ESG investors
Asset managers, real-estate funds, asset-management companies — documenting portfolio biodiversity
For asset-management companies, article 8/9 SFDR real-estate funds, insurers, pension funds, biodiversity compliance is becoming a structuring axis. SFDR PAI 7 requires a quantified indicator. EU Taxonomy DNSH criterion 6 documents non-harm. France's article 29 LEC has required a detailed biodiversity strategy since 2022. TNFD provides a complementary international framework. NORMAXIS equips the documentation of this biodiversity layer via the proprietary BPS tool — operated by IRICE as an independent third party under ISO/IEC 17065, providing the opposability expected by the French AMF and auditors.
Positioning
Biodiversity is a critical infrastructure, not peripheral compliance.
Living soils, vegetation, water resources, local fauna form a natural capital that drives the resilience and value of real-estate assets over time. This capital deserves to be evaluated with the same rigour as energy or carbon — not as a marketing add-on.
The reality: current biodiversity evaluations suffer from a trust deficit. Too often, those who design and implement biodiversity strategies are also those who produce the evidence. For an opposable capital allocation — SFDR, Taxonomy, article 29 LEC, CSRD — this configuration no longer holds. The French AMF doctrine, like EU Directive 2024/825, requires verified, opposable data produced by an independent third party.
Three critical moments
Where biodiversity becomes an actionable financial risk.
Nature risk runs through the whole investment cycle. NORMAXIS structures evidence production at each of the three moments that bind allocations.
Moment 1
Pre-acquisition
Diagnostic of the target asset's initial ecological state, identification of sensitive areas (Natura 2000, ZNIEFF, wetlands), resilience assessment against pressures (climate, land take). Initial BPS scoring. Outcome: argued go/no-go, adjusted negotiation price.
Moment 2
Allocation decision
Regulatory validation of the allocation: DNSH criterion 6 biodiversity documented, SFDR article 8/9 coherence, Taxonomy objective 6 alignment, French article 29 LEC compliance. BPS attestation as independent third party under ISO/IEC 17065 — opposable evidence before the French AMF.
Moment 3
Post-acquisition
Long-term monitoring of the asset's biodiversity performance, continuous feeding of reporting (ESRS E4, PAI 7, article 29 report). Early detection of degradation. Protection of value over time — essential before any resale or refinancing.
2022-2026 regulatory shift
The window for voluntary schemes is closing.
The regulatory framework has changed profoundly between 2022 (start of article 29 LEC) and 2026-2027 (full application of EU Directive 2024/825 and article 35 of the French Climate Act). The asymmetry between voluntary and opposable evidence becomes decisive for legal security of allocations.
2022-2024
Voluntary schemes accepted
Labels (BREEAM, HQE, various certifications), agency ESG ratings, internal reports, public commitments. Sufficient as a baseline, but with limited opposability before the AMF, the sustainability auditor or an unfair-commercial-practice challenge.
2025-2026 and beyond
Opposable evidence required
Only ISO/IEC 17065 certification as independent third party produces legally opposable evidence. Risk: requalification of non-compliant portfolios during AMF / DGCCRF controls, retraction of claims, ESG-rating impact. The window to acquire ISO/IEC 17065 certification is closing fast.
Particular point on DNSH criterion 6 biodiversity: general environmental certifications (BREEAM, HQE) are insufficient on their own — they do not cover biodiversity with the granularity required by Taxonomy DNSH. A specific biodiversity assessment (BPS, Effinature) is essential to attest Taxonomy objective 6 alignment.
Your stakes
Four converging frameworks on the biodiversity axis.
SFDR — PAI 7 biodiversity
Mandatory indicator for article 8/9 actors: activities adversely affecting biodiversity-sensitive areas. By default data come from investee companies (if CSRD). For others, the manager must extrapolate or obtain voluntary data.
Taxonomy — DNSH criterion 6
To qualify an asset as aligned with an environmental objective, it must be demonstrated that it does not significantly harm biodiversity. DNSH criterion 6 documentation is particularly heavy for real-estate and land assets.
French article 29 LEC
For French asset-management companies with more than €500M AuM: obligation to publish a detailed biodiversity strategy aligned with Kunming-Montréal. Quantified indicators, dated action plan, articulation with PAIs. The AMF doctrine specifies expectations.
TNFD — LEAP
Voluntary international framework, expected by international institutional investors. LEAP approach (Locate, Evaluate, Assess, Prepare). Convergence with ESRS E4 — a BPS diagnostic can feed both frameworks simultaneously.
Our engagement
Portfolio diagnostic and opposable documentation.
Locate mapping (TNFD)
Systematic identification of portfolio assets in sensitive areas: Natura 2000, ZNIEFF I and II, Ramsar wetlands, IUCN protected areas, international KBAs. Direct feed to SFDR PAI 7 and Taxonomy DNSH criterion 6.
BPS scoring on material assets
For material real-estate and land assets, BPS diagnostic with 70+ criteria. IRICE attestation as independent third party under ISO/IEC 17065 — opposable before the AMF and auditors. Consolidation at fund level.
Regulatory documentation
Production of pieces: article 29 LEC report compliant with AMF doctrine, SFDR precontractual annexes, Taxonomy DNSH documentation per activity, TNFD report (LEAP, 14 recommendations). Methodological consistency across frameworks.
Repositioning strategy
Beyond reporting: allocation support (exit high-biodiversity-impact assets, enter Taxonomy-aligned assets), thematic biodiversity fund construction, articulation with Greenfin / ISR / Finansol labels.
ESG investor benchmarks
What the engagement covers.
4 frameworks
One portfolio diagnostic, four reports
SFDR · Taxonomy · French article 29 LEC · TNFD
ISO 17065
AMF-opposable third party
IRICE — certification of products, processes, services
LEAP
TNFD method
Locate · Evaluate · Assess · Prepare
AMF doctrine
Systematic alignment
2022-2023 biodiversity expectations
ESG investor FAQ
Frequently asked questions.
To go further
Related pages.
NORMAXIS
SFDR · Taxonomy · French article 29
The three financial regulations, their articulation, methodologies.
Découvrir
NORMAXIS
CSRD — sustainability reporting
The directive that produces the data SFDR consumes. NORMAXIS specialty.
Découvrir
Diagnose the biodiversity of a real-estate portfolio
BPS — Biodiversity Performance Score, 70+ criteria tool for ESG directions (CSRD ESRS E4, SFDR PAI, Taxonomy).
Découvrir
Equipping the biodiversity axis of your portfolio?
Diagnostic of assets in sensitive areas, BPS scoring per material asset, fund consolidation, production of article 29 / SFDR / TNFD reports, articulation with external audit and AMF doctrine.
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