Article 29 French Energy-Climate law
Biodiversity reporting for financial actors

Article 29 of the French Energy-Climate law requires financial actors to report on their alignment with climate and biodiversity objectives, ahead of and alongside CSRD/SFDR.

Article 29 of the French Energy-Climate law

Article 29 of the French Energy-Climate law requires financial actors to report on their alignment with climate and biodiversity objectives, ahead of and alongside CSRD/SFDR. NORMAXIS produces the biodiversity evidence behind this reporting.

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Scope

A French obligation on financial actors, predating CSRD.

Article 29 of the French Energy and Climate Act requires financial market participants operating in France to disclose how they take climate and biodiversity into account: strategy, alignment, and, distinctively, biodiversity, several years before European reporting made it general.

It applies to entities that are often not themselves subject to CSRD as reporting companies, and it asks about portfolios rather than operations. That difference in object is what makes it a separate exercise rather than a subset.

Practice

Portfolio biodiversity depends on data from assets.

Reporting on the biodiversity footprint of a portfolio requires information about the underlying assets, which the investor does not produce. Where those assets are buildings or land, third-party certification and documented ecological assessment are among the few sources that survive scrutiny.

This is where an accredited certification body has a role a consultant cannot fill: the verification enters the investor's disclosure precisely because it was not produced by an interested party.

Method

Portfolio-level claims need asset-level evidence.

The recurring difficulty is granularity. A statement about the biodiversity footprint of a portfolio is only as good as what is known about its assets, and for most portfolios that knowledge is uneven: detailed on recent acquisitions, thin on older holdings. Disclosing that unevenness honestly is more defensible than averaging over it.

Where assets are built, ecological assessment and third-party certification produce data on a consistent basis year after year, which is what makes a trend statement possible at all.

Going further

Related pages.

Article 29 connects to these subjects.

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Engineering, environmental advisory and independent certification under one group, with a strict separation of roles.

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