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.
Preparation
Key datapoints to prepare
＋ Show E4-1 sub-elements (LRA working checklist)
Check whether the organisation’s approach is aligned with the Global Biodiversity Framework.
State whether the requirement covers the organisation’s own activities, its wider supply chain, or both.
Set out the biodiversity-related aims the organisation is pursuing.
Confirm whether a transition plan has been prepared.
Describe the actions the organisation will take to deliver the plan.
Explain how the plan will be funded.
Identify who oversees the plan and how responsibilities are arranged.
Set the biodiversity targets the organisation intends to meet.
Show how the organisation will handle any trade-offs between biodiversity and other priorities, such as climate.
Specify where the information is published, for example on the website or in a report.
Confirm whether the disclosure is made publicly.
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.
Industry examples
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]
Download Centre
Preparation tools & forms
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
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.
Wrong time basis
The data is pulled for the wrong period or cut-off date, which makes the figures and narrative refer to different reporting windows.
Mixed counting basis
One team counts by project, another by site or contract, and the final pack blends them together even though they are not comparable.
Source labels lost
The original file names, system tags, or document references are stripped away, so the reviewer cannot trace each figure back to its starting record.
Separate groups merged
Distinct populations that should stay apart are rolled into one dataset, which hides differences that matter for the final explanation.
No evidence trail
The pack arrives without the supporting metadata, approval notes, or sign-off history needed to show who checked the inputs and when.
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.
Timing basis for actions and targets
Choose one timing basis for milestones, spending and delivery dates, apply it consistently across the plan, and explain whether figures reflect commitments already approved, work underway, or future intentions.
Measured data versus estimates
Use direct measurements where available, estimate only where needed, and disclose which parts of the plan are based on estimates, the main assumptions behind them, and any known limits on reliability.
Rounding and small differences
Apply one rounding approach across the disclosure, state it if it affects totals or subtotals, and explain any small gaps caused by rounding so the narrative still ties back to the underlying numbers.
Privacy limits on site-level detail
If naming a location, supplier or project would expose personal or commercially sensitive information, group the data at a higher level, say why the detail is withheld, and keep the summary sufficient to understand the plan.
Cross-border differences in legal or ecological baselines
When local rules, protected-area definitions or ecological baselines differ by country, describe the basis used in each place, show how the organisation compared them, and explain any non-comparable elements.
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.
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
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
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
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 →Hide answer ↑The scope should be described in a way that makes clear whether it covers only the company’s own activities or also the parts of the value chain that matter to the plan. If suppliers or other upstream or downstream links are relevant to how the business will deliver the plan, they should be included in the explanation rather than left out.
Why this matters · Be clear about whether the plan reaches beyond direct operations into the value chain, where that is relevant to delivery.
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 →Hide answer ↑The plan should not stop at broad ambition. It needs a practical set of targets and actions that show what the organisation intends to do, how it will do it, and how those steps connect to the wider transition plan. Vague statements on their own do not give enough substance for a reader to understand the pathway.
Why this matters · A transition plan needs concrete targets and actions, not just a high-level aspiration.
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 →Hide answer ↑The plan should explain the financial side as well as the operational side. A reader should be able to see how the organisation expects to resource the actions, how those costs fit into planning and budgeting, and whether the financial picture supports delivery of the plan over time.
Why this matters · Show how the plan is backed by money and built into financial planning.
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 →Hide answer ↑A simple statement of support is not enough. The disclosure should explain the governance set-up around the plan, including who oversees it, how decisions are escalated, and how the board or its committees stay informed. That helps the reader understand whether the plan is actually controlled and monitored.
Why this matters · Describe the oversight structure so readers can see how the plan is governed and monitored.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
FAQ
Questions this page answers
How do I use the E4-1 Biodiversity and Ecosystems page to draft the disclosure from scratch?+−
Start with the plain-language explainer, then work through the step-by-step preparation section and the listed datapoints. The page is designed to help you turn those inputs into a draft narrative, with visualisation ideas, narrative starters and a content-index line.
