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.
ESRS E4 remains one of the most demanding standards in terms of factual data expected.
The disclosure requirements of ESRS E4 (2023 version, Delegated Regulation (EU) 2023/2772)
- 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 Targets: measurable targets related to biodiversity and ecosystems.
- E4-5 Impact metrics: quantitative data on impacts: land take, species disturbance, habitat degradation.
- E4-6 Anticipated financial effects of biodiversity-related risks and opportunities.
Targets and impact metrics are the most structuring for real estate: they call for 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
The scope and timeline of the CSRD have been amended at EU level since its adoption. Each company checks its own position against the texts in force for the financial year concerned.
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")
- Indicators aggregated at portfolio or company level, not linked to an asset
- Regulatory impact assessments (focused on legal risk, not performance)
- Multi-criteria approaches where biodiversity is only one topic among others
- 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 and dependencies
- Traceability of methodology, sources and assumptions
This is exactly the gap that the BPS (Biodiversity Performance Score) fills: a structured scoring based on 70+ criteria, applied asset by asset, with quantified results, a documented methodology and an individual attestation signed by IRICE as an independent third party.
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 of ESRS E4: 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 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.
Auditable data: what assurance requires
The sustainability auditor must be able to trace every declared datapoint: verify, recalculate and confirm it. The BPS documents, for each criterion, the source, the method and the assumptions, and IRICE signs the attestation as an independent third party.
What the BPS brings to the auditor
- 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 signs the BPS attestation as an independent third party
- 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 are building an auditable track record, comparable from one financial year to the next.
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 quantitative datapoints of ESRS E4. 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.
Learn more →EU Taxonomy: DNSH
DNSH test on objective 6 for Taxonomy alignment.
Learn more →Double materiality
Impact and financial materiality applied to biodiversity.
Learn more →ESRS E1: climate
The construction carbon component of CSRD reporting.
Learn more →Your CSRD biodiversity reporting starts here
The BPS produces the quantitative datapoints expected by ESRS E4. Quantified score, asset by asset, auditable by an independent third-party body.