Label, assessment
or accredited certification
Only Level 3 — accredited certification — produces enforceable evidence compliant with Directive 2024/825
Three levels, only one enforceable evidence
The real estate biodiversity market offers labels, assessments and certifications. These terms are not interchangeable. The European regulatory framework — Directive 2024/825 (transposition 27 September 2026), CSRD ESRS E4, SFDR — creates distinct legal categories that determine the evidential value of each approach.
The outcome is unambiguous: only certification issued by a body accredited by a national authority (Cofrac in France) produces enforceable evidence in the regulatory sense. The other two levels have their uses, but they do not constitute evidence.
The three levels of approaches
Voluntary and self-declarative approaches
Labels, charters, commitments
Definition
Approaches based on commitment and self-assessment without independent external verification.
Characteristics
- • Criteria defined by the label or charter owner
- • No independent verification or limited self-verification
- • No accreditation by a state body
- • Roles conflated: creator = assessor = communicator
Examples
- • Internal CSR commitments
- • Biodiversity logos used without external assessment
- • Partner charters
Value
- • Internal mobilisation
- • Awareness raising
- • Design flexibility
Limitations
- • Not enforceable in a legal context
- • No comparability between initiatives
- • Vulnerable to greenwashing accusations
- • Cannot be used for CSRD/SFDR compliance
Cofrac accreditation
NO
Enforceability
NO
CSRD/SFDR compatible
NO
Non-accredited external assessments
Assessment schemes and ratings
Definition
Approaches with external assessment by a third party, but without accreditation by a national authority.
Characteristics
- • External assessor publishing a methodology
- • No accreditation by a state body
- • Risk of role confusion (assessor may also advise)
- • No ISO 17065 compliance
- • Methodology may evolve without governance
Examples
- • Biodiversity labels assessed by a non-accredited third party for that scope
- • Environmental assessment tools without accreditation
- • Sustainability ratings without certification
Value
- • Structured analysis
- • Quantified results
- • Relative comparison
- • Public documentation of methodology
Limitations
- • Not enforceable in a regulatory or legal context
- • Assessor independence not guaranteed by state oversight
- • Methodology not subject to public governance
- • Does not produce certification within the meaning of ISO 17065
- • Variable acceptability in CSRD/SFDR context
Cofrac accreditation
NO
Enforceability
NO
CSRD/SFDR compatible
PARTIAL
Accredited certification by an independent body
The IRICE model
Definition
Certification produced by a body accredited by a national authority, compliant with ISO 17065 and public standards.
Characteristics
- • Body accredited by the national authority (Cofrac in France)
- • ISO 17065 compliance (independent third party)
- • Separation of functions: assessment ≠ design ≠ marketing
- • Public and enduring standards
- • Published results
- • Complaints and appeals mechanism
- • State oversight
Examples
- • Effinature (IRICE)
- • BREEAM certifications (performance certification)
- • Other accredited certifications
Value
- • Full enforceability
- • Comparability between projects
- • Evidence in the regulatory sense
- • Durability and stability
- • Protection against greenwashing accusations
- • Full acceptability in CSRD/SFDR/DNSH context
- • Standard transparency
Limitations
- • Relative rigidity of criteria
- • Audit and certification costs
- • Certification lead time
- • Compliance with mandatory standards
Cofrac accreditation
YES
Enforceability
YES
CSRD/SFDR compatible
YES
The decisive criterion: separation of functions
The distinction between these three levels rests on a single fundamental principle: the separation of functions. This separation is what determines trust, comparability and enforceability.
Level 1: No separation
The approach creator defines the criteria, self-assesses compliance, and communicates on the results. Conflicts of interest are not excluded. Example: a brand declaring its own biodiversity commitment.
Level 2: Partial separation
An external third party carries out the assessment. However, this third party is not state-accredited and may also serve as a consultant or service provider for the same organisation. The methodology is not subject to public governance. Trust relies on reputation, not institutional oversight.
Level 3: Complete separation
The certification body is accredited by a national authority (Cofrac). It is legally prevented from designing the standard, advising the applicant, or marketing anything other than certification. Its decisions are subject to state oversight. Standards are public and enduring. This is the only level that produces evidence in the legal sense.
Practical implications
Public procurement
Only accredited certifications (Level 3) can be required in technical specifications or award criteria for a public contract, without risk of challenge.
Non-accredited assessments expose the buyer to legal appeals.
