A working manual for the biodiversity part of a CSRD sustainability statement, written for one corporate entity. It maps the nature-related ESRS requirements to concrete steps and shows where Gaia produces the evidence and where you must supply your own data.

0. Scope, current status and decisions

0.1 Where CSRD stands (as of 13 October 2026)

If you are no longer in scope you can still use this manual voluntarily, for lenders, customers and the voluntary standard. The Commission page does not state wave timings; the figures above come from a secondary source and must be confirmed against the Official Journal.

0.2 What this manual does and does not do

• It covers nature: ESRS 2 general disclosures that touch biodiversity (impact, risk and opportunity identification, strategy and business model) and the biodiversity and ecosystems standard, ESRS E4.

• It does not cover climate, pollution, water or social standards, although Gaia Layers can give spatial context for some of them.

• Requirement numbers are given as in ESRS Set 1 (2023) with the revised numbering noted where a secondary source reports a change. Only the revised Annex I text is authoritative; this manual was written without access to it.

0.3 Decisions to make before you start

1. Is biodiversity material after your double materiality assessment? If not, you explain why (section 2); you do not leave E4 out silently.

2. Reporting boundary: the consolidated group plus the value chain parts you can reach.

3. Sites: the list of own sites and their coordinates and areas.

4. Which year you start: FY 2026 early use of the revised ESRS or FY 2027.

5. Method rules: radius for "near" a sensitive area, baseline year, record-count minimum for Gaia indexes.

6. Owner for each disclosure, including the person who signs the sustainability statement.

7. Assurance: who will review and what evidence the assurer will ask for (section 6).

0.4 What Gaia does and what you supply

Honest limits. Gaia works from secondary data. Counts are lower than in GBIF as a whole because only commercially licensed records are shown, and a species with no record is not proven absent. Indexes describe the composition of records; they are not a measure of ecosystem condition.

1. Requirement map

Numbers follow ESRS Set 1 (2023). A secondary source reports that the July 2026 revision has five E4 requirements instead of six (E4-1 to E4-5) and no prescribed metric list; check the revised Annex I for the final numbering and wording.

Gaia is strongest on location context (IRO-1, E4-5) and on evidence for actions (E4-3). It does not replace policies, spending data or the financial analysis.

Procedure

1. Copy this table into your gap register and add owner and due date per row.

2. Mark every row "material", "not material, explained" or "phase-in".

3. Run the Gaia routine (section 6) only for rows where Gaia is named.

2. Double materiality for nature (IRO-1, SBM-3)

Double materiality stays mandatory after the simplification. You assess impact materiality (your effect on nature) and financial materiality (nature's effect on your finances), and you document how.

2.1 Steps

1. List sites and activities. One row per site, with coordinates, area (ha) and activity.

2. Screen location. In Gaia Map and Layers, overlay each site with protected areas, Habitats Directive habitats and other sensitive layers from national agencies. Record the layer, the authority, the date and the distance.

3. Characterise local ecology. Run Gaia KPIs for a fixed radius and window: records, species count, Shannon-Wiener, Simpson dominance, Berger-Parker. Note record counts; below your minimum, write "insufficient data".

4. Check pressures. Use Nexus for pests and invasive alien species that interact with your activity or crops.

5. Score. Rate impacts and dependencies on a scale you define (for example 1 to 5 for severity, scale and likelihood) and set a threshold for "material".

6. Extend to the value chain. Identify upstream sites and sourcing regions; locate them in Layers where coordinates exist, otherwise by region.

7. Document. Keep the scoring sheet, the thresholds and the sign-off.

2.2 Evidence table

2.3 If biodiversity is not material

State the conclusion and a short explanation of how you reached it, in the same section as the other materiality outcomes. Keep the Gaia screening as the proof that sites were checked.

Limits. Gaia does not assess dependencies on ecosystem services such as pollination or water, nor financial effects. Use your own or specialist analysis for those, and mark the result as your judgement.

3. Strategy, policies, actions and targets (E4-1 to E4-4)

If a requirement does not apply to you (no plan, no policy, no target), the standard asks you to say so rather than leave a gap. A secondary source on the revised E4 also says a transition plan is described only if a public one exists.

3.1 E4-1 Transition plan

Describe the plan's key features if you have one. Use Gaia to support its content: Nexus for biological control options against pests, Traits for species choice in planting, Layers for where measures sit.

3.2 E4-2 Policies

Gaia does not write policies. Cover scope, objectives, standards referred to, and the topics the standard raises: traceability of raw materials, own sites near sensitive areas, and land, ocean and deforestation practices. Use the Layers screening to show which sites the policy applies to most.

3.3 E4-3 Actions and resources

For each action write: what, where (site and ha), when, expected outcome, owner and the operating and capital spending. Check legal approval before introducing any species for biological control, and check each trait source's licence before using trait data in a public deliverable.

3.4 E4-4 Targets

A target needs a value, unit, baseline, target year and method.

1. Choose a metric you can measure yourself, such as hectares restored.

2. Use Gaia KPIs as a context indicator only (for example Berger-Parker not rising above the baseline), never as the sole target, since record counts change with observation effort.

3. Fix the baseline year and the Gaia parameters in the parameter sheet (section 6).

4. Review yearly and record changes in method.

4. Metrics (E4-5) and financial effects (E4-6)

E4-5 is the only E4 requirement a secondary source describes as always required once biodiversity is material. It asks for three things: where your locations are in relation to sensitive areas, which areas and activities, and metrics on drivers of change, species, ecosystems and ecosystem services, each with unit, method, sources and baseline. The 2023 text also named land-use change, and estimates are allowed where direct data are missing if you explain method and sources.

4.1 Locations and sensitive areas

1. Define "near" yourself (a distance or an overlap) and apply it to every site. The standard sets no distance in the secondary source reviewed.

