European Taxonomy
DNSH objective 6 — biodiversity
For a real estate activity to be aligned with the European Taxonomy, it must not cause significant harm to biodiversity and ecosystems. This DNSH (Do No Significant Harm) test on objective 6 requires a specific impact assessment.
The European Taxonomy applied to real estate
The Taxonomy Regulation (EU 2020/852) defines the criteria for determining whether an economic activity is "green" in the European sense. For real estate, covered activities include new building construction, renovation, acquisition and asset management.
To be aligned with the Taxonomy, a real estate activity must meet three cumulative conditions:
- 1. Substantial contribution to at least one of the 6 environmental objectives (climate mitigation, adaptation, water, circular economy, pollution, biodiversity)
- 2. DNSH (Do No Significant Harm) — not cause significant harm to any of the other 5 objectives
- 3. Minimum safeguards — compliance with international conventions (OECD, UN, ILO)
In practice, a building that substantially contributes to objective 1 (climate mitigation, via RE2020 for example) must also demonstrate that it does not cause significant harm to objective 6 (biodiversity). This is the biodiversity DNSH test.
The biodiversity DNSH test: concrete requirements
Annex I of the Taxonomy delegated regulation details the DNSH criteria for objective 6 applied to real estate activities. The main requirements:
Environmental impact assessment
For projects subject to impact assessment (ICPE, ZAC, IEA thresholds), the mitigation measures identified in the EIA must be implemented. For projects not subject to assessment, a proportionate biodiversity impact evaluation must be carried out.
Natura 2000 and protected areas
The project must not undermine the integrity of Natura 2000 sites or protected areas. If the site is located in or near such an area, an appropriate assessment must confirm the absence of harm.
Mitigation hierarchy
The activity must respect the mitigation hierarchy: Avoid first, Reduce second, Compensate as a last resort. The measures taken at each step must be documented and proportionate to the identified impacts.
No conversion of high-value land
The activity must not lead to the conversion of land with high biodiversity value (primary forests, wetlands, high-biodiversity natural grasslands) into land of lower ecological value.
These criteria are formulated as negative conditions ("do not cause harm"), but demonstrating them requires positive data: documented baseline assessment, traced mitigation measures, monitoring results. This is precisely the structure of the BPS.
How the BPS documents the DNSH test
The BPS was not designed as a Taxonomy tool, but its three-phase structure structurally covers the DNSH objective 6 requirements:
| DNSH objective 6 requirement | Corresponding BPS phase | Criteria mobilised |
|---|---|---|
| Impact assessment | Baseline Assessment | Fauna/flora inventories, habitats, wetlands, ecological corridors |
| Natura 2000 areas | Baseline Assessment | Location, distance to designated sites, regulatory context |
| Mitigation hierarchy | Design | Avoidance measures, impact reduction, any compensation |
| No land conversion | Baseline Assessment + Design | Soil characterisation, land footprint, net land take |
| Monitoring and maintenance | Operation (forthcoming) | Design/delivery consistency, ecological management, maintenance |
The BPS attestation signed by IRICE constitutes a documented piece of evidence for the DNSH test. It does not replace a formal Taxonomy assessment (which is the responsibility of the company and its auditor), but it provides the factual and quantitative basis needed to build one.
Taxonomy alignment rate: the challenge for real estate funds
Real estate funds classified SFDR article 8 or 9 must publish their Taxonomy alignment rate — the share of their portfolio invested in aligned activities. To increase this rate, each asset must pass the DNSH test on the 5 non-targeted objectives, including biodiversity.
In practice, objective 6 (biodiversity) is often the weak link: climate criteria (objective 1) are documented via the energy performance certificate or RE2020, water criteria (objective 3) via flow meters, but biodiversity criteria lack standardised data. The BPS fills this gap by providing a reproducible score for each asset.
⚠️ Effinature accredited certification and Taxonomy
Frequently asked questions
Yes. Any real estate activity that claims Taxonomy alignment (regardless of the targeted objective) must demonstrate that it does not cause significant harm to biodiversity (objective 6). It is a necessary condition of alignment.
The regulatory EIA partially covers DNSH objective 6 requirements, but its conclusions are not always structured according to the Taxonomy delegated regulation criteria. The BPS provides a framework directly aligned with these criteria.
DNSH verifies the absence of significant harm (minimum threshold). Substantial contribution to objective 6 requires active and measurable improvement of biodiversity. The BPS documents DNSH; the Effinature accredited certification can document a substantial contribution.
Taxonomy and carbon: objective 1 too
Objective 6 (biodiversity) is only one of the six environmental objectives of the EU Taxonomy. Objective 1 (climate change mitigation) is the most frequently invoked for real estate activity alignment. Activity 7.1 (new building construction) requires a full LCA for buildings > 5,000 m2, including modules A4-A5 (construction site emissions).
Efficarbone produces the EN 15978 measurement data needed to demonstrate alignment with objective 1. ESRS E1 climate →
EU Taxonomy: document biodiversity and carbon
BPS (DNSH objective 6, biodiversity) and Efficarbone (objective 1, construction site LCA): the two tools to demonstrate alignment of your real estate assets.