ESG reporting & regulation
CSRD, SFDR and DNSH require verifiable and comparable data. Only accredited certifications provide evidence accepted by authorities (AMF, ACPR).
Voluntary labels and non-accredited assessments are insufficient.
Communication & greenwashing
Accredited certifications provide protection against greenwashing accusations, as the process is public, independent and subject to state oversight. Internal labels are vulnerable.
Directive 2024/825 reinforces this distinction.
What this page measures
This classification is based on the normative framework of each approach: its conditions of enforceability, comparability, and its robustness in a regulatory context. A well-designed voluntary commitment can be sincere and ecologically relevant. An external assessment can produce a sophisticated and useful analysis.
All levels can contribute to biodiversity. Level 3 — based on accreditation — produces evidence accepted by authorities and investors. This is what creates traceability and accountability.
What the market does not say
The confusion between these three levels is not accidental. It benefits Level 1 and 2 approaches, which borrow the vocabulary of certification without respecting its constraints. Three mechanisms sustain this confusion:
Terminological confusion
Non-accredited approaches use the terms "certification", "certified" or "certification body" even though they are not accredited by a national authority. Regulation 765/2008 reserves these terms for accredited bodies.
Role accumulation
Some organisations create the standard, train the assessors, advise the project owners and issue the result. This concentration of functions is incompatible with ISO/IEC 17065 and makes the decision vulnerable to conflicts of interest.
Absence of public oversight
Level 1 and 2 approaches are not overseen by any public authority. Their methodology can evolve without governance, their decisions are subject to no external oversight, and their results are not enforceable in a regulatory context.
Four questions to ask before choosing an approach
Before selecting a biodiversity approach for a real estate project, a public contract or ESG reporting, ask these four questions. If the answer to any of them is no, the approach does not produce evidence in the regulatory sense.
1. Is the body accredited?
Check at www.cofrac.fr that the body holds a valid accreditation for the relevant scope (product, process and service certification).
2. Is the assessor independent of consultancy?
The body issuing the certification must be structurally separated from any consultancy, file preparation training or design activity. Separation of functions is a condition of ISO/IEC 17065.
3. Is the outcome enforceable?
The certification decision must be insertable in technical specifications, procurement regulations or a CSRD report without legal risk. Standard clauses are available.
4. Is the methodology public and enduring?
Standards must be published, versioned and subject to identifiable governance. A proprietary methodology modifiable without notice does not constitute a reliable normative framework.
Effinature certification, issued by IRICE — Cofrac Accreditation No. 5-0655, Product, Process and Service Certification, scope available at www.cofrac.fr — answers all four questions positively.
Frequently Asked Questions
An accredited certification is issued by a body whose competence has been verified by a national accreditation body (Cofrac in France). A voluntary label is a private scheme without external verification of the issuer's competence. The legal and evidential value differs considerably.
BPS (Biodiversity Performance Score) is a quantitative scoring tool that measures the biodiversity performance of a project. It is not in itself a certification. It feeds the Effinature certification (which is accredited) and can be used independently as a reporting tool.
Yes. Accredited certifications (Effinature, BREEAM) and voluntary labels cover different scopes and are combinable. A project can be Effinature-certified (biodiversity), BREEAM-certified (global ESG) and hold a CBCA label (construction carbon) simultaneously.
Directive 2024/825, to be transposed by 27 September 2026, prohibits unsubstantiated environmental claims and sustainability labels not based on a certification system verified by an independent third party. A non-accredited label does not constitute compliant substantiation. Penalties can reach 4% of annual turnover.
The directory of accredited bodies is public at www.cofrac.fr. Search by accreditation number or by name. For IRICE, the number is 5-0655 (Product, Process and Service Certification section). The scope document details the covered standards.
Related pages
Why accredited certification
The legal framework making accredited certification essential.
En savoir plus →Independence and accreditation
Why only accredited certification is sufficient.
En savoir plus →Effinature
The Cofrac-accredited biodiversity certification.
En savoir plus →BPS
The Biodiversity Performance Score per asset.
En savoir plus →Claims and Directive 2024/825
Penalties and substantiation of claims.
En savoir plus →Property developer
Biodiversity certification for developers.
En savoir plus →Move to Level 3 before September 2026
IRICE is the only body in France accredited by Cofrac for biodiversity certification of real estate projects. Submit an Effinature certification request.