General information, not legal advice.
A practical guide for sustainability teams preparing CSRD reports after the Omnibus simplification, including who is in scope, what the revised ESRS change, what the biodiversity standard (ESRS E4) now asks for, and a pre-submission checklist.
ESRS E4 in brief. ESRS E4 is the CSRD reporting standard on biodiversity and ecosystems. It covers a company's impacts and dependencies on nature and the related risks and opportunities, takes account of the Kunming-Montreal Global Biodiversity Framework, and applies only if biodiversity is material under the company's double materiality assessment.
Key takeaways
- Fewer companies report, and later. The Omnibus I Directive limits CSRD to companies with more than 1,000 employees and more than €450 million net turnover. Companies not yet reporting now start with financial year 2027, published in 2028.
- The standards are lighter but not optional. The revised ESRS, adopted by the Commission on 3 July 2026, cut mandatory datapoints by more than 60% and keep double materiality as the core test.
- Materiality now decides everything. Non-material information is generally not allowed in the report, so the double materiality assessment determines what your team collects, assures and publishes.
- Biodiversity is narrower and more concrete. If biodiversity is material, ESRS E4 always requires location-based metrics: where your sites are, which sensitive areas they touch, and what your activities do to nature.
- Location data is the new bottleneck. Site coordinates, area of influence, baselines and methods need an owner before the first report, because estimates are accepted only when method and limits are explained.
- The report and your marketing must tell the same story. From 27 September 2026, EmpCo limits consumer-facing environmental claims, so CSRD disclosures and public claims need one shared evidence base.
- Every number needs its limits attached. Whatever the data source, each E4 indicator should carry its method, resolution, time window and limits, so a reviewer can trace it back.
What CSRD is, why sustainability owns it, and why it matters
CSRD is the Corporate Sustainability Reporting Directive (Directive (EU) 2022/2464). It requires in-scope companies to publish a sustainability statement inside the management report, prepared under the European Sustainability Reporting Standards (ESRS), digitally tagged and subject to external assurance.
Between 2025 and 2026 the directive was reshaped twice: the Stop-the-Clock Directive delayed later reporting waves, and the Omnibus I Directive narrowed the scope. A third step, the revised ESRS, changes what is actually reported. Any scoping or readiness work completed before March 2026 should be re-checked.
Sustainability teams own CSRD in practice because the hard parts are not the written composition. They are the double materiality assessment, the data behind every metric, the controls an assurance provider will test, and the link between what the company reports and what it says publicly. Finance, legal, procurement and marketing all contribute, but someone has to hold the evidence together.
CSRD is a directive, so each Member State writes it into national law. Transposition is not finished everywhere, and some countries may go further than the EU minimum. Check the national rules for each country where you have in-scope entities.
The opportunity is focus. A report built around a small number of material topics, with a clear evidence file behind each number, is easier to assure, easier for investors to use, and easier to reuse in tenders, financing and customer questionnaires.
The teams that benefit most from the simplification will be the ones that use it to build a repeatable data process, not to postpone the work.
Who and what are covered
After Omnibus I, CSRD applies only to companies that pass both tests below, individually or on a consolidated basis. The old split between later reporting waves has been removed.
If you planned against the original waves: wave 1 companies (large public-interest entities reporting since financial year 2024) continue to report, subject to the transition rules below. Wave 2 (other large companies) and wave 3 (listed SMEs), which Stop-the-Clock had postponed, are now tested against the new thresholds only. Those that pass report first for financial year 2027; listed SMEs below the thresholds are out of scope.
The proposed non-EU standard focuses on impacts on people and the environment. EFRAG’s consultation on the draft standard closed on 31 October 2026. EFRAG expects to deliver its technical advice to the European Commission in January 2027, so the final details may still change.
Non-EU, US and UK companies
CSRD reaches companies outside the EU through three routes, and one group can be caught by more than one:
- EU listing. A non-EU company with securities on an EU regulated market is tested against the same thresholds as an EU company.
