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ESRS E4: Biodiversity and Ecosystems · 2026-5010-final

Disclosure Requirement E4-1

Biodiversity Transition Plan

Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official EFRAG source.

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Reviewed by Dr Ross Kurinko · Sustainability Reporting Trainer LRA educational guidance · Not issued or endorsed by EFRAG

To prepare this disclosure

11datapoints↓ 6claims to verify↓ 5evidence areas↓ 3report examples↓

Disclosure focus

This disclosure asks an organisation to explain whether it has a biodiversity transition plan, and if so, what that plan is meant to achieve and how it is being put into practice. In plain terms, the report should show how the organisation is responding to biodiversity-related impacts, dependencies, risks and opportunities over time, rather than only describing isolated actions or one-off projects.

The practical focus is on whether the plan is embedded across the business and value chain, or whether it is limited to a few visible sites or initiatives. A useful explanation would cover the main actions, priorities, time horizon, and how progress is being managed and tracked in day-to-day operations, so readers can see if the plan is credible, organisation-wide and connected to real implementation.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official EFRAG source.

Before you start

A quick mental checklist before you prepare this disclosure — tick each as you settle it.

Have you actually got a biodiversity transition plan in place, or are you still deciding whether one exists at all? Which parts of the business does it cover: only your own sites and operations, or also suppliers, customers, and other parts of the wider value chain? Are the goals, actions, funding, and oversight arrangements already set out in a way you can trace back to a source document or owner? Have you checked whether the plan is meant to sit alongside your wider nature, climate, or other strategic commitments, and where any trade-offs need to be explained? If you are saying the plan is public, can you point to the place it is published, such as the website or a report?

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner

Transition plan flag Whether the organisation has a transition plan in place for the reporting period, recorded as yes or no. Approved strategy paper, board paper, or sustainability plan showing the plan status for the period. Sustainability / Strategy

GBF alignment A plain-language description of how the organisation’s approach lines up with the Global Biodiversity Framework, if applicable. Biodiversity strategy, target mapping, or internal alignment note linking actions to the framework. Sustainability / Biodiversity

Strategic biodiversity aims The organisation’s main biodiversity-related aims that sit within its wider strategy, stated in business terms. Strategy deck, annual plan, or board-approved sustainability priorities. Strategy / Sustainability

Boundary of coverage Which parts of the business and which upstream or downstream activities are included in the disclosure, stated clearly enough to show the reporting boundary. Reporting boundary memo, consolidation note, or scope statement used for the report. Reporting / Finance

Biodiversity targets The specific biodiversity targets the organisation has set, including what is being measured and the intended direction or end point. Target register, KPI sheet, or board-approved sustainability scorecard. Sustainability / Performance Management

Biodiversity actions The concrete actions the organisation is taking to deliver its biodiversity aims and targets. Action plan, project tracker, or implementation roadmap with owners and milestones. Sustainability / Operations

Funding plan The financial resources planned or allocated to support the biodiversity-related plan, including any budget or funding assumptions. Budget, business case, capex/opex plan, or finance approval paper. Finance / Sustainability

Governance setup How responsibility for the biodiversity plan is organised, including the roles of the board, management, and any committees. Governance chart, committee terms of reference, or board paper assigning oversight and delivery roles. Company Secretariat / Governance

Biodiversity trade-offs Any known tensions between biodiversity goals and other priorities, and how the organisation is handling those trade-offs. Decision papers, risk register, or strategy notes showing competing objectives and the chosen approach. Sustainability / Risk

Public disclosure flag Whether the relevant information has been made public, recorded as yes or no. Published report, website page, or filing record showing the disclosure status. Reporting / Communications

Disclosure location Where the public disclosure appears, such as the company website or a report, using the actual publication route. Live URL, published report copy, or filing reference. Reporting / Communications

＋ Show E4-1 sub-elements (LRA working checklist)

How to prepare it

1Set the reporting boundary first: decide which sites, activities and parts of the supply chain are in scope, then keep that boundary consistent across the whole response.

2Translate the plan into the required content blocks: confirm whether a transition plan exists, then prepare the statements on how it fits the biodiversity framework, the strategic aims, the targets, the actions, the funding approach, the governance set-up and any trade-offs you need to explain.

3Gather the source material behind each statement: board papers, management approvals, project plans, budgets, target trackers, action logs and any other records that support the narrative or figures you will report.

4Draft the disclosure in the order that suits your internal process, but make sure every required point is covered and that any yes/no item is answered clearly and any text item is specific enough to stand on its own.

