Double Materiality | Fiegenbaum Solutions

Biodiversity in ESG: Regulatory Frameworks, Risks & Opportunities for 2030

Written by Johannes Fiegenbaum | 8/2/25 7:22 AM

Biodiversity in ESG is rapidly shifting from voluntary reporting to mandatory compliance. Companies must understand how integrating biodiversity into their ESG strategies affects financial risks, regulatory obligations, and competitive positioning. The Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES) reports over one million species face extinction, creating urgent pressure on businesses to act.

Key Takeaways:

  • CSRD/ESRS E4 Requirements: Mandatory reporting on biodiversity risks, dependencies, and targets under double materiality assessment
  • TNFD Framework: Practical implementation through the LEAP approach (Locate–Evaluate–Assess–Prepare) for nature-related financial disclosures
  • EUDR Compliance: Geolocation requirements for supply chains affecting raw materials like coffee, cocoa, and timber
  • Financial Materiality: The World Economic Forum estimates $44 trillion of global GDP—over half—depends moderately or highly on nature and ecosystem services
  • Integrated Strategy: Biodiversity targets must align with climate goals and transition plans for 1.5°C pathways

Addressing biodiversity isn't just environmental responsibility—it's economic necessity. Companies acting now strengthen both nature and their long-term viability whilst positioning themselves as leaders in an evolving regulatory landscape.

Regulatory Frameworks Shaping Biodiversity in ESG

EU Biodiversity Strategy and Nature Restoration Law

The EU Biodiversity Strategy for 2030 sets binding targets: protect 30% of land and marine areas, restore 30% of degraded ecosystems, and rehabilitate 25,000 km of free-flowing rivers. The EU Nature Restoration Law makes ecosystem restoration legally binding, requiring member states to restore at least 20% of EU land and sea areas by 2030.

Financial institutions and businesses rely increasingly on these frameworks to assess nature risks. Financial commitments include $200 billion annually for biodiversity protection and reducing harmful subsidies by $500 billion. These targets directly influence corporate strategy, supply chains, and investment decisions.

CSRD and ESRS E4: Double Materiality for Nature

The Corporate Sustainability Reporting Directive (CSRD) introduces mandatory reporting standards on biodiversity and ecosystem services through ESRS E4. Companies must disclose their strategies, biodiversity risks, opportunities, and measurable biodiversity targets based on double materiality assessment—both how nature affects business and how business affects nature.

ESRS E4 reporting requirements include 19 disclosure points covering dependencies, biodiversity impact, governance, and location-specific risks. This shifts biodiversity from environmental reporting into core financial planning and risk management frameworks. German companies affected increase from 550 to 15,000 under CSRD expansion.

CSDDD and EUDR: Supply Chain Due Diligence

The Corporate Sustainability Due Diligence Directive (CSDDD) extends biodiversity requirements throughout the "chain of activities." Companies must identify nature-related risks upstream and downstream, including invasive species introduction and habitat degradation from suppliers.

The EU Deforestation Regulation (EUDR) prohibits trade in products causing deforestation. Large companies must demonstrate compliance from December 2025, smaller ones from June 2026. This requires geolocalised plot-level data for raw materials like coffee, cocoa, palm oil, rubber, soy, timber, and cattle.

Practical implications: Businesses need polygon tracking systems, satellite monitoring, and supplier engagement programmes to prove zero-deforestation sourcing. EUDR compliance strategies demand new data infrastructure and supplier relationship management.

TNFD Implementation: From Concept to Practice

The LEAP Approach for Nature-Related Risk Assessment

The Taskforce on Nature-Related Financial Disclosures (TNFD) framework provides structured methodology for integrating biodiversity into financial decision-making. The LEAP approach guides companies through:

Locate: Identify interface with nature across own sites, upstream, and downstream activities. Map dependencies on ecosystem services and biodiversity impact across value chains.

Evaluate: Assess dependencies and impacts using metrics like Global Biodiversity Score (GBS), Corporate Biodiversity Footprint (CBS), and Species Threat Abatement and Restoration (STAR). Prioritise material locations based on sensitivity and operational footprint.

Assess: Evaluate nature-related risks and opportunities. Financial risks include physical risks (resource scarcity, ecosystem collapse), transition risks (regulatory changes, market shifts), and systemic risks (climate-nature interactions).

Prepare: Develop response strategies, set science-based targets, and integrate nature-positive actions into business strategy. Align with Science Based Targets Network (SBTN) methodologies for freshwater, land use, and biodiversity targets.

TNFD disclosure is becoming best practice amongst financial institutions and large corporates. Investors increasingly view TNFD alignment as essential rather than optional, particularly for sectors with high nature dependencies like agriculture, forestry, and resource extraction.

