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

Disclosure Requirement E4-2

Policies

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

19datapoints↓ 6claims to verify↓ 5evidence areas↓ 3report examples↓

Disclosure focus

This disclosure asks an organisation to explain the policies it has in place to address biodiversity and ecosystems impacts, dependencies, risks and opportunities. In practice, the report should show whether those policies are formal, who they apply to, and what areas they cover, rather than only describing a few isolated initiatives or a flagship site.

The practical focus is on the breadth and substance of policy coverage across the business. Readers should be able to see whether the policies apply to the whole organisation, specific operations, sites, supply chains or activities, and how they guide day-to-day decisions and management. The aim is to understand how biodiversity and ecosystems considerations are built into governance and operations, not just stated as a general commitment.

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 settled which policy or policies you will describe, and what business area they sit in? Have you fixed the practical reach of each policy — which operations, sites, products, materials, suppliers, and upstream or downstream links are included? Have you agreed what the policy is trying to achieve, in plain operational terms? Have you checked whether any sites, activities, or supply links fall in or near sensitive nature areas, and whether that changes the policy coverage? Have you decided whether your approach covers land, sea, or forest-related impacts, and whether any scenario work is being used to shape it? Can you trace every statement back to a named source, and have you confirmed the definitions and cut-off basis you are using are the ones your organisation will stand behind?

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner

Policy title Record the exact name used for the policy in internal documents and external reporting. Approved policy register, board paper, or published policy document. Sustainability / policy team

Policy coverage Describe what the policy applies to, including the activities, entities, or topics it is meant to cover. Policy text, scope statement, or internal governance note. Sustainability / policy team

Policy aims Set out the intended outcomes or purposes the policy is designed to achieve. Policy document, strategy paper, or approval memo. Sustainability / policy team

Ecosystem and species coverage Capture the number or extent of ecosystems and species covered by the reported measure, using one consistent counting basis. Biodiversity assessment, site survey, or environmental inventory. Environment / biodiversity team

Traceability controls Describe the controls used to follow materials through the chain, such as tracking, tagging, or chain-of-custody steps. Traceability procedure, supplier standard, or audit trail records. Supply chain / procurement

Tracked materials List the materials that are included in the traceability approach, using the same material categories as the operating process. Material master, sourcing policy, or supplier specification list. Supply chain / procurement

Supply chain reach State which parts of the supply chain are included, for example direct suppliers, upstream tiers, or specific sourcing routes. Supplier mapping, sourcing policy, or procurement scope note. Supply chain / procurement

Sensitive-area sites Identify the sites that sit in or close to protected, high-value, or otherwise sensitive locations. Site register, GIS map, or environmental screening output. Environment / site operations

Policy reach Explain which sites, operations, or activities are covered by the policy in relation to those sensitive locations. Policy scope note, site register, or environmental management plan. Environment / site operations

Influence area Describe the surrounding area where the organisation’s activities could affect nature, people, or local conditions. Impact assessment, site study, or environmental baseline report. Environment / site operations

Land use flag Confirm whether land use is relevant for the reporting period or activity set, using a simple yes/no basis. Impact screening, project register, or environmental review. Environment / sustainability reporting

Ocean impact flag Confirm whether ocean-related impacts are relevant for the reporting period or activity set, using a simple yes/no basis. Impact screening, project register, or environmental review. Environment / sustainability reporting

Deforestation flag Confirm whether deforestation is relevant for the reporting period or activity set, using a simple yes/no basis. Commodity sourcing review, risk screening, or supplier assessment. Supply chain / sustainability reporting

Scenario analysis use State whether scenario analysis was used in the reporting period, on a yes/no basis. Climate or nature risk assessment, planning paper, or board pack. Risk / strategy

Scenario type Name the kind of scenario approach used, such as the planning frame or risk pathway selected. Scenario analysis report, risk model note, or strategy paper. Risk / strategy

Scenario outputs List the outputs from scenario analysis that were used in decision-making or reporting, such as risk ratings, forecasts, or planning assumptions. Scenario report, decision paper, or management presentation. Risk / strategy