- EU subsidiaries. An EU subsidiary or subgroup that passes the thresholds reports in its own right.
- Group-level report. A non-EU ultimate parent with more than €450 million EU turnover and an EU subsidiary or branch above €200 million publishes a group report under Article 40a.
The Article 40a report does not discharge an EU subsidiary's own obligation, so check both levels. UK companies are treated like any other non-EU company.
Groups and subsidiaries
Thresholds are tested individually or on a consolidated basis. A subsidiary can generally be exempt from its own report if it is included in its parent's consolidated sustainability report, subject to conditions set in national law. Decide early whether group reporting or stand-alone subsidiary reports make more sense, because the choice drives where your data has to be consolidated.
Companies below the threshold are not automatically off the hook
The Omnibus introduced a value chain cap. An in-scope company cannot require a value chain partner with 1,000 employees or fewer to provide more than the voluntary reporting standard (based on VSME) asks for. The cap does not cover gross Scope 1, 2 and 3 greenhouse gas emissions metrics, and it applies from financial year 2026.
In practice, suppliers, investees and borrowers will still be asked for data, but the requests should be shaped by the voluntary standard. If you sit in an in-scope company, plan your supplier data requests around that cap from the start.
What the report covers
The sustainability statement covers environmental, social and governance topics. The revised ESRS keep the same twelve standards: two cross-cutting standards, five environmental standards (climate, pollution, water, biodiversity and ecosystems, resource use and circular economy), four social standards and one governance standard. A topic is reported only if it is material.
What the revised ESRS change
The Commission reports that mandatory datapoints fall by more than 60% and total datapoints by more than 70% compared with the original ESRS, and estimates about 30% lower reporting cost per company. The topics stay the same; the way you decide and justify what to report changes.
Two cautions. First, flexibility moves the burden of justification onto you: every use of a proxy, exclusion or immateriality conclusion needs a written rationale. Second, the revised ESRS are expected to enter into force in November 2026 after scrutiny, so check that the final published text matches the version summarised here.
Double materiality: where the work starts
Double materiality is retained in the revised ESRS. A topic is material if it matters for your impact on people and the environment, or for the risks and opportunities that affect your business, or both. Everything else in the report follows from this list.
For biodiversity, the assessment has a special difficulty: the answer depends on place. A quarry beside a protected wetland and an office in a city centre do not have the same impact, even in the same company. A sensible sequence for sustainability teams:
- Reopen your existing assessment. Check it against the revised ESRS 1, especially the new treatment of mitigation, positive impacts and opportunities.
- Choose top-down, bottom-up or both. For a company with many sites and a long value chain, a top-down screen of sectors, geographies and sourcing regions can focus effort before detailed work starts.
- Screen your locations early. List every site and major sourcing area with coordinates, and check them against protected and recognised biodiversity areas before deciding that biodiversity is not material.
- Separate impacts from dependencies. Impacts on nature (land use, water, pollution) and dependencies on ecosystem services (pollination, water supply, flood protection) feed different parts of the assessment.
- Write down the thresholds and judgments. Assurance providers will ask why a topic was judged material or immaterial and how severity and likelihood were rated.
- Set a yearly review trigger. New sites, suppliers, acquisitions or data should prompt a check.
The revised E4 does not require one specific method. Frameworks such as the TNFD's LEAP approach or Science Based Targets for Nature can structure the work, but the report should explain whichever approach you actually used.
Biodiversity under ESRS E4
The revised ESRS E4 has five disclosure requirements, and only one of them, the metrics, applies in every case where biodiversity is material. The others ask you to describe what you already have in place. It applies only if biodiversity and ecosystems are material for your company.
E4 covers four 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. Climate and pollution drivers are reported under E1 and E2, but their impacts on nature belong in E4. The standard takes account of the Kunming-Montreal Global Biodiversity Framework, the EU Biodiversity Strategy for 2030, the Birds and Habitats Directives and the Nature Restoration Regulation.