5Record anything you leave out or change from prior reporting, including why it is excluded, what has moved in or out of scope, and whether the publication is available publicly and, if so, where it is hosted.

6Check the final wording against the official source before sign-off so the scope, content and publication details match the underlying requirement and no required item has been missed or misstated.

Request the data

Request the biodiversity plan evidence pack

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

Do we have a current, board-backed plan for how the business will reduce and manage its impacts on nature, and can we evidence the main elements behind it?

Use your organisation’s own terms first, then map them to the labels below. For example, if you talk about a nature plan, habitat plan, land stewardship plan, or site ecology roadmap internally, use that wording in the request and only translate it afterwards for reporting. Keep the ask in business language, not framework language, and check the source material before sign-off.

Weak request

Please provide the ESRS E4:E4-1 biodiversity transition plan, including alignment with GBF, strategic objectives, scope, targets, actions, financial plan, governance structure, trade-offs, and public disclosure channel.

Why it fails: This uses framework language that many operational teams will not use day to day, so it is harder to answer quickly and may miss the actual internal documents. It also bundles several reporting labels without telling the owner what business artefacts to pull together, which makes it less practical for evidence collection.

Better request

Please send the current nature plan or biodiversity roadmap for [reporting period], plus the supporting papers that show: what the plan is trying to achieve, which sites and activities it covers, the main milestones, the workstreams to deliver it, the budget or funding basis, who oversees it, any balancing decisions with other priorities, and whether a public version has been shared. Use your own internal wording, and we will map it to the reporting labels afterwards.

Formal email template

Subject: Request for biodiversity plan evidence for [reporting period]

Dear [name/team],

We are preparing the sustainability reporting pack for [reporting period] and need the current evidence for our nature-related plan.

Please send the latest version of the plan, together with any supporting papers or trackers that show:
- whether the business has a current plan in place;
- how it links to wider nature or environmental commitments;
- the main goals and milestones;
- the parts of the business and value chain it covers;
- the key actions, funding, and governance arrangements;
- any known trade-offs or balancing decisions, for example where nature work interacts with climate, land use, or other priorities;
- whether any public version has been shared, and where it was published.

Please use your team’s own terminology in the source material. We will map it to the reporting labels separately.

If helpful, you can return the information in the table below and attach the source documents.

This is a draft training request for internal use only; please check the source material before sign-off.

Many thanks,
[preparer name]
[team]
[contact details]

Short Teams / Slack version

Hi [name/team] — for the [reporting period] sustainability pack, could you share the latest nature/biodiversity plan evidence?

We need the current plan, scope, goals, actions, funding, governance, any trade-offs, and whether anything has been published externally.

Please use your own team terms in the reply and attach the source docs. We’ll map it for reporting after that.

Thanks, [name]

Industry examples

Manufacturing

Context. A multi-site manufacturer with quarries, factories, and supplier impacts wants evidence from the environment team and capital projects team.

Adapted request. Please share the current nature or land stewardship plan for our sites and key suppliers, including the goals, site-level actions, budget, governance, and any decisions where production, land use, or biodiversity priorities had to be balanced. If a public summary exists, include the link or publication reference.

Example response. Attached: Nature roadmap v3 dated 14 Mar 2025; approved by the executive committee; covers 12 sites and tier-1 raw material suppliers; includes restoration targets, watercourse protection actions, and a capex/opex summary; public summary published on the corporate website on 2 Apr 2025.

Retail / Consumer Goods

Context. A retailer with owned offices, distribution centres, and a supplier base needs evidence from sustainability, property, and procurement.

Adapted request. Please provide the current nature action plan covering our estates and priority suppliers, with the main objectives, delivery actions, funding, oversight, and any trade-offs with logistics, sourcing, or store development. Also confirm whether any version has been published externally and where.

Example response. Attached: Biodiversity and nature action plan 2025-2028; owner Sustainability Director; covers distribution centres, head office, and selected agricultural suppliers; includes supplier screening, habitat enhancement at sites, and a programme budget; no public publication yet.

Draft your disclosure

Notes that turn data into a disclosure

LRA training templates — adapt them to your organisation, and check the official source before sign-off.

Method note

State how the reporter defined the biodiversity plan, what was counted as in scope, and which internal sources were used to confirm the plan’s aims, actions, funding, oversight, and public release.