Integrating TNFD with CSRD Reporting

Companies subject to both TNFD and CSRD requirements should align processes to avoid duplication. TNFD's LEAP naturally feeds into ESRS E4 disclosure requirements:

  • Locate phase informs ESRS E4 site-level impact assessments
  • Evaluate provides data for double materiality analysis
  • Assess delivers risk management disclosures
  • Prepare connects to transition plans and CapEx allocation

This integrated approach ensures consistency between sustainability reporting and financial risk management whilst reducing administrative burden. ESG reporting integration creates efficiency and strengthens stakeholder trust.

Business Case for Integrating Biodiversity into ESG Strategies

Financial Materiality and Risk Management

Biodiversity loss poses direct financial risks. Since 1970, monitored wildlife populations declined by 73%. According to the World Economic Forum, economic values exceeding $44 trillion—more than 50% of global GDP—depend on nature and its services. When ecosystem services degrade, businesses face:

Physical Risks: Resource scarcity (water, raw materials), supply chain disruptions, operational constraints from ecosystem collapse, and increased insurance costs.

Transition Risks: Regulatory penalties, compliance costs, loss of market access, reputational damage, and shifting consumer preferences demanding sustainable practices.

Systemic Risks: Interconnected climate and biodiversity crises amplifying each other, creating compound risks that traditional risk models underestimate.

Only 5% of companies currently assess their biodiversity impact, and less than 1% understand their dependencies. This gap represents both risk and opportunity. Companies addressing biodiversity proactively gain competitive advantages through improved risk management and strategic positioning.

Opportunities Through Nature-Positive Strategies

Nature-positive business models create value whilst restoring ecosystems. Research shows 65% of Nature-based Solutions (NbS) projects deliver positive economic outcomes, particularly in nature-based agriculture and ecosystem management.

Nature-positive approaches offer multiple benefits:

  • Innovation: New products and services leveraging ecosystem services, circular economy models, and bio-based materials
  • Market Access: Meeting customer and investor requirements for sustainable sourcing, particularly for Article 8/9 funds under Sustainable Finance Disclosure Regulation
  • Resilience: Diversified supply chains, reduced dependency on degraded ecosystems, and adaptive capacity for climate change
  • Cost Efficiency: Lower resource costs through regenerative practices, reduced waste, and optimised natural resource use

Biodiverse forests store 50-70% more carbon than monocultures, demonstrating how biodiversity targets strengthen climate goals. Integrating biodiversity and climate strategies creates synergies rather than trade-offs.

Practical Steps for Biodiversity Integration

Conducting Materiality Assessment

Start with thorough assessment of biodiversity dependencies and impacts. Analyse how production processes, products, and supply chains affect species diversity, soil health, water quality, and natural habitats. Consider:

  • Direct Operations: Land use on own sites, pollution from facilities, water extraction, and habitat fragmentation
  • Upstream: Raw materials sourcing, supplier practices, deforestation risks, and ecosystem degradation in procurement regions
  • Downstream: Product use impacts, waste management, end-of-life considerations, and invasive species risks

Landscape-based approaches focusing on procurement regions enable better understanding of regional ecosystem characteristics. Digital tools and habitat mapping guides support practical implementation of biodiversity risk assessments.

Setting Science-Based Biodiversity Targets

Measurable targets are crucial for effective biodiversity management. Companies should align with international frameworks whilst addressing material impacts:

  • SBTN Targets: Use Science Based Targets Network methodologies for land, freshwater, and oceans. Set targets for zero conversion of natural ecosystems, restoration of degraded areas, and improved management practices.
  • Coverage: Ensure targets address both own operations and value chain, with particular focus on high-impact procurement regions.
  • Metrics: Select appropriate indicators like ecosystem integrity, species abundance, habitat quality, and ecological connectivity. Track progress using quantifiable data rather than vague commitments.
  • Stakeholder Alignment: Develop targets collaboratively with local communities, conservation organisations, and suppliers to ensure feasibility and local relevance.

National Biodiversity Strategies and Action Plans (NBSAPs) provide valuable frameworks for integrating biodiversity across industries. As research emphasises, mainstreaming within NBSAPs requires institutional changes across policy areas to embed biodiversity into core decision-making.

Embedding Nature in Corporate Governance

Transform biodiversity from a compliance exercise into strategic advantage through governance integration:

Board Oversight: Establish clear accountability at board level for nature-related risks and opportunities. Include biodiversity in enterprise risk management frameworks alongside climate and other material ESG factors.

Target Alignment: Link executive compensation to biodiversity performance, similar to climate targets. This drives accountability and signals strategic priority to stakeholders.

Investment Decisions: Integrate nature considerations into CapEx decisions, supplier selection, and innovation pipelines. Prioritise investments in Nature-based Solutions and circular economy approaches that deliver both biodiversity and business benefits.

