CSRD and climate
what ESRS E1 requires for real estate

The ESRS E1 — Climate change standard, published by EFRAG under the CSRD directive, structures climate reporting obligations into 9 disclosure requirements. For real estate companies, three points are particularly structuring: 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, a REIT or a social landlord, upstream scope 3 concentrates the bulk of the carbon footprint: materials, transport to site, energy consumption and waste production during the construction phase. These are precisely modules 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). Scope 3 is the grey area — and for real estate, the heaviest item.

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

The real estate project owner faces three regulatory frameworks requiring carbon data, each with its own scope and specific requirements. They overlap on one point: construction site emissions.

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

The Bilan d'Emissions de Gaz a Effet de Serre (BEGES — the French corporate carbon footprint) is mandatory for companies with more than 500 employees (250 in overseas territories) and local authorities with more than 50,000 inhabitants. Since the decree of 1 January 2023, scope 3 is included in the mandatory perimeter — which fundamentally changes the equation for developers and contractors.

For a property developer with 500+ employees, scope 3 category 1 (purchased goods and services — including construction services) typically represents 80 to 90% of the total carbon footprint. Completing it with average sector-level lump sums is accepted but fragile: statutory auditors and Cofrac-accredited independent third-party bodies increasingly expect primary data.

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

This trajectory implies a drastic reduction in construction emissions — not just operational emissions. RE2020 thresholds (Ic construction) are tightening progressively: the 2025 milestone is already in force, the 2028 milestone will be more stringent, and the 2031 milestone will mark a step change for developments that have not optimised their construction site footprint.

In this context, having an actual measurement of construction site emissions — not just a theoretical calculation — becomes a competitive advantage. Project owners who measure their sites with Efficarbone are building a carbon track record that documents their reduction trajectory year after year.

For real estate, the ESRS E1 (climate) and ESRS E4 (biodiversity) standards are not separate silos. They converge on the ground: a construction site emits carbon (E1) and disrupts ecosystems (E4). Reduction actions overlap — less transport, less waste, less land take — and reporting data feeds into each other.

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