CSRD and biodiversity
what ESRS E4 actually requires
The ESRS E4 standard requires companies to document their impacts on and dependencies on biodiversity with quantitative, auditable and traceable data. Understanding these requirements is the first step towards meeting them without improvisation.
What the CSRD changes for biodiversity
The CSRD (Corporate Sustainability Reporting Directive) does not merely ask companies to "talk about biodiversity". The ESRS E4 — Biodiversity and ecosystems standard, published by EFRAG, structures this obligation into precise requirements: targets, transition plans, quantitative indicators, value chain coverage and dedicated governance.
The Content Directive, which entered into force on 18 March 2026, confirmed the post-Omnibus scope: companies with more than 1,000 employees or EUR 450 million in turnover. EFRAG reduced the total number of datapoints by 61%, yet ESRS E4 remains one of the most demanding standards in terms of factual data expected.
The 5 disclosure requirements of ESRS E4
- E4-1 Biodiversity transition plan — targets, trajectory, financial resources, governance. Recommended alignment with the TNFD / LEAP framework.
- E4-2 Biodiversity policies — formalised commitments, scope of application (own operations + value chain), integration into governance.
- E4-3 Actions and resources — concrete measures implemented, timeline, allocated budget, expected and achieved results.
- E4-4 Impact indicators — quantitative data on negative impacts: land take, species disturbance, habitat degradation. Mandatory quantitative datapoints.
- E4-5 Dependency indicators — quantification of ecosystem services on which the company depends: pollination, water regulation, soil fertility, local climate regulation.
Requirements E4-4 and E4-5 are the most structuring for real estate: they require quantitative data per site, not global qualitative statements. This is precisely what the BPS (Biodiversity Performance Score) produces: a quantified scoring, asset by asset, auditable line by line.
Who is affected, and when
The CSRD scope has evolved with the Omnibus proposal of February 2025 and the Content Directive of March 2026. Here is the consolidated timeline for real estate stakeholders:
| Category | Thresholds | Financial year | Publication |
|---|---|---|---|
| Large listed companies | > 500 employees (former NFRD scope) | 2024 | 2025 |
| Large unlisted companies | > 1,000 employees or > EUR 450m turnover (post-Omnibus) | 2025 | 2026 |
| Listed SMEs | Listed on regulated market, subject to conditions | 2026 | 2027 |
| REITs / Listed property companies | Listed, generally above NFRD thresholds | 2024 | 2025 |
| Asset managers (SFDR) | > EUR 500m AUM (Art. 29 LEC) | Already applicable | Annual |
Critical point: even if a company does not fall directly within the CSRD scope, its clients and investors do. An unlisted developer with 200 employees is not subject to the CSRD, but if its institutional investors (listed REITs, SFDR 8/9 funds) demand asset-by-asset biodiversity data to feed their own reporting, the trickle-down effect is immediate.
The biodiversity data problem
Unlike carbon (where the tonne of CO2 is a standardised and universal indicator), biodiversity does not have a single consensus indicator. This is what makes ESRS E4 so difficult to complete with existing tools:
What is not sufficient
- Qualitative statements ("we are committed to biodiversity")
- Macro indicators not linked to an asset (portfolio MSA, company-level GBS)
- Regulatory impact assessments (focused on legal risk, not performance)
- Multi-criteria labels where biodiversity is one topic among 10 (HQE, BREEAM)
- Proprietary data not auditable by a third party (internal spreadsheets)
What ESRS E4 requires
- Quantitative data linked to each site/asset
- Reproducible indicators (same methodology from one year to the next)
- Results auditable by an independent third-party body
- Coverage of impacts (E4-4) and dependencies (E4-5)
- Traceability of methodology, sources and assumptions
This is exactly the gap that the BPS (Biodiversity Performance Score) fills: a structured scoring based on 75+ criteria, applied asset by asset, with quantified results, a documented methodology and an individual attestation signed by IRICE — a Cofrac-accredited body under the ISO/IEC 17065 standard.
BPS and CSRD — direct complementarity
Double materiality: what it means in practice
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 for the company (financial materiality).
Impact materiality
How does my activity affect biodiversity?
- Land take
- Habitat fragmentation
- Light and noise pollution
- Consumption of natural resources
Financial materiality
How does biodiversity affect the viability of my activity?