What data do I need to collect for E4-1 Biodiversity and Ecosystems before I start drafting?+−
The page lists the datapoints to prepare, including the transition plan flag, GBF alignment, strategic biodiversity aims, boundary of coverage, biodiversity targets, biodiversity actions, funding plan, governance setup, biodiversity trade-offs, public disclosure flag and disclosure location. Use that list as your collection checklist before drafting.
How should I set the scope and boundary of coverage for the E4-1 biodiversity disclosure?+−
The page flags boundary of coverage as one of the datapoints to prepare, so you should define the reporting boundary before writing the narrative. The step-by-step preparation section is the place to align the scope with the rest of the disclosure inputs.
What should I include in the E4-1 biodiversity evidence pack for assurance readiness?+−
The page includes an evidence pack with five items to support assurance readiness. Use it alongside the six assurance claims to verify so you can link each claim to a clear source of evidence.
How do I use the six assurance claims on the E4-1 page to check my draft?+−
Treat the six claims as a review checklist: for each one, confirm the related risk and the evidence you can show. That helps you test whether the draft is supportable before it goes to assurance.
What are the common reporting gaps or mistakes to avoid in an E4-1 biodiversity disclosure?+−
The page has a section on common reporting gaps and mistakes, which you can use as a pre-submission quality check. Review it after drafting to spot missing datapoints, weak evidence or unclear wording.
How do I use the Prep & Assurance workbook for E4-1 Biodiversity and Ecosystems?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is intended to support preparation and assurance readiness. Use it to organise the datapoints, evidence and review steps before finalising the disclosure.
What is the printable Library Card for E4-1 and when should I use it?+−
The Download Centre also provides a printable Library Card in PDF format. It is a practical companion for keeping the disclosure checklist, evidence and draft outputs in one place during preparation.
Are there synthetic example disclosures for E4-1 Biodiversity and Ecosystems that I can copy as a drafting model?+−
Yes, the page includes synthetic illustrative example disclosures, including a quantitative data table. They are there to show how the disclosure can be presented, but they are examples only and should be adapted to your own data.
How can I turn my E4-1 biodiversity data into a draft narrative and content index line?+−
The draft-output section gives visualisation ideas, narrative starters and a content-index line to help you shape the final text. Use those prompts after you have completed the datapoints and checked the evidence pack.
Where can I find real company reports that show how biodiversity topics are disclosed?+−
The page has a 'From company reports' table that links to real published reports and the pages where the topic is disclosed. It is useful for seeing how others present the topic in practice, without treating it as a formal mapping.
More questions this page can help with
E4-1 Biodiversity and Ecosystems: what should I prepare before I ask data owners for inputs?E4-1 Biodiversity and Ecosystems: which datapoints belong in my first draft checklist?E4-1 Biodiversity and Ecosystems: how do I document the boundary of coverage in a way that is assurance-ready?E4-1 Biodiversity and Ecosystems: how do I assign ownership for the transition plan flag, targets and actions?E4-1 Biodiversity and Ecosystems: what evidence should sit behind the biodiversity trade-offs statement?E4-1 Biodiversity and Ecosystems: how do I use the assurance claims and evidence pack together?E4-1 Biodiversity and Ecosystems: what are the most common mistakes when completing the disclosure location field?E4-1 Biodiversity and Ecosystems: how do I use the workbook to track the public disclosure flag and disclosure location?E4-1 Biodiversity and Ecosystems: are the synthetic examples useful for building my own narrative starters?E4-1 Biodiversity and Ecosystems: where do I find the content-index line in the draft-output section?E4-1 Biodiversity and Ecosystems: how do I use the company report links without treating them as official guidance?E4-1 Biodiversity and Ecosystems: what should an assurance reviewer look for in the evidence pack?
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