Buffer distance State the distance used to define the protective or screening buffer around relevant sites or features. GIS settings, environmental methodology note, or site screening tool. Environment / GIS

Buffer method Explain how the buffer was set, including the rule, tool, or calculation approach used. Methodology note, GIS procedure, or technical appendix. Environment / GIS

Impacted sites List the sites identified as affected by the buffer or screening exercise. Site register, GIS output, or impact assessment table. Environment / site operations

＋ Show E4-2 sub-elements (LRA working checklist)

How to prepare it

1Set the boundary first. Identify the policy by name, then state what it is meant to achieve and where it applies. Make clear whether it covers land use, marine matters, and forest loss, and note the business areas, sites, or activities included in the review.

2Define the coverage terms you will use. Explain which ecosystems and species are counted, and record the supply chain reach, the materials in scope, and any traceability methods used to follow them through the chain.

3Gather the supporting records before drafting. Pull together site lists, maps, internal policy documents, supplier records, monitoring outputs, and any other source material that shows which locations are inside or close to sensitive areas and which operations are affected.

4Prepare the figures and narrative in a single working file. Enter the required yes/no responses, then write the supporting text for the policy scope, the area of influence, the scenario use details if relevant, the scenario type, the outputs relied on, and any buffer distance and method used to identify affected sites.

5Explain any exclusions, assumptions, or changes in approach. If a site, material, ecosystem, or species is left out, or if the method differs from a prior period, state that clearly so the reader can see what changed and why the reported coverage is what it is.

6Check the draft against the official source before sign-off. Confirm that every required item is answered, the wording matches the underlying evidence, and the final submission reflects the source material rather than a reworked summary.

Request the data

Request the biodiversity policy details and supporting evidence

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

What policy wording, coverage and supporting methods do we need to describe how the organisation manages nature-related impacts and dependencies?

Use your organisation’s own policy and site-management language first, then map it to the reporting fields. If your teams use different terms for habitats, protected areas, sourcing controls, or site screening, keep those terms in the request and in the evidence pack, and only translate them at the reporting stage. This is a possible LRA training template; adapt it to your organisation and check the source material before sign-off.

Weak request

Please provide the ESRS E4:E4-2 policy disclosures, including all required datapoints and the relevant narrative for the standard.

Why it fails: It uses framework language instead of the organisation’s own operational terms, so the owner has to translate the ask before they can respond. It also does not tell them which systems, site lists, policy documents, or screening methods to pull from, so the response is likely to be incomplete or inconsistent.

Better request

Please send the current nature or land-stewardship policy and the supporting evidence for [period]: policy name, what it covers, what it is trying to achieve, which habitats/species or site types it applies to, how you track relevant materials, which sites sit in or near sensitive areas, what those sites are covered by, how far your screening reaches, what method you use, whether you use any scenario work and what outputs feed decisions, and the list of affected sites. Use your team’s own terms and include the source file or system for each item.

Formal email template

Subject: Request for nature-policy evidence and site screening details

Hi [name/team],

We are preparing the sustainability reporting pack and need your help with the nature-related policy evidence for [reporting period].

Please send the current policy or equivalent document, plus the supporting details for the areas below, using your own team’s wording where possible:
- policy name and version
- what it covers and what it is meant to achieve
- which sites, activities, materials, or supply chains it applies to
- how you identify or track relevant materials or locations
- any screening used for sites close to sensitive areas
- whether you use any scenario work, and if so, what type and what outputs are used
- any buffer distance or other rule used in site screening, and the method behind it
- the list of affected sites, if applicable
- the source system or file location for each item

Please include the reporting period, boundary, and the owner for each item. If anything is not used, please say so clearly.

This is a possible LRA training template; adapt it to your organisation and check the source material before sign-off.