Stakeholder Engagement: Actively involve local communities, particularly indigenous peoples whose traditional knowledge enhances ecosystem management. Transparent communication builds stakeholder trust and strengthens social licence to operate.

Prof. Nathalie Seddon from Oxford University notes: "The value of nature is often overlooked in accounting frameworks, but our study shows its enormous economic benefits. At a time when global systems are under pressure and the planet is warming, Nature-based Solutions offer an important opportunity to strengthen the resilience of ecosystems—and the economy that depends on them."

Data and Technology for Biodiversity Management

Advanced Monitoring and Analytics

Modern technology transforms biodiversity management from reactive compliance to strategic advantage. Key developments include:

Satellite Monitoring: High-resolution imagery tracks deforestation, land use changes, and ecosystem health in real-time. Essential for EUDR compliance and supply chain transparency.

AI-Driven Analysis: Machine learning algorithms identify biodiversity hotspots, predict ecosystem degradation, and optimise restoration efforts. Automated screening tools assess supplier risks efficiently.

Integrated Platforms: ESG software increasingly incorporates nature KPIs alongside carbon metrics. Real-time dashboards enable continuous monitoring rather than annual snapshot reporting.

Scenario Modelling: Tools like the Biodiversity Impact Assessment Tool (BIAT) help companies model different strategies' outcomes, assess trade-offs, and make informed decisions aligned with TNFD requirements.

Currently, 47% of organisations still rely on spreadsheets for ESG data management. This manual approach creates audit risks and limits strategic insights. Purpose-built platforms offer automated data collection, audit-ready reports, and integration with existing enterprise systems.

Dr. Choen Krainara from ESGLeadership explains: "ESG data is no longer a back-office compliance burden—it's a strategic asset. It informs capital allocation, operational risks, product design, and stakeholder trust."

Addressing Data Gaps Pragmatically

Despite technological advances, biodiversity data remains more complex than carbon accounting. Practical approaches include:

  • Good-Enough-for-Decisions: Focus on decision-relevant accuracy rather than false precision. Document assumptions clearly and improve data quality iteratively.
  • Proxy Indicators: Where direct biodiversity measurement is impractical, use validated proxies like land use intensity, habitat connectivity, or pressure-state-response models.
  • Collaborative Data: Participate in industry initiatives, data-sharing platforms, and standardisation efforts. Collective action improves data availability whilst reducing individual company costs.
  • Hybrid Approaches: Combine quantitative metrics with qualitative assessments from local experts, conservation organisations, and community knowledge.

The World Bank emphasises moving beyond perfect data paralysis towards adaptive management based on best available information. This pragmatic approach enables progress whilst acknowledging uncertainty.

Strategic Advisory for Biodiversity Integration

Integrating biodiversity into ESG strategies requires specialised expertise spanning regulatory compliance, scientific methodology, and strategic business planning. Fiegenbaum Solutions offers comprehensive support including:

Strategy Development: Biodiversity materiality assessment, science-based target setting, and integration with climate and circular economy strategies. Particular focus on aligning TNFD, CSRD, and corporate objectives.

Compliance Support: ESRS E4 reporting, EUDR due diligence implementation, and CSDDD supply chain mapping. Technical assistance with geolocation systems, supplier engagement, and documentation.

Impact Measurement: Life Cycle Assessment (LCA) incorporating biodiversity metrics, scenario analysis for nature-related risks, and dashboards tracking progress against targets.

Risk Management: Nature-related financial risk assessment, integration into enterprise risk frameworks, and investor relations support for ESG queries and due diligence.

For startups and growth-stage companies, tailored approaches address resource constraints whilst building scalable biodiversity management systems. Transparent pricing includes project-based consulting for specific challenges and retainer agreements for ongoing support.

With regulatory expertise, entrepreneurial experience, and scientific rigour, Fiegenbaum Solutions helps companies transform biodiversity from compliance burden into strategic opportunity.

Linking Climate and Nature Goals

Integrated Transition Planning

IPCC scenarios demonstrate that 1.5-2°C pathways are nearly impossible without significant ecosystem restoration. Climate strategies ignoring nature are incomplete and likely to fail. Integrated planning requires:

Nature-Based Solutions for Decarbonisation: Reforestation, peatland restoration, and regenerative agriculture sequester carbon whilst delivering biodiversity co-benefits. These should complement—not replace—emissions reductions.

Synergy Identification: Map where climate and nature actions reinforce each other. For example, renewable energy deployment designed with biodiversity considerations, or circular economy models reducing both emissions and resource extraction.

Avoiding Trade-Offs: Some climate solutions harm biodiversity (e.g., large-scale biofuel monocultures, poorly sited renewables). Integrated planning identifies and mitigates these conflicts early.