2. In Gaia Layers, overlay each site boundary with legally protected areas (for example Natura 2000) and scientifically recognised ones where national layers exist. Gaia Layers can pull EU Habitats Directive data (for example Annex I habitat types and Natura 2000 sites) as context, so you can see which habitats a site touches.

3. For each hit record: area name, type, authority, distance, and the activity that could affect it.

4. Add sites without a hit as "none found in the layers checked", naming the layers.

4.2 Drivers of change

Hectares converted, occupied or restored come from your own land records. Gaia can show the surrounding habitat and protection status to interpret them, but it does not measure land-use change.

4.3 Species and ecosystems with Gaia indexes

With n_i records of species i, N total records and p_i = n_i / N:

• Shannon-Wiener H' = -sum(p_i ln p_i). Higher means a more even, richer record set.

• Simpson dominance D = sum(p_i squared). Higher means more dominance. Confirm with Gaia whether the shown value is D or 1-D before you interpret it.

• Berger-Parker d = n_max / N: the share of the most recorded species.

Procedure

1. Fix radius, taxa, record types and two equal-length windows (baseline and reporting year) in the parameter sheet.

2. Run KPIs for both windows with identical settings.

3. Report the indexes together with N and the number of species.

4. Describe the change in words and note observation effort.

Limits. The indexes describe the records Gaia holds (GBIF, commercially licensed only, filtered where feasible). A rise in records from more observers can change an index without any change in nature. They indicate composition, not ecosystem condition or extent; for those, report your own survey results. For threatened species use red-list status from the source records and generalise sensitive coordinates.

4.4 Ecosystem services

List services you depend on or affect (pollination, water regulation, soil protection). Use Nexus to document the species interactions behind a service, such as pollinators or natural enemies of pests. The valuation stays with you.

4.5 E4-6 Anticipated financial effects

Gaia does not calculate financial effects. Give the finance team the site screening, the dependency list and the Nexus evidence as inputs, and let them describe risks and opportunities, time horizons and any quantification or phase-in the standard allows.

5. Value chain and crosswalks

5.1 Value chain

ESRS cover the value chain, but the Omnibus value chain cap and the voluntary standard limit what you can demand from companies with fewer than 1,000 employees. Plan accordingly.

1. Rank suppliers and commodities by likely nature impact.

2. Where you have supplier site coordinates, run the same Layers screening as for your own sites.

3. Where you only have a region, say so and use region-level layers.

4. Ask suppliers for data through the voluntary standard's request list, not a custom questionnaire.

5. Mark every value chain figure as estimated or supplier-reported.

5.2 Crosswalks

The mapping is indicative. Reuse one Gaia data set across all three frameworks by keeping the same parameter sheet, then cite it in each. Companion Gaia manuals for TNFD and GRI 101 follow the same structure.

6. Gaia workflow, data governance and assurance evidence

An assurer will ask where each number came from and whether you can reproduce it. Build that trail as you work.

6.1 Four-step routine

1. Search and discover. In Map, set site and radius; see which records, years and layers exist.

2. Calculate KPIs. Run the indexes for baseline and reporting windows with identical settings.

3. Context and solutions. Add Layers for sensitive areas, Nexus and Traits for measures, Gaia Bioacoustics where sound adds evidence.

4. Draft, filter, download. Use the AI reporting assistant for a draft, filter and analyse the data, download tables as evidence.

6.2 Parameter sheet (per site, per year)

6.3 Evidence file for assurance

One folder per reporting year: parameter sheet, KPI exports, Layers screenshots with legend and date, the AI draft and the final text, the materiality scoring sheet and a reviewer note. Name files by site, requirement and year, for example SiteA_E4-5_2027. Cite each file in the sustainability statement's data point index. Limited assurance is the only level required under the Omnibus text reviewed, but expect questions on method and consistency.

6.4 Data governance

• Read Gaia's terms and privacy policy before uploading your own data.

• Occurrence and eDNA records are secondary data from GBIF; only commercially licensed points are used, so counts are lower than in GBIF overall. State this in your method note.

• Generalise coordinates of sensitive species.

• Credit licensed records as their licences require.

• Check each trait source's licence before public or commercial use.

• Treat the AI draft as a draft; check every number against an export.

• Confirm with Gaia: the Simpson form used, how eDNA is weighted in indexes, and how uploaded data is stored.

7. Timeline, quality control and sources

7.1 Timeline (first reporting cycle, about 16 weeks)

In later years, repeat the Gaia routine with unchanged parameters.

7.2 Quality control checklist

• Materiality outcome documented for nature, including an explanation if not material.

• Every material E4 requirement answered, or "none" stated where policy, action or target does not exist.

• Definition of "near a sensitive area" stated and applied to all sites.

• Baseline and reporting windows have equal length and identical Gaia parameters.

• Each Gaia figure traces to an export.

• Indexes shown with N and species count and the licence limitation.

• Sensitive coordinates generalised.

• Value chain figures marked as estimated or reported.

• Requirements checked against the revised Annex I.

• Sign-off by accountable owner.

7.3 Common errors

7.4 Sources

• European Commission, corporate sustainability reporting (updated 3 July 2026).

• EFRAG, delegated act on revised ESRS.

• European Commission draft delegated act 2026: application dates and early use; Annex I was not in the text I could read.

• Latham & Watkins, Omnibus conclusion: scope thresholds, timing, assurance.

• Darwin, ESRS E4 after the July 2026 revision: vendor summary of revised E4; unverified against the official text.

• Gaia, Illuminum AB, Global Biotic Interactions.

Limits of this manual. Scope figures and the revised E4 structure come from secondary sources. Verify them against the Official Journal and the revised Annex I before you publish.