ESRS E4 after Omnibus: biodiversity and ecosystems reporting under the amended ESRS (2026)
Disclaimer: New EUDR developments - December 2025
In November 2025, the European Parliament and Council backed key changes to the EU Deforestation Regulation (EUDR), including a 12‑month enforcement delay and simplified obligations based on company size and supply chain role.
Key changes proposed:
- New enforcement timeline: 30 December 2026 for large/medium operators, 30 June 2027 for small/micro operators
- Simplified DDS: One-time declarations for small and micro primary producers
- Narrowed scope: Most downstream actors and non‑SME traders would no longer need to submit DDSs
- New DDS requirement: Estimated annual quantity of regulated products must be included
These updates are not yet legally binding. A final text will be confirmed through trilogue negotiations and formal publication in the EU’s Official Journal. Until then, the current EUDR regulation and deadlines remain in force.
We continue to monitor developments and will update all guidance as the final law is adopted.
Key Takeaways
- ESRS E4 is the CSRD standard for biodiversity and ecosystems reporting, applying only when the topic is deemed material.
- Post-Omnibus, the December 2025 draft makes biodiversity transition plan disclosure conditional on one already being in place.
- Policies, targets, and actions only need to be disclosed if they already exist and are relevant to material biodiversity impacts.
- Coolset's platform helps companies run ESRS E4 materiality assessments and structure biodiversity disclosures for CSRD, book a free demo today.
In response to the EU's evolving sustainability reporting framework, ESRS E4 establishes the requirements for corporate biodiversity and ecosystems reporting under CSRD. This standard requires companies to assess their impacts and dependencies on biodiversity and to disclose how they are managing related risks and opportunities.
What is ESRS E4?
ESRS E4 — Biodiversity and Ecosystems — is the CSRD standard covering how a company affects and depends on biodiversity and ecosystem services. Key areas of disclosure include:
- Impacts of operations on biodiversity (land use, species loss, habitat degradation)
- Dependencies on ecosystem services (water, pollination, soil quality)
- Site-level biodiversity assessments for operations in or near sensitive areas
- Targets and actions to address biodiversity impacts
- Alignment with the Global Biodiversity Framework (GBF) and Kunming-Montreal goals
What changed under Omnibus
The Omnibus I Directive simplified ESRS E4 significantly. Key changes:
- Many data points previously mandatory are now conditional or optional
- Site-level reporting requirements simplified
- Biodiversity transition plan requirements reduced for companies outside the largest scope
Companies with 1,000+ employees and >€450M turnover still face meaningful E4 reporting obligations, but the overall burden is lower than originally specified.
How to approach ESRS E4
Biodiversity is one of the most challenging ESRS topics because data availability is low and methodologies are still developing. A practical approach:
- Start with materiality: Your DMA determines whether E4 is material. Many companies will find E4 material given global supply chains and land-use impacts.
- Map your value chain: Identify where your operations and supply chain intersect with sensitive biodiversity areas.
- Use sector-specific guidance: Different sectors (agriculture, food, textiles, construction) have different biodiversity footprints. Industry frameworks like TNFD provide sector-specific tools.
- Build toward site-level data: Even where Omnibus has reduced mandatory site-level requirements, best practice points toward granular geographic data for high-impact operations.
How Coolset supports ESRS E4
Coolset’s CSRD platform guides companies through the ESRS E4 requirements as part of the full ESRS data collection and reporting workflow. Book a demo to see how it works.
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