2025 Draft Simplified ESRSESRS E4

Disclaimer

  1. This draft version of the Simplified ESRS has been published by EFRAG as a Technical Advice to the European Commission on 30 November 2025 and is not yet adopted as a Delegated Act. A version based on the Delegated Act on Simplified ESRS will be provided on the ESRS Knowledge Hub as soon as available. Access latest adopted 2023 ESRS here.

Objective

  1. 1.

    (1 amended) The sustainability statement shall include information in relation to ESRS E4 Biodiversity and Ecosystems if this topic relates to material impacts, risks and opportunities to cover all the reporting areas listed in paragraph 5 of ESRS 1 General Requirements. If not all the sub-topics prescribed by this Standard are to be reported following the materiality assessment, paragraph 30 of ESRS 1 General Requirements applies.

  2. 2.

    (7 amended) The objective of this Standard is to set out Disclosure Requirements (DRs) providing information in relation to the reporting areas referred above that implement and complement the cross-cutting provisions of ESRS 1 General Requirements and ESRS 2 General Disclosures.

  3. 3.

    In this Standard, each DR is introduced by a disclosure objective except for policies, actions and targets, for which the provisions in ESRS 2 GDR-P, GDR-A and GDR-T provide the necessary framing for the relevant DRs.

  4. 4.

    (1(c) amended) This Standard takes account of EU regulatory frameworks and other relevant frameworks, including the vision of the Kunming-Montreal Global Biodiversity Framework and its relevant goals and targets, relevant aspects of the EU Biodiversity Strategy for 2030, EU Birds and Habitats Directives (Directive 2009/147/EC of the European Parliament and of the Council and Council Directive 92/43/EEC), the Marine Strategy Framework Directive (Directive 2008/56/EC of the European Parliament and of the Council), the 2023 EU Marine Action Plan, the EU Water Framework Directive (Directive 2000/60/EC of the European Parliament), and the Nature Restoration Regulation (Regulation (EU) 2024/1991 of the European Parliament and of the Council).

  5. 5.

    This Standard sets out DRs related to biodiversity and ecosystems, particularly with respect to the following closely interlinked sub-topics: drivers of biodiversity and ecosystem change; the state of species; the condition and extent of terrestrial, freshwater and marine ecosystems; and ecosystem services.

  6. 6.

    (3 amended) The terms ‘biodiversity’ and ‘biological diversity’ refer to the variability among living organisms from all sources including, inter alia, terrestrial, freshwater, marine and other aquatic ecosystems and the ecological complexes of which they are part.

  7. 7.

    Context-specific considerations are particularly important in relation to biodiversity and ecosystems. If material impacts, risks or opportunities are related to specific geographies, it is important to consider appropriate aggregation or disaggregation of the reported information, e.g. by site, ecosystem or another level in accordance with ESRS 1 General Requirements, Chapter 3.3.2 Level of Aggregation, Disaggregation.

Interaction with other ESRS

  1. 8.

    (4 and 5(a) amended) Social and environmental topics interact with each other. For instance, direct drivers of biodiversity and ecosystem change are climate change, pollution, land-use change, freshwater-use change and sea-use change, direct exploitation of organisms and invasive alien species. These drivers are covered in ESRS E4 Biodiversity and Ecosystems except for climate change and pollution, which are addressed by ESRS E1 Climate Change and ESRS E2 Pollution. The main points of interaction between ESRS E4 Biodiversity and Ecosystems and the other topical standards are the following.

    1. (a)

      (5(a) amended) ESRS E1 Climate Change addresses climate change mitigation, climate change adaption and energy, whereas impacts on biodiversity and ecosystems related to the undertaking’s activities addressing climate mitigation and adaption are addressed in ESRS E4 Biodiversity and Ecosystems.

    2. (b)

      (5(b) amended) ESRS E2 Pollution addresses the emission of pollutants to air, water and soil and the manufacturing, use and release of microplastics, whereas impacts of pollution on biodiversity and ecosystems are addressed in ESRS E4 Biodiversity and Ecosystems.

    3. (c)

      (5(c) amended) ESRS E3 Water addresses the use of water, whereas impacts on biodiversity and ecosystems related to the use of water are addressed in ESRS E4 Biodiversity and Ecosystems.

    4. (d)

      (5(d) amended) ESRS E5 Resource Use and Circular Economy addresses the type and circularity of resource inflows, including marine resources, waste and the implementation of circular economy principles, whereas the impacts on biodiversity and ecosystems related to these topics are addressed in ESRS E4 Biodiversity and Ecosystems.