Context note

Explain what the figures show about how far the organisation has moved from intent to implementation, including whether the plan is limited to operations or also reaches into the value chain, and whether it is aligned to the broader biodiversity framework.

Fluctuation statement

If the reported position has changed, note whether the shift reflects a new or updated plan, a wider or narrower scope, revised targets or actions, changes in funding, or a different publication route.

Content index entry

E4-1 Biodiversity Transition Plan — [location / page] / [notes]

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Preparation tools & forms

Professional preparation tools for E4-1 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI-assistant.

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01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧

Go deeper · E4-1

Learn to prepare this disclosure end-to-end

This guide covers one Disclosure Requirement. The ESRS / CSRD Reporting course walks the full European workflow — double materiality, datapoints, evidence and assurance — with exercises on your own data.

Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.

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Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check

We limited the coverage figure to the sites, activities and parts of the business we actually reviewed for this plan, and we can show why anything outside that boundary was left out.The assurer may find the scope was chosen to make the figure look stronger, or that excluded parts were still material to the plan.Scope memo, boundary map, list of included and excluded entities/activities, rationale for exclusions, sign-off from the preparer and reviewer.

We prepared the summary around the business changes we say the plan is meant to drive, and we can trace that link back to our internal strategy papers.The assurer may question whether the stated direction of travel is genuinely tied to the company’s wider strategy, rather than added after the fact.Strategy documents, board papers, transition-plan draft history, cross-reference showing how the plan links to business model and strategy changes.

We have an approved transition plan in place, not just a draft or concept note, and the version used for the statement was the current one at the reporting date.The assurer may doubt whether a formal plan existed at the cut-off date, or whether the disclosed version was outdated.Approved plan document, approval minutes, version control log, effective date, evidence of periodic review or refresh.

We included the plan’s goals, main actions, funding assumptions and oversight arrangements because those were the elements we had documented and could support.The assurer may test whether the summary is complete, whether the chosen elements are consistent with the underlying plan, and whether any unsupported claims were omitted or overstated.Plan pack, target register, action tracker, budget or financing papers, governance chart, committee terms of reference, consistency check between the statement and source records.

Where the plan contains more than one objective, we checked for clashes and reinforcing effects before publishing, and we kept a record of how we handled them.The assurer may probe whether tensions between objectives were identified honestly and whether the treatment of those tensions was documented rather than implied.Trade-off analysis, workshop notes, decision log, risk register, management review comments, evidence of how conflicting objectives were resolved or explained.

We made the key points available through public-facing channels before, or at the same time as, the sustainability statement was released.The assurer may test whether the information was genuinely public in time, and whether the channel used was accessible to external users.Website screenshots, publication timestamps, archived web pages, press release or investor-relations posting, evidence of public access and release timing.

Evidence pack to prepare

The governing policy or written commitment behind this disclosureA methodology / definition note setting out how the disclosure was scoped and preparedSource-system exports the figures or facts were drawn fromThe internal approval / sign-off record for the disclosure before publicationMinutes or records evidencing the relevant engagement or consultation

Common reporting gaps

The information is presented without a date or as-at point.The scope or boundary of the statement is left undefined.Key terms are used inconsistently across the report.Material changes since the previous period are not disclosed.Assertions are made without supporting detail or a source record.Boilerplate is used that does not actually answer what is asked.

Common gaps

Mistakes to avoid when collecting the data

Wrong owner

The request goes to the wrong team or person, so the answer is built from the wrong operational records instead of the group that actually runs the plan.

Framework language only

People ask for the information using reporting jargon, and the business cannot map it back to its own project, programme, or workstream names.

Scope left vague

No one pins down which sites, activities, or supply-chain parts are in or out, so different teams collect different slices of the same topic.

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Where judgement is often needed

Acquisition and disposal cut-off

Set a clear cut-off date for adding or removing sites, assets and activities, explain whether the plan reflects the opening or closing group structure, and note any material changes from deals completed near period end.

Different local naming for the same habitat or species

Where country teams use different labels or classification systems, map them to one internal grouping, explain the mapping used, and disclose any places where local practice could not be translated cleanly.

Borderline activities near the plan boundary

For operations or suppliers that sit just inside or just outside the chosen scope, state the rule used to include or exclude them and explain any material borderline cases separately.

