European taxonomy
DNSH objective 6 — biodiversity
For a real estate activity to be aligned with the EU Taxonomy, it must not cause significant harm to biodiversity and ecosystems. This DNSH (Do No Significant Harm) test for Objective 6 requires a specific impact assessment.
The European Taxonomy Applied to Real Estate
The Taxonomy Regulation (EU 2020/852) defines the criteria for determining whether an economic activity is "green" according to European standards. For real estate, the activities covered include the construction of new buildings, renovation, acquisition, and asset management.
To be aligned with the Taxonomy, a real estate activity must meet three cumulative conditions :
- 1. Substantial contribution to at least one of the 6 environmental objectives (climate mitigation, adaptation, water, circular economy, pollution, biodiversity)
- 2. DNSH (Do No Significant Harm) — do not cause significant harm to any of the other 5 objectives
- 3. Minimum guarantees — compliance with international conventions (OECD, UN, ILO)
In practical terms, a building that contributes substantially to objective 1 (climate mitigation, via RE2020 for example) must also demonstrate that it does not cause significant harm to objective 6 (biodiversity). This is the DNSH biodiversity test.
The DNSH biodiversity test: specific requirements
Annex I of the Taxonomy Delegated Regulation details the DNSH criteria for Objective 6 applied to real estate activities. The main requirements are:
Environmental impact assessment
For projects subject to an environmental impact assessment (ICPE, ZAC, IEA thresholds), the mitigation measures identified in the EIA must be implemented. For projects not subject to an environmental impact assessment, a proportionate assessment of the biodiversity impact must be carried out.
Natura 2000 sites and protected areas
The project must not compromise the integrity of Natura 2000 sites or protected areas. If the site is located in or near such an area, an appropriate assessment must confirm the absence of harm.
ERC sequence
The activity must adhere to the mitigation hierarchy: Avoid first, Reduce second, Compensate as a last resort. Measures taken at each stage must be documented and proportionate to the identified impacts.
No conversion of high-value land
The activity must not lead to the conversion of lands with high biodiversity value (primary forests, wetlands, natural grasslands with high biodiversity) into lands of lower ecological value.
These criteria are formulated as negative conditions (“not to cause harm”), but demonstrating them requires positive data : documented baseline, tracked mitigation measures, and follow-up results. This is precisely the structure of the BPS.
How BPS Documents DNSH Testing
The BPS was not designed as a Taxonomy tool, but its three-phase structure structurally covers the requirements of the DNSH objective 6 test:
| DNSH Objective 6 Requirement | Corresponding BPS phase | Criteria used |
|---|---|---|
| Impact assessment | Initial State | Fauna/flora inventories, habitats, wetlands, ecological corridors |
| Natura 2000 areas | Initial State | Location, distance to listed sites, regulatory context |
| ERC sequence | Design | Avoidance measures, impact reduction, possible compensation |
| No land conversion | Initial State + Design | Soil characterization, land footprint, net artificialization |
| Monitoring and maintenance | Operation (coming soon) | Consistency between design and implementation, ecological management, maintenance |
The BPS attestation signed by IRICE constitutes documented evidence for the DNSH test. It does not replace a formal Taxonomy assessment (which is the responsibility of the company and its auditor), but it provides the factual and quantitative basis for constructing it.
Taxonomy alignment rates: the key issue for real estate funds
Real estate funds classified under SFDR Article 8 or 9 must publish their Taxonomy alignment rate —the proportion of their portfolio invested in aligned activities. To increase this rate, each asset must pass the DNSH test on the five non-targeted objectives, including biodiversity.
In practice, objective 6 (biodiversity) is often the weakest link : climate criteria (objective 1) are documented via the Energy Performance Diagnosis (DPE) or the RE2020 regulations, water criteria (objective 3) via flow meters, but biodiversity criteria lack standardized data. The Biodiversity Performance Score (BPS) fills this gap by providing a reproducible scoring system for each asset.
⚠️ Effinature Certification and Taxonomy
Frequently Asked Questions
Yes. Any real estate activity claiming Taxonomy alignment (regardless of the specific objective) must demonstrate that it does not cause significant harm to biodiversity (Objective 6). This is a necessary condition for alignment.
The regulatory EIA partially covers the DNSH Objective 6 requirements, but its findings are not always structured according to the criteria of the Taxonomy Delegated Regulation. The BPS provides a framework directly aligned with these criteria.
The DNSH verifies the absence of significant harm (minimum threshold). A substantial contribution to Target 6 requires active and measurable enhancement of biodiversity. The BPS documents the DNSH; Effinature certification can document a substantial contribution.
Taxonomy and carbon: Goal 1 too
Objective 6 (biodiversity) is just one of the six environmental objectives of the EU Taxonomy. Objective 1 (climate change mitigation) is most frequently cited for aligning real estate activities. Activity 7.1 (new building construction) requires a full LCA for buildings > 5,000 m², including modules A4-A5 (construction site emissions).
Efficarbone produces the EN 15978 measurement data necessary to demonstrate alignment with objective 1. ESRS E1 climate →
EU taxonomy: document biodiversity and carbon
BPS (DNSH objective 6, biodiversity) and Efficarbone (objective 1, LCA construction site): the two tools to demonstrate the alignment of your real estate assets.