Many existing guides and early reports follow the original E4, which had six disclosure requirements, with E4-6 covering anticipated financial effects. Map your disclosures to the revised numbering, not to older checklists.
Sensitive areas and what "near" means
The standard does not set a distance. Whether a site outside a sensitive area counts as near it is determined by defining the site's area of influence. You can use buffer distances specific to your type of activity, based on regulation, science-based recommendations or industry practice. Choose the distances, document the reasoning, and apply them consistently.
How much detail on sites
An exhaustive list of every site is not expected. You may group sites by the same sensitive area or by a cluster of areas in a region, provided grouping does not hide material information. Screen every site, then report the ones that matter.
Which metrics
No single metric is imposed. The guidance says primary data on the state of nature, collected at location level or through remote sensing, is the best means of determining impacts, especially near sensitive areas. You may also use data on impact drivers or secondary data on the state of nature. When choosing, consider the monitoring frequency, the baseline value and year, and whether the metric lets users understand how it relates to the material impact.
If you describe your material impacts, indicate which concern land degradation, desertification or soil sealing, and operations that affect threatened species or ecosystems.
ESRS E4 and TNFD
If you already use the TNFD recommendations, most of the work carries over. The LEAP approach maps onto E4 roughly as follows:
The difference is mandate: TNFD is voluntary and investor-oriented, while E4 applies whenever biodiversity is material and is subject to assurance. TNFD and EFRAG have published a correspondence mapping for the original ESRS.
Learning from filed reports
Sustainability statements already filed by early reporters, such as voestalpine and Covestro, show how companies handled E4 in practice. Read them as examples of structure and evidence, keeping in mind that they were prepared under the original ESRS.
From site list to E4 metrics
A credible E4 metric set rests on three questions: where are our sites relative to sensitive natural areas, what do our activities do to nature there, and what do we depend on. The route from data to disclosure has six steps, and each one needs an owner.
- Build the location register. Site name, type, coordinates or boundary, and the activity carried out. Add major sourcing areas where materials drive your impacts.
- Define the area of influence. Set buffer distances by activity type and document the source for each.
- Screen against sensitive areas. Check both legally protected areas (such as Natura 2000 sites and UNESCO World Heritage sites) and areas recognised for ecological importance without legal protection (such as Key Biodiversity Areas), and record the name and type of each area touched.
- Link activities to impacts. For each site in or near a sensitive area, state which of your activities relate to material negative impacts.
- Choose metrics per sub-topic. Pick the indicators that match your material impacts, with unit, method, source, baseline and monitoring frequency.
- Record limits. Note resolution, coverage, uncertainty, proxies used and what the number cannot tell a reader.
Step 6 matters most for assurance. An indicator is evidence of what it measures, not of the larger story it invites.
Common starting points for the data:
- IBAT for Key Biodiversity Areas around sites. An IBAT licence is required to see the WDPA indicator and can be available via Landler.
- IUCN Red List species. Available in Landler via the Threatened-species presence indicator, using GBIF occurrence records linked to IUCN Red List threat categories.
- EEA Natura 2000 data for EU protected sites. Most Natura 2000 sites are available via the IBAT license providing the WDPA indicator.
- UNESCO World Heritage List for natural and mixed sites.
- ENCORE for sector-level impacts and dependencies, useful in a top-down materiality screen. Landler uses ENCORE as the basis for its Compliance & Disclosure Module (coming out soon). Ask our team for a preview demo.
- Remote sensing for habitat extent, land-use change and deforestation at location level.
The route from indicator to disclosure should keep the method, resolution, period, geography, coverage and uncertainty attached. Where direct data is not available, the ESRS allow estimates and proxies, provided you explain method, sources and baseline. A first version built from site addresses and revenue by activity is a reasonable start that can be refined with purchase volumes or site data later.
