CSRD and ESRS E4: From Group Reporting to Asset-Level Operations

1. The CSRD directive: architecture and timeline

Directive (EU) 2022/2464 of 14 December 2022, the Corporate Sustainability Reporting Directive (CSRD), replaces the 2014 NFRD. It broadens the scope of companies subject to non-financial reporting, harmonises the format using European ESRS standards, and requires verification by a statutory auditor or an independent assurance provider.

Implementation waves

• 2025 (FY 2024) — large public-interest entities already subject to the NFRD: approximately 11,700 entities.
• 2026 (FY 2025) — all large companies meeting two of three criteria: 250 employees, EUR 50 million turnover, EUR 25 million balance sheet.
• 2027 (FY 2026) — listed SMEs on a regulated market, with a simplified regime.
• 2029 (FY 2028) — non-EU companies generating more than EUR 150 million turnover in the European Union.

The February 2025 Omnibus package

The European Commission published an Omnibus package in February 2025 simplifying the implementation of the CSRD: raising the eligibility threshold, postponing waves 2 and 3 by one to two years, and reducing the list of mandatory indicators. The central principle — the biodiversity reporting obligation — is maintained and has not been called into question.

The 12 thematic ESRS

The CSRD relies on the European Sustainability Reporting Standards (ESRS), developed by EFRAG and adopted by the Commission. The corpus comprises two cross-cutting standards (ESRS 1 and ESRS 2) and ten thematic standards:

• ESRS E1 — Climate change
• ESRS E2 — Pollution
• ESRS E3 — Water and marine resources
• ESRS E4 — Biodiversity and ecosystems
• ESRS E5 — Circular economy
• ESRS S1 — Own workforce
• ESRS S2 — Workers in the value chain
• ESRS S3 — Affected communities
• ESRS S4 — Consumers and end-users
• ESRS G1 — Business conduct

3. From reporting to operations: the four pillars

ESRS E4 requires the annual production of verifiable information. Statutory auditors expect traceable data, comparable year on year, and supported by a reproducible methodology. Moving from declarative reporting to a robust operational chain requires four structural pillars.

Pillar 1 — Map the portfolio

First step: inventory all assets with their site characteristics (location, area, uses, ecological sensitivity of the surroundings). Without an initial mapping, no aggregated reporting is possible. This mapping can draw on the manager's own data (land, floor areas) and on public resources (INPN — French national natural heritage inventory, IGN Geoservices, CartoNatura).

Pillar 2 — Assess performance per asset

Each asset must be assessed against comparable indicators. This is the role of a multi-criteria biodiversity score, calculated on a common framework. Assessment typically covers three phases: baseline state of the site before intervention, project design (where applicable), and operations. For existing portfolios, only the operations phase is relevant — the baseline post-dates delivery.

Pillar 3 — Define an asset policy

ESRS E4 requires companies to disclose their biodiversity-related policies. In practice: acquisition criteria, requirements for new developments and renovations, and a management plan for outdoor areas of existing assets. This policy must be consistent with the stated trajectory and manageable at the portfolio level.

Pillar 4 — Set a measurable improvement trajectory

ESRS E4 expects a dated, quantified trajectory: a baseline score at year N, interim targets (N+3, N+5), and a long-term horizon (N+10). The trajectory requires a repeatable measurement across multiple reporting periods, which rules out one-off or proprietary non-standardised assessments.

5. Tooling the chain: assessment, certification, advisory

Translating ESRS E4 into an operational policy requires three complementary building blocks: a standardised assessment for the existing portfolio, an accredited certification for new developments, and advisory support to structure the asset policy.

Portfolio biodiversity assessment — BPS

The Biodiversity Performance Score (BPS) is a multi-criteria assessment tool published by IRICE. It provides a quantified score out of 100 per asset, aggregable at portfolio level, and feeds into ESRS E4, SFDR PAI 14-15 and EU Taxonomy reporting. Three assessment phases: baseline state, project design, and operations. Over 70 criteria cover the full ESRS E4 scope (soil, vegetation, fauna, impacts, competencies). BPS is a scoring tool, distinct from any certification process, and falls outside the scope of IRICE Cofrac accreditation.

Accredited certification for new developments

For new developments and major renovation projects, an accredited certification enables an independent third party to attest the biodiversity performance of the project. Effinature, accredited by Cofrac under ISO/IEC 17065, covers four referentials: NCO (new construction), EVO (renovation), HOR (landscaping), HVE (post-certification monitoring). The Effinature attestation constitutes per-asset evidence, enforceable before statutory auditors and ESG auditors.

Carbon footprint of ongoing operations

ESRS E4 does not cover the carbon footprint of ongoing operations (ESRS E1 Climate scope) but their articulation is expected: statutory auditors verify the consistency between the biodiversity policy (E4) and the carbon policy (E1) for the same asset. For construction contracts and building sites, Efficarbone measures EN 15978 modules A4 to A9 and feeds the carbon reporting for operations delivered during the year.

Advisory for asset policy

Beyond technical tooling, drafting the asset policy (acquisition criteria, requirements for new developments, outdoor area management plan) requires environmental advisory support. ARKENOR, a subsidiary of the NORMAXIS group, supports ESG directorates in formalising their biodiversity policy and steering the improvement trajectory expected by ESRS E4.