    5. (e)

      (6 amended) ESRS S3 Affected Communities addresses material negative impacts on affected communities arising from biodiversity and ecosystems-related impacts attributable to the undertaking.

Disclosure Requirements

Strategy

Disclosure Requirement E4-1 – Biodiversity and ecosystems transition plan

  1. 9.

    (12 amended) The objective of this DR is to enable an understanding of the undertaking’s response and contribution to the transition implied by the Kunming-Montreal Global Biodiversity Framework (GBF) if it has in place a biodiversity and ecosystems transition plan and has made public its key features.

  2. 10.

    (15 amended) If the undertaking has in place a biodiversity and ecosystems transition plan to transform its business model and strategy so that it contributes to the global goal of halting and reversing biodiversity loss, as stated in the GBF, and it has made public the key features of such plan, it shall disclose those features.

APPLICATION REQUIREMENTS

AR 1 for para. 10

(Biodiversity and ecosystems transition plan)

(AR 1 amended) Biodiversity can also be part of an undertaking’s broader transition plan that, for instance, addresses climate change. Biodiversity and ecosystems transition plans, or plans that integrate biodiversity, contain information on targets, key actions, financial planning and governance. They are also expected to include a clear explanation of how the undertaking’s strategy and business model will evolve to contribute to the global goal of halting and reversing global biodiversity loss set out in the GBF and can include the identification and management of synergies and trade-offs with other transition plan objectives, including any response and contribution to the transition implied by the Paris Agreement.

AR 2 for para. 10

(Biodiversity and ecosystems transition plan)

(new) ‘Has made public’ means that the undertaking has made the key features of its biodiversity and ecosystems transition plan available before or at the time of the release of its sustainability statement, through accessible public channels such as its website or reports.

Impact, risk and opportunity management

Disclosure Requirement E4-2 – Policies related to biodiversity and ecosystems

  1. 11.

    (22 amended) The undertaking shall disclose its biodiversity and ecosystems policies in accordance with the provisions of ESRS 2 GDR-P.

  2. 12.

    In addition to the provisions of ESRS 2 GDR-P, the undertaking shall describe the content of its biodiversity and ecosystems-related policies with respect to:

    1. (a)

      (23(d) amended) supporting the traceability of products, components and raw materials that have actual or potential material impacts on biodiversity and ecosystems in its value chain; and

    2. (b)

      (24(a) amended) sites in its own operations in or near a biodiversity-sensitive area.

APPLICATION REQUIREMENTS

AR 3 for para. 11

(Policies related to biodiversity and ecosystems)

(24(b), (c), (d) amended) When describing the content of its policies, the undertaking shall specify, where applicable, whether they address sustainable land or agricultural practices; sustainable oceans or seas practices; or deforestation.

AR 4 for para. 11

(Policies related to biodiversity and ecosystems)

(18 amended) Biodiversity and ecosystems scenario analysis can inform the identification, assessment and management of material risks and opportunities over short-, medium- and long-term time horizons. The undertaking can consider the use of scenario analysis when defining its policies, actions and targets.

AR 5 for para. 12 (b)

(Policies related to biodiversity and ecosystems)

(new) If the undertaking’s site is in or near a biodiversity-sensitive area, its activities can be related to material negative impacts on the biodiversity-sensitive area. Whether an undertaking’s site outside a biodiversity-sensitive area is near such an area shall be determined by defining the site’s area of influence. The area of influence can be determined by applying buffer distances specific to the undertaking’s type of activity following regulatory requirements, science-based recommendations and industry best practice.

Disclosure Requirement E4-3 – Actions and resources related to biodiversity and ecosystems

  1. 13.

    (27 amended) The undertaking shall disclose its key biodiversity- and ecosystems-related actions and resources allocated to their implementation in accordance with the provisions of ESRS 2 GDR-A.

  2. 14.

    (28 amended) In addition to the provisions of ESRS 2 GDR-A, the undertaking shall describe any biodiversity offsets used as part of its actions, including the aim of the offsets, the financing effects in monetary terms, the area, type and quality criteria applied, and the standards with which the biodiversity offsets comply.

APPLICATION REQUIREMENTS

AR 6 for para. 13

(Actions related to biodiversity and ecosystems)

(AR 23 amended) Actions to be disclosed under paragraph 13 shall consider the right to free, prior and informed consent of indigenous peoples (see also ESRS S3- 2).