- Flood risk (loss of wetlands)
- Urban heat island (loss of green cover)
- Asset depreciation (proximity to Natura 2000)
- Regulatory restriction (ZAN, water legislation)
For real estate, this dual perspective is particularly structuring: each development is both a generator of impact (land take, disturbance) and a recipient of risk (dependency on ecosystem services for the long-term viability of the asset).
CSRD, SFDR, Taxonomy: an interconnected framework
ESRS E4 does not operate in isolation. It sits within a European regulatory triptych where each piece refers to the others:
ESRS E1 — climate
The carbon component of CSRD reporting. Efficarbone produces scope 3 construction site data.
SFDR
Biodiversity and climate PAIs for article 8 and 9 funds. BPS and Efficarbone per asset.
EU Taxonomy
Objectives 1 (climate) and 6 (biodiversity). DNSH tests and alignment data.
E4 Datapoints
Quantitative indicators E4-4 and E4-5: datapoint detail 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 baseline data: a biodiversity score per asset, quantitative, reproducible and auditable. The BPS has been designed to meet this dual demand in a single tool.
TNFD and the LEAP approach: convergence with ESRS E4
The Taskforce on Nature-related Financial Disclosures (TNFD) published its recommendations in September 2023, with a structured approach in four steps — LEAP: Locate, Evaluate, Assess, Prepare. EFRAG has confirmed the convergence between TNFD/LEAP and ESRS E4, meaning that a company applying LEAP produces work directly usable in its CSRD reporting.
The 4 LEAP steps
- Locate Locate the interfaces with nature — identify sites, biomes, sensitive areas (Natura 2000, wetlands, ZNIEFF). The BPS integrates this step in its Baseline Assessment phase.
- Evaluate Evaluate dependencies and impacts — which ecosystem services the activity consumes, which pressures it exerts. Covered by the BPS dependency criteria.
- Assess Assess material risks and opportunities — translate impacts and dependencies into financial risks. BPS results enable this translation asset by asset.
- Prepare Prepare the response — targets, strategy, monitoring indicators, governance. The E4-1 transition plan builds on data produced in the preceding steps.
The 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 then has factual data on which to build it.
Towards reasonable assurance: anticipating 2028
The CSRD provides for a progressive increase in the level of assurance required on non-financial reporting data. Currently at limited assurance (moderate confidence level), the transition to reasonable assurance (a level equivalent to financial audit) is planned from 2028.
This transition fundamentally changes the nature of expected data: Cofrac-accredited independent third-party bodies will need to be able to verify, recalculate and confirm every declared datapoint. Qualitative data or undocumented self-assessments will not withstand this level of scrutiny.
Why the BPS is designed for reasonable assurance
- Full traceability — every criterion is documented: data source, calculation method, assumptions retained
- Reproducibility — an independent auditor can reproduce the scoring by following the same methodology
- Signed attestation — IRICE, a body accredited under ISO/IEC 17065, signs the BPS attestation with its accreditation number
- Separation of roles — IRICE is neither the consultant, nor the engineering office, nor the project designer: independence is structural
Companies that feed their CSRD reporting with BPS data from today are building an auditable track record: when reasonable assurance is required, data from previous financial years will already be at the right quality level.
Frequently asked questions
No. ESRS E4 only applies to companies for which biodiversity is a material issue after a double materiality analysis. In real estate, land take almost systematically makes E4 material, but the analysis remains mandatory.
The EU Taxonomy classifies activities as aligned or not (binary DNSH test on 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 quantitative data per asset (scores, impact metrics) that feed the E4-4 and E4-5 datapoints required by the standard. ESRS E4 reporting remains the responsibility of the company and its auditor.
E4 datapoints 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 studies separately.
Explore biodiversity reporting further
SFDR and biodiversity
PAIs, articles 8 and 9 for real estate funds.
En savoir plus →EU Taxonomy — DNSH
DNSH test on objective 6 for Taxonomy alignment.
En savoir plus →Double materiality
Impact and financial materiality applied to biodiversity.
En savoir plus →ESRS E1 — climate
The construction carbon component of CSRD reporting.
En savoir plus →Your CSRD biodiversity reporting starts here
The BPS produces the quantitative datapoints expected by ESRS E4. Quantified scoring, asset by asset, auditable by Cofrac-accredited independent third-party bodies.