Thanks,
[preparer name]

Short Teams / Slack version

Hi [name/team] — we’re pulling together the nature-policy evidence for [period]. Could you share the current policy/equivalent doc and the supporting details on scope, objectives, covered sites/materials, traceability or screening, sensitive-area checks, any scenario work, buffer distance/method, and affected sites? Please use your team’s own terms. This is a possible LRA training template; adapt it to your organisation and check the source material before sign-off.

Industry examples

Food manufacturing

Context. The business sources agricultural inputs and operates processing sites near watercourses and mixed-use land.

Adapted request. Please share the current land and sourcing policy, plus the site-screening pack for [period]. We need the policy name, scope, objectives, which crops or raw materials it covers, how supplier traceability is handled, whether any sites are close to sensitive habitats or water areas, what screening distance is used, and the list of affected plants or depots.

Example response. Policy: Land and Responsible Sourcing Standard v2.1. Scope: farms, mills, and processing sites. Objectives: avoid conversion of sensitive land and improve supplier traceability. Materials covered: soy, palm, timber packaging. Traceability: supplier declarations and chain-of-custody checks. Sensitive-area sites: 4 processing sites within the screening radius of protected wetlands. Buffer distance: 5 km using GIS screening. Affected sites: Site A, Site C, Site F, Site H.

Mining and quarrying

Context. The business manages extraction sites, haul roads, and nearby land with ecological sensitivity.

Adapted request. Please send the biodiversity and land-management policy, plus the screening note for all active sites in [period]. We need the policy name, scope, objectives, which site activities it covers, how you identify nearby sensitive areas, whether any scenario work is used in planning, what outputs are used, the buffer rule for screening, and which pits, quarries, or support sites are affected.

Example response. Policy: Biodiversity and Land Management Procedure v4.0. Scope: active quarries, exploration areas, haul routes, and rehabilitation land. Objectives: reduce land disturbance and manage proximity to sensitive areas. Coverage: habitat protection and species checks around extraction sites. Scenario use: yes, land-use planning scenario. Outputs used: site selection review and rehabilitation timing assumptions. Buffer distance: 3 km from mapped sensitive areas. Affected sites: Quarry 2, Quarry 5, Exploration Block 7.

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

We based the draft on the collected policy and coverage fields, using the reporter’s own definitions for the policy, the materials and supply-chain boundary, the site and area-of-influence scope, and the yes/no flags for land, marine and deforestation topics, plus scenario use.

Context note

Taken together, these datapoints show how far the policy reaches across operations, supply chains and sensitive locations, and whether the organisation has identified coverage for land, ocean and deforestation-related matters.

Fluctuation statement

If any of these fields change from one period to the next, explain whether the shift reflects a broader policy scope, a revised boundary for sites or supply chains, or a change in how the organisation classifies the environmental topics it tracks.

Content index entry

E4-2 Policies — [location / page] / [notes]

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Preparation tools & forms

Professional preparation tools for E4-2 — 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 · E4-2

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 prepared the coverage figure from the policies we had formally approved during the reporting period, and we checked that each one was described with its main purpose, the impacts or risks it was meant to address, the parts of the business it applied to, any changes made this year, and any outside framework or initiative it was aligned to.An assurer may test whether the list is complete, whether the descriptions match the underlying policy documents, whether period-on-period changes were captured correctly, and whether any claimed alignment to external frameworks is supported.Approved policy register; board or committee papers; policy documents and revision history; mapping of each policy to the relevant impact/risk/opportunity; internal cross-reference showing scope and coverage; evidence for any stated external standard or initiative alignment; review notes showing the final wording was checked against source documents.

For sites we said were relevant because of their location, we based the statement on a site-by-site review and kept the working papers showing which locations were included, how we judged proximity or influence, and why each site was treated as in scope.An assurer may probe whether the site population is complete, whether the location test was applied consistently, whether the area considered around each site was reasonable, and whether any excluded sites were left out without support.Site inventory; maps or GIS outputs; location screening file; methodology note for the proximity test; list of included and excluded sites with reasons; internal approvals of the scope decision; supporting correspondence or consultant output where external input was used.