＋ Show 5 more

Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — Food manufacturing

We have set out a biodiversity transition plan for our own sites and key suppliers, and we say it is aligned with the Global Biodiversity Framework. The plan explains our main aims, the actions we will take, the funding we have set aside, the board and committee oversight, and the trade-offs we are managing between lower-carbon sourcing, land use and habitat protection; we also publish it on our website and in our annual report. - Our plan covers both operations and the value chain, with targets for habitat restoration, pesticide reduction and supplier screening. - Delivery is led by the sustainability team, reviewed by the risk committee, and approved by the board; the finance plan is ring-fenced within our medium-term capital programme.

Illustrative only: shows a plain-language narrative that covers whether a plan exists, how it links to the global biodiversity framework, what it is trying to achieve, where it applies, the targets and actions, how it is funded, who oversees it, the main trade-offs, and where it is made public.

Illustrative (synthetic) example — Utilities and infrastructure

We have published a biodiversity transition plan for our network assets and the contractors we rely on, and we describe it as consistent with the Global Biodiversity Framework. It sets out our priorities, the measures we will use, the budget we have allocated, and how the board, its committees and management will oversee delivery; it also explains the balance we are striking between network resilience, cost control and nature recovery. - The plan applies to our operations and selected upstream and downstream activities, with targets for protected-area avoidance, invasive-species control and supplier due diligence. - We disclose the plan on our website and in our sustainability report, alongside the governance map and the funding profile.

Illustrative only: shows a different sector using the same disclosure points in a separate narrative, including whether a plan exists, its link to the global biodiversity framework, its aims, scope, targets, actions, funding, oversight, trade-offs, and publication route.

Company reportsReal published reports

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How companies report E4-1 in practice

Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

bioMérieux S.A.

Healthcare Providers, Services and Technology · France · 2024

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bioMérieux S.A.'s 2024 Universal Registration Document includes a narrative on its transition plan and the consideration of biodiversity and ecosystems within its strategy and business model, as noted on page 126. The report references biodiversity pressures and related environmental topics on pages 125 and 102, indicating some contextual coverage. However, no further detailed or quotable evidence on specific biodiversity disclosures was found elsewhere in the report.

Enagás, S.A.

Gas Utilities · Spain · 2025

Open report →

Enagás, S.A.'s 2025 Annual Report includes references to its biodiversity and ecosystems strategy, mentioning a transition plan and consideration of biodiversity within its strategy and business model, notably on pages 83, 141, and 283. The report also points to material impacts, risks, and opportunities related to biodiversity, as indicated on pages 141 and 283. However, the disclosures are unclear and lack explicit detail or clear statements on these datapoints, with no direct or quotable evidence found for specific narrative items.

Aena S.M.E., S.A.

Air Transportation — Airport Services · Spain · 2025

Open report →

Aena S.M.E., S.A.’s 2025 Sustainability Report includes references to a transition plan and consideration of biodiversity and ecosystems within its strategy and business model, notably on pages 73 and 163, though these mentions do not constitute a clear or detailed disclosure of the specific datapoint (p.73, p.163). The report provides related context about material impacts, risks, and opportunities linked to biodiversity and ecosystems but lacks explicit, quotable evidence directly addressing the disclosure requirements (p.73). Several narrative items relevant to this disclosure are not found or remain unclear in the report, indicating gaps in comprehensive reporting on this topic.

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Scenarios to work through

A group has drafted a nature-related transition plan for its quarrying and packaging activities, but the draft only covers site operations and leaves out key suppliers that provide raw materials from sensitive habitats. The team is deciding whether the scope is broad enough for the disclosure.

QShould the plan description stay limited to owned sites, or should it also cover the wider supply chain where the business can influence impacts?

Reveal model answer →

A preparer has a draft plan with a headline goal to reduce pressure on habitats, but the actions are written as broad intentions such as “improve biodiversity performance” with no link to time-bound targets or named measures. Management wants to know whether that is enough for the disclosure.

QCan the plan be presented with general ambitions only, or does it need a clearer set of targets and actions that show how the ambition will be delivered?

Reveal model answer →

A finance team has prepared a nature plan with operational measures, but no one has linked it to funding, capex, or the internal budget cycle. The sustainability lead is unsure whether the financial side belongs in the disclosure.

QShould the plan explain how it is funded and embedded in financial planning, or is it enough to list the environmental actions alone?

Reveal model answer →

A company has a biodiversity plan that was approved by senior management, but the board only sees it once a year and there is no named committee or reporting line for oversight. The reporting team is deciding how much governance detail to include.

QDoes the disclosure need to show who oversees the plan and how it is governed, or is a simple statement that leadership supports it enough?

Reveal model answer →

Framework references