The tone shift: from ambition to evidence
Sustainability reports used to reward warmth and scale. The revised ESRS push the other way. They discourage information that is not material, require fair presentation, and limit opportunities to those you are actually pursuing. A defensible disclosure reads less like a campaign line and more like a well-written caption: what was measured, where, when, by what method, and what it does not cover.
This is also an advantage. A statement tied to a place, a period and a method is easier to assure, harder to challenge and more useful to an investor than a broad promise.
The examples below show a direction, not approved wording. Each real disclosure still needs its own evidence and review.
A useful test before any sentence goes into the report: is it material, is it linked to the right location or activity, was the evidence in place before publication, does the wording match the evidence in time, geography and method, and can a reader find the limits? A result can be real without supporting the larger story a headline implies.
Where CSRD meets CSDDD, EmpCo, EUDR, ISSB and your investors
CSRD rarely stands alone. The same location and supply chain data answers several rules at once, and inconsistency between them is a risk in itself.
The practical rule is one register of locations and one evidence file per claim, owned by the sustainability team and used by reporting, marketing, procurement and investor relations alike.
How The Landbanking Group can support you
ESRS E4 reporting
Through Landler, The Landbanking Group helps sustainability teams turn evidence from their own sites into a structured basis for ESRS E4 reporting. Site onboarding, location screening, nature baselines and portfolio comparisons bring boundaries, indicators, methods and limitations together in one shared record.
Our team uses this evidence, together with client-provided policies, actions and targets, to prepare an ESRS E4-aligned Disclosure Report. Landler supports the biodiversity component of double materiality and disclosure preparation; it does not replace the company’s enterprise-wide materiality assessment, reporting controls, external assurance or legal advice.
Other nature-related disclosures
The location register, screening results and indicators you build for E4 are not single-use. The same evidence can answer many of the other requests sustainability teams receive, from voluntary frameworks to regulation and investor questionnaires. Landler keeps it in one record, so each disclosure draws on the same boundaries, methods and limits instead of a new round of data collection.
Typical reuses include:
- TNFD. The Locate and Evaluate phases of LEAP rely on the same site screening and impact and dependency data.
- EUDR. Plot-level geolocation and deforestation monitoring for in-scope commodities.
- GRI 101: Biodiversity. Location-level reporting on sites and their impacts on biodiversity.
- Investor and lender requests. For example, the SFDR indicator on activities negatively affecting biodiversity-sensitive areas, and biodiversity questions in CDP and bank questionnaires.
- CSDDD. The same impact identification and location data can support due diligence when it applies.
Which of these apply depends on where you operate, what you source and where you sell. Pathfinder maps that footprint against nature-related laws, reporting duties, funding schemes and voluntary standards, so you can see which instruments may apply to you before planning the data work. Treat the results as a starting point for review, not legal advice.
Try Pathfinder to see which other disclosures may apply to you.
The pre-submission checklist
Before approving the biodiversity section of a sustainability statement, confirm:
- Scope has been re-checked against the post-Omnibus thresholds and the national transposition law.
- The double materiality assessment was reviewed against the revised ESRS 1 and the rationale is written down.
- If biodiversity is judged immaterial, the screening and thresholds behind that conclusion are documented.
- Every site and major sourcing area is in one location register with coordinates or boundaries.
- Buffer distances for the area of influence are defined, justified and applied consistently.
- Sensitive areas were checked across both legally protected and scientifically recognised categories, and the date of the screening is recorded.
- Each metric states unit, method, source, baseline year and monitoring frequency.
- Proxies, estimates and exclusions are disclosed with their rationale.
- Where the transition plan is mentioned, its key features are public by the time the report is released.
- Offsets, if used, are described with aim, financing, area, type, quality criteria and standards, and are kept separate from measured reductions.
- Wording matches the evidence in time, geography and boundary, and implies no causation without attribution evidence.
- Non-material information is either removed or clearly labelled.