Where we referred to traceability arrangements, we checked that the description matched the actual controls in place, the materials covered, and the parts of the supply chain or downstream chain that the controls reach, and we retained the evidence behind that mapping.An assurer may challenge whether the controls described really exist, whether the materials and chain stages were identified correctly, and whether the wording overstates the practical reach of the process.Traceability procedure; supplier or product mapping; material list; value-chain scope analysis; control testing results; sample records showing the traceability trail; sign-off from the responsible team confirming the final description reflects the operating process.

When we said the policies covered land use, marine or coastal practices, or forest loss, we checked the source policy text and marked clearly which of those topics were actually addressed, rather than assuming coverage from general sustainability language.An assurer may look for unsupported claims that a policy covers a topic when it only mentions it indirectly, or for inconsistent treatment across different policies and business units.Policy text with topic tagging; issue-by-issue mapping matrix; legal or sustainability review notes; version-controlled extracts showing the exact clauses relied on; internal approval of the topic classification.

For the scenario work, we kept a record of whether it was used when shaping the policy set, the actions and the targets, and we documented the scenario type and the outputs that informed those decisions.An assurer may ask whether scenario analysis was actually used, whether the scenario type is described accurately, and whether the outputs cited were the ones that influenced the final policy choices.Scenario analysis report; workshop materials; decision papers showing how outputs fed into policy, action or target setting; list of scenarios considered; summary of outputs used; management review notes confirming the linkage.

For sites outside the designated sensitive locations, we used a documented method to decide which ones were close enough to matter, and we kept the working papers showing the method, the sites affected, and the distance bands or other thresholds applied.An assurer may test whether the distance or influence test was defined before use, whether it was applied consistently, and whether the selected sites really fall within the stated threshold.Methodology note for the closeness assessment; site list with calculated distances or influence zones; maps and buffer outputs; threshold rationale; exception log; reviewer sign-off on the final site set.

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

Figures are stated without the supporting narrative, or narrative without figures.Scope is inconsistent between the text and the numbers.The reporting boundary is left undefined.Material changes since the previous period are not disclosed.Estimates and measured values are not distinguished.Source records for the figures are not identified.

Common gaps

Mistakes to avoid when collecting the data

Wrong owner

The team asks the sustainability lead for a policy detail that sits with operations, procurement, or site management, so the answer comes from the wrong part of the business.

Framework language only

People ask for answers in ESRS-style terms instead of the organisation’s own wording, which makes staff guess how to translate the policy into day-to-day language.

No scope set

The data pull starts before everyone agrees which business units, sites, products, or activities belong in the population, so the figures and text are built on different boundaries.

＋ Show 5 more

Where judgement is often needed

Set the cut-off date for newly bought or sold operations

Choose one reporting date for the policy map, then explain whether newly acquired or disposed sites are included from the deal date, the period start, or the period end, and keep that approach consistent.

Handle different local meanings for the same habitat or species label

Where country teams use different legal or technical labels, map them to one internal business definition, state the mapping used, and note any places where the local meaning does not line up exactly.

Decide how to treat sites that sit partly inside the policy perimeter

If a site, supplier, or project only partly falls within the area covered by the policy, explain the rule used to include it, exclude it, or split it, and show how that rule was applied.

＋ Show 6 more

Examples

Illustrative examples

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

Illustrative (synthetic) example — Food processing

We keep a named biodiversity policy that applies across our own operations and the parts of our value chain where we can influence outcomes, with the aim of reducing pressure on habitats and species while improving restoration planning. It covers terrestrial and freshwater ecosystems, plus the species most exposed to our sourcing footprint; we also use traceability checks for palm oil, soy, cocoa and timber, apply them from direct suppliers back to the first tier of origin, and extend our site review to 18 locations, of which 6 sit in or close to sensitive areas and are covered by the policy’s controls across a 25 km area of influence. - We report that our policy addresses land, marine and forest impacts, and we use scenario analysis to test how our approach could perform under different nature-risk pathways. - For the synthetic figures: 18 sites reviewed, 6 in or near sensitive areas, 12 outside; 4 material groups under traceability, all 4 covered by first-tier supplier checks.

