alignment test.

The Greenhouse Gas Emissions Assessment (BEGES) is mandatory for companies with more than 500 employees (250 in the French overseas departments and territories) and local authorities with more than 50,000 inhabitants. Since the decree of January 1, 2023, Scope 3 are included in the mandatory scope — which radically changes the situation for developers and builders.

For a property developer with 500+ employees, Scope 3 Category 1 (purchases of goods and services — including construction services) typically represents 80 to 90% of the total carbon footprint . Reporting this using average sector-specific figures is acceptable but unreliable: auditors and Cofrac-accredited organizations increasingly expect primary data.

The National Low-Carbon Strategy (SNBC) sets sectoral carbon budgets to achieve carbon neutrality by 2050. SNBC3, currently being finalized, provides for a 49% reduction in emissions for the building sector by 2030 compared to 2015, and near-neutrality by 2050.

This trajectory implies a drastic reduction in construction emissions — not just operational ones. The RE2020 thresholds (construction footprint) are becoming progressively stricter: the 2025 level is already in effect, the 2028 level will be more stringent, and the 2031 level will mark a turning point for projects that have not optimized their construction footprint.

In this context, having a real-time measurement of construction site emissions—and not just a theoretical calculation—becomes a competitive advantage. Project owners who measure their construction sites with Efficarbone build a carbon history database that documents their reduction trajectory year after year.

ESRS E4 (biodiversity) standards are not separate entities. They converge in practice: a construction site emits carbon (E1) and disrupts ecosystems (E4). Reduction measures overlap—less transport, less waste, less land development—and reporting data is mutually reinforcing.

IRICE is the only organization to simultaneously cover both environmental aspects of real estate reporting: construction carbon (Efficarbone) and biodiversity (Effinature / BPS). This dual coverage allows companies to structure a consistent CSRD report, using data from a single independent third party.