CSRD and biodiversity
: what ESRS E4 actually requires
The ESRS E4 standard requires companies to document their impacts on and dependencies on biodiversity using quantitative, auditable, and traceable data. Understanding these requirements is the first step to meeting them effectively.
What the CSRD changes for biodiversity
The Corporate Sustainability Reporting Directive (CSRD) does not simply ask companies to "talk about biodiversity." The ESRS E4 standard – Biodiversity and Ecosystems , published by EFRAG, structures this obligation into specific requirements: objectives, transition plans, quantified indicators, value chain, and dedicated governance.
The Content Directive, which came into force on March 18, 2026 , confirmed the post-Omnibus scope: companies with more than 1,000 employees or €450 million in revenue. EFRAG reduced the total number of data points by 61%, but ESRS E4 remains one of the most demanding standards in terms of expected factual data.
The 5 ESRS E4 Disclosure Requirements
- E4-1 Biodiversity Transition Plan — objectives, trajectory, financial resources, governance. Alignment with the TNFD/LEAP framework recommended.
- E4-2 Biodiversity policies — formalized commitments, scope of application (own operations + value chain), integration into governance.
- E4-3 Actions and resources — concrete measures implemented, timetable, budget allocated, expected and achieved results.
- E4-4 Impact indicators — quantitative data on negative impacts: soil sealing, disturbance of species, habitat degradation. Mandatory numerical data points.
- E4-5 Dependency indicators — quantification of ecosystem services on which the company depends: pollination, water regulation, soil fertility, local climate regulation.
The E4-4 and E4-5 requirements are the most significant for the real estate sector: they mandate quantitative data per site , not overall qualitative statements. This is precisely what the BPS (Biodiversity Performance Score) provides: a quantified score, asset by asset, auditable line by line.
Who is affected, and when?
The scope of the CSRD (Consumer Security and Disaster Reduction) has evolved with the Omnibus proposal of February 2025 and the Content Directive of March 2026. Here is the consolidated timetable for real estate stakeholders:
| Category | Thresholds | Exercise | Publication |
|---|---|---|---|
| Large listed companies | > 500 employees (former NFRD scope) | 2024 | 2025 |
| Large unlisted companies | > 1,000 employees or > €450M turnover (post-Omnibus) | 2025 | 2026 |
| Listed SMEs | Listed on a regulated market, subject to conditions | 2026 | 2027 |
| Real Estate Investment Trusts / REITs | Listed, generally > NFRD thresholds | 2024 | 2025 |
| Asset management companies (SFDR) | > €500 million outstanding (Art. 29 LEC) | Already applicable | Annual |
Critical point : even if a company does not fall directly under the scope of the CSRD ( the Social and Solidarity Economy), its clients and investors are . A privately held developer with 200 employees is not subject to the CSRD, but if its institutional investors (listed real estate companies, SFDR 8/9 funds) request biodiversity data for each asset to support their own reporting, the trickle-down effect is immediate.
The problem of biodiversity data
Unlike carbon (where the tonne of CO₂ is a standardized and universal indicator), biodiversity does not have a single, universally accepted indicator. This is what makes ESRS E4 so difficult to populate with existing tools:
That is not enough
- Qualitative statements (“we are committed to biodiversity”)
- Macroeconomic indicators not linked to an asset (MSA portfolio, GBS enterprise)
- Regulatory impact studies (focused on legal risk, not performance)
- Multi-criteria labels where biodiversity is one aspect among 10 (HQE, BREEAM)
- Proprietary data not auditable by a third party (internal spreadsheets)
What ESRS E4 requires
- Quantitative data associated with each site/asset
- Reproducible indicators (same methodology from one exercise to another)
- Results auditable by an independent third-party organization (ITO).
- Coverage of impacts (E4-4) and dependencies (E4-5)
- Traceability of the method, sources and assumptions
This is exactly the gap that the BPS (Biodiversity Performance Score) : a scoring structured in 70+ criteria, applied asset by asset, with quantified results, a documented methodology and an individual certificate signed by IRICE — an organization accredited by Cofrac according to the ISO/IEC 17065 standard.
BPS and CSRD — direct complementarity
Dual materiality: what this means in concrete terms
The CSRD is based on the principle of double materiality : a company must report not only its impacts on biodiversity (impact materiality), but also the risks and opportunities that biodiversity poses to the company (financial materiality).
Materiality of impact
How does my activity affect biodiversity?
- Soil artificialization
- Habitat fragmentation
- Light pollution, noise pollution
- Consumption of natural resources
Financial materiality
How does biodiversity affect the viability of my business?