Illustrative only; shows how a reporter might describe a biodiversity policy, traceability, sensitive-area coverage and scenario use without naming the organisation.

Illustrative (synthetic) example — Consumer electronics assembly

Our nature policy is set for our manufacturing sites and the upstream materials we can influence, with the practical aim of limiting harm to habitats, water systems and vulnerable species while improving supplier controls. It focuses on freshwater and coastal ecosystems, covers species affected by mineral extraction and packaging inputs, and uses traceability for aluminium, copper, lithium and paper-based packaging from direct suppliers to smelter, mill or equivalent origin point; we reviewed 9 sites, including 2 in or near sensitive areas, and those 2 are within the policy’s active coverage across a 15 km influence zone. - We also state that the policy addresses land, ocean and forest impacts, and we test it with scenario work. - Synthetic figures: 9 sites total, 2 sensitive-area sites, 7 other sites; 4 material groups traced, all 4 covered through the stated supply-chain boundary.

Illustrative only; shows a different sector describing the same datapoints in a separate, internally consistent way.

Company reportsReal published reports

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How companies report E4-2 in practice

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

Sanoma Oyj

Education Services · Finland · 2025

Open report →

Sanoma Oyj's 2025 Annual Report provides partial coverage of biodiversity-related actions, noting that these apply to its own operations and upstream value chain, specifically concerning all paper used (p.101). The report references policies related to biodiversity and ecosystems and mentions actions and resources allocated, but does not clearly disclose specific targets or headline values (p.99-101). Several expected narrative and numeric disclosures on biodiversity are not found or remain unclear, indicating limited detailed reporting on this topic.

Assicurazioni Generali S.p.A.

Banks / Diverse Financials / Insurance · Italy · 2024

Open report →

Assicurazioni Generali S.p.A.'s 2024 Annual Integrated Report and Consolidated Financial Statements provides limited direct evidence on the disclosure, with no quotable narrative or numeric data explicitly addressing the topic throughout the report. Some references to policies related to biodiversity and ecosystems appear on pages 106, 139, 141, and 142, but these are not detailed in the evidence map. Additionally, there are mentions of greenhouse gas emissions data on page 123 and sustainability statements on page 177, yet no clear connection to the specific disclosure is found, indicating notable gaps in coverage.

Snam S.p.A.

Gas Utilities · Italy · 2025

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Snam S.p.A.’s 2025 Annual Report includes a reference to biodiversity and ecosystems policies and guidelines, specifically mentioning the Health, Safety and Quality Policy (HSEQ Policy) of Bioenerys Ambiente on page 252. The report also notes the allocation of financial resources related to biodiversity and ecosystems, with a figure of €4 million mentioned on page 347. However, the report lacks detailed narrative or numeric disclosures on biodiversity impacts, dependencies, or specific management actions beyond these points, with multiple sections showing no quotable evidence.

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Scenarios to work through

A manufacturer has one biodiversity policy covering its own sites, but the draft note only names the policy and says it applies group-wide. The team has not yet described what the policy is meant to achieve or whether it also reaches suppliers and contractors.

QWhat should the preparer do before finalising the policy note?

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A food company sources raw materials from several countries and has a nature policy that mentions traceability, but the draft only says 'we track materials' without saying which materials or how far back the checks go. The sustainability team is unsure whether to mention suppliers beyond tier 1.

QHow should the preparer decide what to include about traceability?

Reveal model answer →

A port operator has sites close to wetlands and coastal habitats. The draft policy note says the company 'supports nature protection' but does not say whether the policy covers those nearby locations or the wider area that could be affected by operations.

QWhat judgement should the preparer make about the policy coverage description?

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A forestry business has a policy on land management and deforestation, and the draft includes a yes/no flag for land use but leaves the other nature topics blank because the team thinks they are 'covered elsewhere'. The same draft also mentions that scenario analysis was used, but gives no detail on the type or outputs.

QWhat should the preparer check before sign-off?

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Framework references