ESRS E4 mandates reporting, SBTN frames targets, ACT Biodiversity assesses strategy. Three biodiversity frameworks often confused, in reality complementary — and all dependent on the same raw material: reliable, traceable field data.
Sustainability teams face an accumulation of biodiversity frameworks: the ESRS E4 standard under the CSRD, the ACT Biodiversity methodology (ADEME-OFB), and SBTN (Science Based Targets Network) targets. The temptation is to pit them against each other or to ask "which one to choose". That is a framing error: they do not answer the same question. This article clarifies the role of each and shows what they have in common.
Key takeaways
- ESRS E4 is a mandatory reporting standard (CSRD); SBTN is a target-setting framework; ACT Biodiversity is a strategy-assessment methodology.
- These three frameworks are not substitutable: a mature company uses them sequentially and coherently.
- Their common denominator is reliable, traceable biodiversity data.
- The ACT roadtest stumbled on this very point: public CSRD data proved insufficient to assess.
- The right reading is a chain: measure → set targets (SBTN) → deploy and assess (ACT) → report (ESRS E4).
Three different questions
| Framework | The question it answers | Nature |
|---|---|---|
| ESRS E4 (CSRD) | "What must I disclose about my biodiversity impacts, risks and opportunities?" | Mandatory reporting standard |
| SBTN | "What science-based targets should I set for nature?" | Target-setting framework |
| ACT Biodiversity | "Is my biodiversity strategy commensurate with a nature-positive pathway?" | Strategy-assessment methodology |
These three frameworks are not substitutable. One mandates what to say (ESRS E4), another helps set what to aim for (SBTN), the third assesses what the company actually does (ACT). A mature company will mobilise all three — sequentially and coherently.
ESRS E4: the reporting obligation
ESRS E4 is the "Biodiversity and ecosystems" standard of the European sustainability reporting standards, applicable under the CSRD directive (EU 2022/2464). Subject to materiality, it requires disclosure of the transition strategy, impacts and dependencies, risks, targets and a set of quantitative datapoints. It is a transparency framework: it structures the information disclosed, but does not say whether the strategy is good. To go further, see our dedicated page on ESRS E4 — biodiversity reporting.
SBTN: setting science-based targets
The Science Based Targets Network offers companies a process to define "science-based" targets for nature (water, soils, biodiversity, oceans), consistent with planetary boundaries. SBTN operates upstream of action: it helps determine where to act first and which targets to set. The ACT Biodiversity methodology explicitly refers to it — notably through the SBTN list of high-impact commodities (HIC), to which the roadtest recommends aligning certain upstream-module criteria.
ACT Biodiversity: assessing the actual strategy
ACT Biodiversity, for its part, operates downstream of commitment: it assesses the strategy actually deployed — targets, governance, practices, business model — and grades it on three dimensions (performance, narrative, trend). Where ESRS E4 organises disclosure and SBTN frames ambition, ACT measures the actual alignment between intentions and actions. It is a steering and progress tool, not a regulatory obligation. For the detail, see our guide to the ACT Biodiversity methodology.
The common denominator: field data
Here is the point that juxtaposing these frameworks makes visible: all three rest on the same raw material — reliable biodiversity data.
- ESRS E4 requires traceable, auditable quantitative datapoints.
- SBTN assumes a baseline assessment of the initial state to set credible targets.
- ACT Biodiversity, as its roadtest recalls, "does not assess the state of nature itself", which "must be analyzed by companies prior to the assessment".
Yet the first ACT Biodiversity roadtest stumbled precisely on this data: it concludes that "even for companies publishing a CSRD-compliant report, public data was not sufficient" to conduct the assessment, due to insufficient maturity on ESRS E4. The report also notes that companies are, overall, "less mature on biodiversity than climate change". In other words: stacking frameworks is pointless as long as the state data is not solid.
A coherent chain, not a stack
The right reading is not "ESRS E4 versus SBTN versus ACT", but a chain:
- Measure the actual state of biodiversity (certified field data).
- Set science-based targets (SBTN).
- Deploy and have your strategy assessed (ACT Biodiversity).
- Report in an auditable way (ESRS E4).
Each step builds on the previous one. And all of them depend on the first: without reliable measurement, targets are arbitrary, the assessment is fragile and reporting is exposed to the risk of unsubstantiated claims. That is the role of certified third-party measurement we detail in our article on independent certification of biodiversity data.
Secure the data foundation of all three frameworks. IRICE's Effinature certification — a body accredited by Cofrac under no. 5-0655 to ISO/IEC 17065 (scope available at www.cofrac.fr) — produces the reliable, traceable field data that feeds your ESRS E4 reporting as well as your SBTN targets and your ACT assessments. Talk to an IRICE expert.
Sources: ACT Biodiversity methodology v1 (ADEME-OFB, June 2026); ACT Biodiversity roadtest report (EVEA for ADEME and the OFB, January 2026); ESRS E4 (Commission Delegated Regulation EU 2023/2772).
Frequently asked questions
ESRS E4 is a mandatory reporting standard under the CSRD (what to disclose). SBTN helps set science-based targets (what to aim for). ACT Biodiversity assesses the strategy actually deployed (what the company does). The three are complementary.
No. They are not substitutable. A mature approach chains them: measure the initial state, set targets (SBTN), deploy and have the strategy assessed (ACT), then report in an auditable way (ESRS E4).
All three rest on the same raw material: reliable, traceable biodiversity data. Without robust field measurement, targets are arbitrary, the assessment is fragile and reporting is exposed to the risk of unsubstantiated claims.
No. Unlike ESRS E4, which applies under the CSRD, ACT Biodiversity is a voluntary methodology for assessing and steering biodiversity strategy.
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Cofrac Accreditation No. 5-0655, Product, Process and Service Certification, scope available at www.cofrac.fr.