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Sustainability data and the AMF framework: towards a new proof regime

Sustainability data and the AMF framework: towards a new proof regime

Saturday, April 19, 2025

Increasingly stringent sustainability requirements are profoundly transforming the expectations of financial markets. For issuers, property developers and management companies, environmental information is no longer a narrative supplement, but a binding document subject to verification. The Autorité des marchés financiers (AMF) now incorporates these requirements into all its doctrines and control processes. In this context, IRICE's structuring as a third-party certifier - within the ARKORIS Group - provides a proof framework compatible with the expectations of investors, regulators and statutory auditors.

1. A rapidly evolving AMF doctrine: towards standardized sustainable information

European Directive 2022/2464 (CSRD), transposed into French law, requires large listed companies and groups to publish auditable sustainability information according to European standards (ESRS). This requirement has been incorporated into AMF doctrine, notably via guide DOC-2016-13 on social, societal and environmental responsibility, and the AMF General Regulation (Books II and IV), which provide a framework for the sincerity, consistency and publication of this information.These developments aim to enhance transparency, reduce greenwashing and secure the place of ESG criteria in the financial valuation of assets.

2. IRICE certification: a structured response to proof requirements

Verification of environmental data becomes a condition of regulatory admissibility. The AMF holds issuers liable for unsubstantiated or vague claims. Simply mentioning environmental commitments is no longer enough: we need to be able to justify their reality, traceability and measured impacts. IRICE acts as an independent third-party certifier in these areas. Its non-commercial stance, official accreditation and strict scope of ecological certification (biodiversity, resilience, land use) make it a tool that can be mobilized by any player subject to sustainable publication or ESG reporting obligations.

3. Operational structure within the ARKORIS group

The ARKORIS Group structures the entire environmental performance value chain:

  • ARKEMEP, a technical design office, is involved right from the design and simulation phase (thermal, fluids, acoustics).
  • ARKENOR, in support of project owners, secures environmental certifications (NF Habitat HQE, BREEAM, BDM, etc.) and manages regulatory diagnostics.
  • Finally, IRICE acts as an independent third party, solely for ecological certification and verification of commitments relating to biodiversity and natural hazards.

This organization avoids conflicts of interest and guarantees a clear separation between project support and certification. It meets the AMF's expectations in terms of third-party independence and the accuracy of published information.

4. Strategic leverage for regulated players in the real estate sector

Fund-backed developers, portfolio management companies, listed groups or groups in the process of being listed: real estate players are increasingly affected by AMF regulations. The use of verifiable benchmarks, the backing of independent certifiers, and the traceability of commitments are becoming implicit conditions of regulatory acceptability.The ARKORIS Group is part of this dynamic with a sober, structured and coherent approach:

  • Studies are carried out without compromising on technical rigor (ARKEMEP).
  • Certification processes are isolated in dedicated entities (ARKENOR, IRICE).
  • Each intervention can be formally verified or audited if necessary.

Conclusion

The shift from communication to regulation is imposing a new discipline on operators: producing evidence. The ARKORIS group has been preparing for this for several years. With IRICE as a third-party certifier, ARKENOR as an environmental consultant and ARKEMEP as an integrated consultancy, this capacity can now be activated at project, portfolio or group level. Against a backdrop of tighter regulation of ESG publications, this structuring is a guarantee of strategic continuity.

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