ACT Biodiversity provides a solid framework for assessing biodiversity strategy. But it does not measure the actual state of nature — it expects it as an input. Why that field data must be measured and certified independently, and how this building block connects with ACT.
The ACT Biodiversity methodology (ADEME-OFB) gives companies a solid framework to assess their biodiversity strategy. But a careful reading of the methodology and its roadtest reveals an often-overlooked condition: ACT Biodiversity does not measure the actual state of nature. It expects it as an input. This article explains why that field data, to be credible, must be measured and certified independently — and how this building block connects with ACT.
Key takeaways
- ACT Biodiversity assesses a company's strategy, not the state of nature: the latter is an input to be produced upstream.
- The roadtest confirmed that public CSRD data is not enough and that the upstream chain remains a "blind spot" (19 %).
- The methodology recognises third-party certification itself: its indicator 4.2 weights certified responsible sourcing at 20 % (FSC, PEFC, ISCC, RSB).
- Only certification accredited to ISO/IEC 17065 delivers data that is at once impartial, technically controlled and comparable.
- IRICE (Cofrac no. 5-0655) certifies this field data through Effinature, upstream of ACT — a complementary, never competing, position.
What ACT Biodiversity assesses — and what it does not
ACT Biodiversity is a strategy-assessment methodology: commitments, targets, governance, practices, business model. The roadtest report puts it unambiguously: the methodology "does not assess the state of nature itself" (page 5), which "must be analyzed by companies prior to the ACT assessment".
This boundary is structuring. ACT answers the question: "What is the company doing, and is it commensurate with the stakes?" It does not answer: "What is the actual state of biodiversity on this site, in this value chain, and how is it evolving?" That second question belongs to field measurement — a prerequisite, not a deliverable of the assessment. An ambitious strategy backed by approximate state data remains fragile.
The roadtest confirmed it: data is the breaking point
The first roadtest results converge on the same diagnosis. The weakest module is upstream (19 % average score), described as a "critical blind spot"; and above all, the report concludes that "even for companies publishing a CSRD-compliant report, public data was not sufficient" to carry out the assessment. Most assessments had to rely on private data shared under NDA.
Analysts also judged data collection for module 4 to be "very difficult", and recommended, going forward, relying on suppliers' environmental certifications as a pragmatic lever for engagement and selection. The message is clear: reliable, traceable, third-party-verified data is the missing link.
The methodology already recognises third-party certification
This is not an interpretation: the ACT Biodiversity v1 methodology explicitly builds third-party certification into its scoring. Within indicator 4.2 (responsible sourcing), the "Responsible Sourcing of Renewable Materials" criterion is weighted at 20 %, and the methodology names the certification schemes ("Certification schemes (FSC, PEFC, ISCC, RSB, etc.)") as a means of reducing the risks of over-harvesting, illegal sourcing or unsustainable management.
In other words, ACT Biodiversity values the evidence provided by an independent third party. This is the very logic of accredited certification: a trusted third party, whose impartiality and competence are themselves controlled, attests to the reality of a performance.
Why independence and accreditation change everything
Biodiversity data can be produced in three ways: declared by the company, verified by a service provider, or certified by an accredited body. Only the last delivers a defensible guarantee:
- Structural impartiality: the certification body has no stake in the outcome. Its neutrality is a normative obligation, not a stance.
- Controlled competence: Cofrac accreditation, to the ISO/IEC 17065 standard, periodically verifies technical competence, decision consistency and the traceability of evidence.
- Comparability: data certified against a public standard is comparable from one site to another, from one year to the next — an indispensable condition to measure a "nature-positive" trajectory.
That is exactly what an ACT assessment, an ESRS E4 report or an SFDR investor is looking for: not a figure, but a figure whose reliability is guaranteed by a third party whose competence is itself attested. We develop this doctrine in our page on Independence, accreditation, evidence.
The place of IRICE and Effinature in this chain
IRICE is an independent certification body, accredited by Cofrac under no. 5-0655 to ISO/IEC 17065 (scope available at www.cofrac.fr). Its Effinature certification covers precisely the building block ACT Biodiversity expects as an input: the measurement of the state and biodiversity performance of a site or project, based on a public standard and a third-party field audit.
The positioning is complementary, not competing. IRICE does not apply the ACT Biodiversity methodology and does not audit ACT assessments. IRICE operates upstream: producing the certified field data — ecological state, management practices, development performance — that the company can then use to feed an ACT assessment, CSRD/ESRS E4 reporting or a public-procurement requirement. Without this foundation, both assessment and reporting rest on self-declaration.
In summary
The first ACT Biodiversity roadtest sends companies a clear signal: maturity will not be decided on assessment frameworks — they exist and are improving — but on the quality, traceability and independence of the data feeding them. ACT acknowledges this itself by valuing third-party certification in its scoring. The companies that pull ahead will be those investing now in certified field measurement — the kind that turns an ecological finding into defensible data.
Make your biodiversity data evidence, not a declaration. IRICE certifies the biodiversity performance of your sites and projects through the Effinature standard, under Cofrac ISO/IEC 17065 accreditation. Reliable, traceable field data, ready to feed your assessments and reporting. Talk to an IRICE expert.
Sources: ACT Biodiversity methodology v1 (ADEME-OFB, June 2026), indicator 4.2; ACT Biodiversity roadtest report (EVEA for ADEME and the OFB, January 2026).
Frequently asked questions
No. ACT Biodiversity assesses a company's strategy, whereas an accredited certification measures and attests the actual state of biodiversity on the ground. The two approaches are complementary: certification produces the input data ACT assumes is already available.
Yes. Within indicator 4.2, the methodology weights responsible sourcing of renewable materials at 20 % and explicitly names the certification schemes FSC, PEFC, ISCC and RSB as a way to reduce biodiversity risks.
Because it guarantees three things declared data does not: the structural impartiality of the body, its technical competence periodically controlled by Cofrac, and the comparability of data from one site and one year to the next.
No. IRICE does not apply ACT Biodiversity and does not audit ACT assessments. IRICE operates upstream, certifying the field data through the Effinature standard, under Cofrac accreditation no. 5-0655.
Président, IRICE Certification
Cofrac Accreditation No. 5-0655, Product, Process and Service Certification, scope available at www.cofrac.fr.