Regional Approaches: Coordinate emission reductions, ecosystem restoration, and circular economy transitions in specific geographies or supply chains for maximum impact and efficiency.

Understanding climate scenarios helps companies model nature dependencies under different warming pathways. This analysis should inform both climate transition plans and biodiversity strategies.

Convergence of Climate and Nature Disclosure

Regulatory frameworks increasingly require integrated reporting:

  • TCFD and TNFD: Taskforce on Climate-related Financial Disclosures and Taskforce on Nature-Related Financial Disclosures follow parallel structures, enabling aligned risk assessment and governance.
  • CSRD Integration: ESRS E1 (Climate) and E4 (Biodiversity) require consistency in materiality assessment, target-setting, and financial impact analysis.
  • Science-Based Targets: SBTi climate targets and SBTN nature targets use compatible methodologies, allowing companies to set and track integrated environmental goals.

This convergence simplifies reporting whilst acknowledging climate-nature interdependencies. Companies addressing both simultaneously benefit from strategic coherence and operational efficiency.

Conclusion: Biodiversity as Strategic Imperative

Biodiversity in ESG has evolved from voluntary initiative to mandatory compliance and strategic necessity. With 35% of Germany's native animal species and 26% of plant species endangered, the ecological crisis directly threatens economic stability. Companies that act decisively secure competitive advantages whilst contributing to environmental social and governance excellence.

The regulatory landscape—CSRD/ESRS E4, TNFD, EUDR, and CSDDD—creates binding requirements for biodiversity assessment, target-setting, and disclosure. Financial institutions increasingly view nature-related risks as material to investment decisions and credit ratings. Stakeholders demand transparency and effective strategies for biodiversity protection.

Yet only 15% of companies have assessed their value chain's biodiversity impact. This gap represents strategic opportunity. Early movers benefit from:

  • Risk Mitigation: Reduced exposure to regulatory penalties, supply chain disruptions, and reputational damage
  • Market Positioning: Enhanced brand value, customer loyalty, and investor appeal through demonstrated sustainability leadership
  • Innovation: New products, services, and business models aligned with nature-positive economy
  • Resilience: Adaptive capacity for interconnected climate-nature crises through ecosystem-based approaches

Integrating biodiversity requires structured methodology: materiality assessment, science-based targets, governance integration, and continuous monitoring. Tools and frameworks now enable precise measurement and management of nature-related risks and opportunities.

The IMD research institute concludes: "For companies already working on climate action, incorporating biodiversity is not an additional burden but a complementary strategy that strengthens climate goals whilst delivering additional benefits."

Biodiversity is becoming a key differentiator within ESG. Companies establishing foundations today position themselves as market leaders whilst contributing to a sustainable future. Protecting biological diversity represents both ethical responsibility and strategic pathway to long-term business success.

FAQ

What is biodiversity in ESG?

Biodiversity in ESG refers to how companies assess, manage, and report their impacts and dependencies on biological diversity within environmental, social, and governance frameworks. This includes measuring effects on species, ecosystems, and natural resources, whilst identifying nature-related risks to business operations. CSRD's ESRS E4 standard and TNFD framework provide structured approaches for integrating biodiversity into corporate strategy and disclosure. Companies must evaluate both how their activities affect nature and how nature degradation affects their business model—the principle of double materiality.

Does diversity fall under ESG?

Biodiversity and ecosystem services fall specifically under the Environmental pillar of environmental social and governance frameworks. However, nature-related impacts often connect to Social factors (community livelihoods dependent on ecosystems) and Governance (board oversight of nature-related risks). The interconnected nature of ESG means biodiversity strategies should consider these cross-cutting dimensions. For instance, EUDR compliance affects both environmental reporting and supply chain governance.

What does ESG mean in environmental?

The Environmental component of ESG encompasses climate change mitigation and adaptation, pollution prevention, circular economy, water management, and biodiversity protection. Environmental criteria assess how companies manage their ecological footprint, natural resource use, and contributions to environmental challenges. Climate regulation, ecosystem services preservation, and sustainable practices form core elements. Modern environmental ESG extends beyond carbon metrics to include nature risks, circular economy principles, and integrated approaches addressing multiple environmental challenges simultaneously.

What is ESG in renewable energy?

ESG in renewable energy evaluates how clean energy projects balance environmental benefits (emissions reduction) with nature risks (habitat disruption, biodiversity impact) and social considerations (community acceptance, land rights). Renewable energy deployment must avoid trade-offs where climate solutions harm biodiversity—such as wind farms in migratory bird paths or solar farms on natural grasslands. Nature-positive renewable energy integrates ecological design principles, conducts thorough impact assessments, and implements mitigation measures. This ensures energy transition strengthens rather than undermines overall environmental social and governance goals.