ESRS E4 Biodiversity Standard Revamped: Smarter, Leaner, and Stronger
- Samantha Liu
- Aug 11
- 3 min read
Updated: Aug 26
By Mariya Dada
On 31 July 2025, EFRAG published revised and simplified ESRS, including a major update to ESRS E4: Biodiversity & Ecosystems. This was part of the wider Omnibus Simplification Package adopted by the European Commission in February 2025, aimed at reducing regulatory burden while enhancing decision-useful disclosures.
The update launches a public consultation window until 29 September 2025, after which EFRAG will submit its final advice to the Commission. The likely adoption in early 2026 will shape biodiversity reporting under the CSRD for years to come. Let us look at these changes, what this means for nature, and what companies should do to prepare for what’s next!
1. Structural Changes in ESRS E4
Paragraphs have been merged for clarity and conciseness (e.g., multiple objective sections are now unified under §1). For example:
Disclosures related to governance, strategy, and IRO (impact-risk-opportunity) are now covered in ESRS 2 (cross-cutting), reducing duplication across ESRS. For example:
All “may disclose”/ voluntary datapoints have been moved to a Non-Mandatory Illustrative Guidance (NMIG) document to clearly separate what’s required from what’s encouraged. For example:
These changes have resulted in a shorter, simpler standard, focused on high-impact, decision-useful biodiversity disclosures.
2. Key Biodiversity Content Changes
a. Transition Plan (E4-1): Optional earlier, it is now mandatory to disclose if the reporting company already has a public biodiversity transition plan. It Follows the TNFD structure i.e. it must include targets, milestones, capital expenditure alignment, and governance.
b. Location-Specific Metrics (§20): Geo-tagging of material impacts, dependencies, and biodiversity-sensitive areas is now essential. This pushes companies to report at site level rather than only aggregated data.
c. Metrics Hierarchy: Companies should prioritize state-of-nature metrics preferably directly measured at site, then proxies when direct measurement is not feasible, then pressure-based models/ impact drivers if direct data is unavailable.
d. Integration with Global Frameworks: E4 now explicitly references the Kunming-Montreal Global Biodiversity Framework (GBF), EU Nature Restoration Law, and TNFD, easing harmonization for multinationals.
e. Social Links (S3): Includes cross-references to social standard ESRS S3, ensuring alignment with indigenous rights, local communities, and human rights.
3. Why This Exposure Draft Is a Step Forward
This draft brings:
Better alignment with TNFD, GBF, NPI
Clearer definitions, e.g., “near biodiversity-sensitive areas”
Focus on quality data over long checklists
Less duplication across standards
Overall, EFRAG reduced biodiversity datapoints significantly as mandatory datapoints reduced by ~57%, while total datapoints (mandatory + voluntary) were cut by over 60%. Most of the “dropped” datapoints were already optional, or related to financial effects or resilience. These are now rightly integrated into ESRS 2. NMIG now houses former illustrative datapoints as voluntary guidance, giving companies flexibility to tailor disclosures without overload. Hence, this is not a rollback or a weakening, but a strategic reallocation.
4. What Companies Should Do Now to Prepare for What's Ahead:
✅ Map controls and reporting tools to the new paragraph structure
✅ Consolidate strategy and governance content under ESRS 2
✅ Develop geo-tagged data pipelines for location-level biodiversity disclosures
✅ Formalize or refine transition plans with extractable KPIs, targets, governance
✅ Leverage NMIG to enrich your reporting without adding compliance burden
Companies already aligning with TNFD will find this update makes reporting simpler, not harder. At first glance, the trimmed-down E4 standard might look like a regulatory weakening but it’s the opposite. The reallocation of datapoints into ESRS 2 and NMIG, combined with the focus on geographic granularity and series alignment with global standards, actually elevates the duality, decision usefulness, and accountability of biodiversity reporting.
The revised ESRS E4 represents a significant streamlining effort-moving from detailed, prescriptive requirements to a more principles-based approach that maintains rigor while improving practicality for companies reporting on biodiversity and ecosystem impacts, risks, and opportunities.
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