Metrics and Targets

Disclosure Requirement E4-4 – Targets related to biodiversity and ecosystems

  1. 15.

    (31 amended) The undertaking shall disclose its biodiversity and ecosystems targets in accordance with the provisions of ESRS 2 GDR-T.

  2. 16.

    (31, 32(e) amended) If the undertaking uses biodiversity offsets in setting its targets, it shall disclose how these offsets were used.

APPLICATION REQUIREMENTS

AR 7 for para. 15

(Targets related to biodiversity and ecosystems)

(AR 26 amended) Biodiversity-related targets:

(a) typically address ‘pressures’ on nature and aim at reducing the drivers of biodiversity and ecosystem change (e.g. avoiding land-use change due to the conversion of forest land) as well as address the ‘state of nature’ and aim to improve the species and ecosystem extent and condition (e.g. increasing the population size of species at extinction risk or restoring a landscape condition compared to a baseline level);

(b) are most effective if they are science-based and aligned with ecological thresholds and contribute to the targets of the GBF;

(c) can be set at different levels (see ESRS 2 General Disclosures, paragraph 51(c)), e.g. at site, landscape, company or upstream value chain level, depending on the goal of the target and the capacity of the undertaking to influence its achievement;

(d) are typically implemented in accordance with the mitigation hierarchy: avoidance, minimisation, restoration and compensation.

Disclosure Requirement E4-5 – Metrics related to biodiversity and ecosystems change

  1. 17.

    (34 amended) The objective of this DR is to enable an understanding of the performance of the undertaking against material biodiversity and ecosystems change-related impacts, risks and opportunities.

  2. 18.

    (16(a) and 19(a) amended) The undertaking shall disclose the following information for material biodiversity and ecosystem change-related impacts, risks or opportunities:

    1. (a)

      (16(a)(ii) amended) the locations in its own operations to which the material impacts, risks or opportunities relate;

    2. (b)

      (16(a)(iii) amended) for those locations, a list of biodiversity-sensitive area(s) (name and type) related to the undertaking’s material negative impacts, if any; and

    3. (c)

      (16(a)(i) amended) the undertaking’s activities that are related to material negative impacts on the biodiversity-sensitive areas described in (b) above.

  3. 19.

    (33, 36, 38, 39, 40 and 41 amended) In addition to paragraph 18, and in accordance with ESRS 2 GDR-M, the undertaking shall report metrics related to its material impacts on biodiversity and ecosystems.

APPLICATION REQUIREMENTS

AR 8 for para. 18

(Metrics related to biodiversity and ecosystems change)

(new) To inform the prioritisation for disclosure and the level of aggregation or disaggregation, the undertaking shall consider locations where its own operations are related to material negative impacts on biodiversity-sensitive areas.

The undertaking is not necessarily expected to disclose this information for each of its individual sites and can aggregate information to relevant groups of sites related to its material impacts, risks and opportunities, for example based on the same biodiversity-sensitive area or cluster of areas in a region affected by multiple sites, in accordance with ESRS 1 General Requirements, Section 3.3.2.

AR 9 for para. 19

(Metrics related to biodiversity and ecosystems change)

When providing the description of material Impacts in accordance with ESRS 2 IRO-2, the undertaking shall indicate which material impacts concern (16(b) amended) land degradation, desertification or soil sealing and (16(c) amended) operations that affect threatened species or ecosystems.

AR 10 for para. 19

(Metrics related to biodiversity and ecosystems change)

(new) Depending on which sub-topic is assessed material, the undertaking shall include metrics in relation to:

(a) drivers of biodiversity and ecosystem change;

(b) the state of species (e.g. related to extinction risk);

(c) the condition and extent of terrestrial, freshwater, and marine ecosystems (e.g. related to site condition and landscape condition); and

(d) ecosystem services.

AR 11 for para. 19

(Metrics related to biodiversity and ecosystems change)

(AR 30 amended) Primary data on the state of nature metrics collected at location-level or through remote sensing is the best means to help determine impacts on biodiversity and ecosystems. Using primary data on the state of nature is especially relevant where the undertaking’s sites are in or near biodiversity-sensitive areas. The undertaking can also estimate its impacts by using data on impact drivers or secondary data on the state of nature.

AR 12 for para. 19

(Metrics related to biodiversity and ecosystems change)

When identifying metrics to disclose, the undertaking shall consider:

(a) (AR 27(f) amended) the frequency of monitoring and the baseline condition or value and baseline year or period; and

(b) (AR 28 amended) whether the metrics enable users to understand how they relate to the material impacts.