- Figures are consistent with the financial statements, EmpCo-relevant marketing claims and EUDR submissions, or differences are explained.
- Sustainability, finance, legal and marketing reviewers approved the same final wording.
- Each datapoint has an owner, a source file and a review date for the assurance provider.
- Suppliers receive data requests within the value chain cap, with Scope 1, 2 and 3 emissions treated separately.
Frequently asked questions
Is CSRD still mandatory after the Omnibus?
Yes, for companies above the new thresholds. The Omnibus narrowed who reports and when, but did not make reporting voluntary for companies in scope.
What are the new CSRD thresholds?
More than 1,000 employees on average and more than €450 million net turnover. Non-EU groups report at group level if they have more than €450 million EU turnover and an EU subsidiary or branch above €200 million.
Does CSRD apply to UK or US companies?
It can. They are treated as non-EU companies and can be caught through an EU listing, EU subsidiaries above the thresholds, or the group-level test for non-EU parents.
Is biodiversity reporting mandatory under CSRD?
Only if biodiversity and ecosystems are material under your double materiality assessment. If they are, E4-5 metrics are required, and the other E4 requirements ask you to describe what you have in place. If a topic is judged not material, the conclusion and its rationale should be documented, because assurance providers can ask for them.
Do we need a biodiversity transition plan?
No. E4-1 asks for the key features of a plan only if you have one in place and have made those features public. It does not require you to create one.
What if we do not have measured data yet?
The ESRS allow estimates and proxies where direct data is not available, particularly for the value chain. You need to explain the method, sources and baseline, and, for the first three reporting years, what you did to obtain better information. Primary data at location level or from remote sensing is described as the best means of determining impacts, especially near sensitive areas.
Is remote sensing enough?
It can be strong evidence for what the chosen indicator, resolution, geography and period actually measure. Whether it is sufficient for a given disclosure depends on materiality, uncertainty, the link to your operations or products, and what your assurance provider accepts.
Can we report additional voluntary sustainability information?
The revised ESRS generally prohibit reporting non-material disclosure requirements, datapoints and entity-specific information, with exceptions such as information required by other legislation or drawn from recognised frameworks. Anything included on that basis must be clearly identified and must not obscure material information.
Does our supplier below 1,000 employees have to answer all our questions?
No. For value chain partners with 1,000 employees or fewer, you cannot require more than the voluntary standard asks for, except for gross Scope 1, 2 and 3 emissions metrics. Suppliers may still choose to provide more.
Does CSRD require assurance?
Yes, the sustainability statement is subject to external assurance. Check the current assurance level and any Commission guidance for your first reporting year.
We are outside the new scope. Should we stop preparing?
Probably not. Investors, banks and customers may still ask for the same location and nature data, and the voluntary standard gives a shape for what to share. A first screening of your locations is a low-cost way to be ready.
Who should own CSRD biodiversity reporting?
One accountable owner, usually in sustainability, with defined roles for finance (consistency with the financial statements), legal (national rules and wording), operations (site data), procurement (supplier data) and marketing (public claims). Senior management should resolve data and resource gaps rather than letting the reporting calendar decide them.
Sources and further reading
- EUR-Lex: Directive (EU) 2026/470 (Omnibus I), Official Journal of 26 February 2026
- EFRAG Knowledge Hub: revised ESRS E4, Commission Delegated Regulation of 3 July 2026
- Cooley: European Commission adopts revised EU CSRD reporting standards, 21 July 2026
- Linklaters: EU CSRD after the Omnibus, what has actually changed and what has not, 13 August 2026
- EY: European Commission adopts revised ESRS for sustainability reporting, 23 July 2026
- Anthesis: The ESRS are final, 22 September 2026
- Darwin: ESRS E4 after the July 2026 revision, 23 September 2026
- The Landbanking Group: EmpCo guide for marketing teams
- European Commission: CSRD delegated and implementing acts