- Risk of flooding (loss of wetlands)
- Urban heat island (loss of vegetation)
- Asset depreciation (proximity to Natura 2000 sites)
- Regulatory restriction (ZAN, water law)
For real estate, this dual reading is particularly structuring: each operation is both a generator of impact (artificialization, disruption) and a receiver of risks (dependence on ecosystem services for the long-term viability of the asset).
Read the full analysis of the dual materiality of biodiversity →
CSRD, SFDR, Taxonomy: an interconnected framework
ESRS E4 does not operate in isolation. It is part of a three-part European regulatory framework where each component relates to the others:
ESRS E1 — climate
The carbon component of CSRD reporting. Efficarbone produces scope 3 site data.
SFDR
PAI biodiversity and climate for article 8 and 9 funds. BPS and Efficarbone per asset.
EU Taxonomy
Objectives 1 (climate) and 6 (biodiversity). DNSH tests and alignment data.
Datapoints E4
E4-4 and E4-5 numerical indicators: details of the data points and how to produce them.
This interconnection means that a real estate investor subject to SFDR and a developer subject to CSRD need the same basic data : a quantitative, reproducible, and auditable biodiversity score per asset. The BPS was designed to meet this dual requirement in a single tool.
TNFD and LEAP approach: convergence with ESRS E4
The Taskforce on Nature-related Financial Disclosures (TNFD) published its recommendations in September 2023, with a structured four-step approach— LEAP: Locate, Evaluate, Assess, Prepare . EFRAG confirmed the convergence between TNFD/LEAP and ESRS E4, meaning that a company applying LEAP produces work that is directly valuable in its CSRD reporting.
The 4 LEAP steps
- Locate interfaces with nature — identify sites, biomes, sensitive areas (Natura 2000, wetlands, ZNIEFF). The BPS integrates this step into its Initial State phase.
- Evaluate dependencies and impacts — what ecosystem services does the activity consume, what pressures does it exert? Covered by the BPS dependency criteria.
- Assess material risks and opportunities — translating impacts and dependencies into financial risks. BPS results enable this asset-by-asset translation.
- Prepare the response — objectives, strategy, monitoring indicators, governance. The E4-1 transition plan builds on the data produced in the previous steps.
The Business Planning System (BPS) structurally covers the first two steps (Locate and Evaluate) and provides the quantitative data needed for the third (Assess). The company remains responsible for the fourth step (Prepare) — strategy and governance — but it now has factual data to build it.
Towards reasonable insurance: anticipating 2028
The CSRD anticipates an increase in the level of assurance required for non-financial reporting data. Currently at limited assurance (moderate confidence level), the transition to reasonable assurance (a level equivalent to a financial audit) is planned from 2028.
This change fundamentally alters the nature of the expected data: Independent Third-Party Organizations (ITOs) accredited by Cofrac must be able to verify, recalculate, and confirm each declared data point. Qualitative data or undocumented self-assessments will not withstand this level of scrutiny.
Why the BPS is designed for reasonable insurance
- Complete traceability — each criterion is documented: data source, calculation method, assumptions used
- Reproducibility — an independent auditor can reproduce the scoring by following the same methodology
- Signed certificate — IRICE, an ISO/IEC 17065 accredited body, signs the BPS certificate with its accreditation number
- Separation of roles — IRICE is neither the consultant, nor the design office, nor the project designer: independence is structural
Companies that feed their CSRD reporting with BPS data today are building an auditable historical base : when reasonable assurance is required, data from previous periods will already be at the right level of quality.
Frequently Asked Questions
No. ESRS E4 only applies to companies for which biodiversity is a material issue after a dual materiality analysis. For real estate, soil sealing almost always makes E4 a material issue, but the analysis remains mandatory.
The EU Taxonomy classifies activities as aligned or non-aligned (DNSH binary test objective 6). ESRS E4 requires continuous narrative and quantitative reporting on impacts, dependencies, risks, and opportunities related to biodiversity. The two frameworks are complementary.
No. The BPS provides the quantitative data per asset (scores, impact metrics) that feed into the E4-4 and E4-5 data points required by the standard. ESRS E4 reporting remains the responsibility of the company and its auditor.
E4 data points require precise ecological data (inventories, habitat areas, species). The BPS integrates these assessments carried out by qualified ecologists. Without a structured tool, the company must commission these assessments separately.
Further develop biodiversity reporting
SFDR and biodiversity
PAI, articles 8 and 9 for real estate funds.
Learn more →EU Taxonomy — DNSH
Test DNSH objective 6 for Taxonomy alignment.
Learn more →Dual materiality
Materiality of impact and financial impact applied to biodiversity.
Learn more →ESRS E1 — climate
The carbon construction component of the CSRD reporting.
Learn more →Your biodiversity CSRD reporting starts here
The BPS produces the quantitative data points expected by ESRS E4. Numerical scoring, asset by asset, auditable by Cofrac OTIs.