If your company received a CDP “Letter to the Board” this year, you are among the 43,000-plus organizations that CDP’s Capital Markets Signatories are requesting to disclose in 2026. These signatories are over 540 financial institutions—banks, insurers, asset managers, and investment funds representing more than $110 trillion in assets. For many companies, the request comes from the same institutions that lend to them, insure them, or hold their equity.
A different kind of request
A Capital Markets request differs from the Supply Chain requests that drive 90% of disclosures in two practical respects:
Fees. Companies that have previously responded only to Supply Chain requests have not been charged an administrative fee. A Capital Markets request carries CDP’s Admin Fee. For North American companies in 2026, the lowest available tier is $3,250.
Visibility. Any company asked to disclose by Capital Markets Signatories will appear on CDP’s public scores dashboard. The way a company appears depends on how it responds:
- Respond before the scoring deadline, and the resulting score is published.
- Do not respond at all, and the dashboard reflects a “Did not disclose” status.
- Already disclosing through Supply Chain under a non-public election? A Capital Markets request makes the score public regardless, although the detailed responses remain viewable only to Capital Markets Signatories and Supply Chain members.
Considerations in favor of disclosing
Several points are worth weighing as you decide how to respond.
Disclosure is associated with measurable operational change. CDP reports that companies responding to an investor request reduce their direct emissions by 7–10% within two years. The process of measuring and reporting tends to surface efficiency and risk-management opportunities that might otherwise go unidentified.
The first year is the most demanding, and most companies continue. Of the companies that began disclosing following engagement from financial institutions, approximately 90% continued to disclose in subsequent years. The initial response builds a reporting infrastructure that becomes substantially easier to maintain over time.
It supports readiness for emerging regulation. CDP’s questionnaire is closely aligned with the major reporting standards, including ISSB, ESRS, IFRS S2, TCFD, and TNFD. As mandatory regimes such as California’s SB 253 and SB 261 take effect, the work involved in a CDP response provides a foundation for disclosures that will increasingly be required. Establishing the underlying data and governance processes now can reduce duplication later.
It addresses stakeholder expectations directly. Investors, lenders, and customers increasingly use environmental data to assess risk and resilience. A structured disclosure provides a clear, comparable record of a company’s environmental program in the format these stakeholders are already using.
Considerations on the other side
The decision is not one-directional, and two factors warrant consideration.
What was previously a “free” exercise now bears a cost. And for some companies, a publicly visible score (particularly low ones) may raise specific concerns about how it will be interpreted by stakeholders or competitors.
If the public score is the primary concern, there is a middle path. A company can submit its disclosure after the mid-September scoring deadline. CDP will register the response, so the company is recorded as having participated, but the response is not scored, and the dashboard reflects a “Not scored” status rather than “Did not disclose.” Submissions are accepted through the final window in late October. This allows a company to demonstrate engagement and develop its reporting capability without placing a score on public display.
Our recommendation
On balance, we generally advise companies to disclose. The most resilient position is to appear on the dashboard as a participant rather than as a non-respondent, and the broader trajectory favors building this capability sooner rather than later.
The right form of disclosure will depend on your circumstances. For companies confident in their environmental program, a public score is a credible signal. For those earlier in the process, a registered but unscored response offers a measured way to participate while building toward a stronger position in future cycles. In either case, getting your environmental data into a structured format is sound preparation for what investors, customers, and regulators are likely to ask next.
We are happy to discuss which approach best fits your situation and to support the work of preparing your data ahead of the relevant deadlines.
Frequently asked questions
Andrew “Riz” has 10 years of experience in leadership, technology implementation and client service. As Director of Sustainability Reporting at Greenplaces, he leads disclosure preparation for customers responding to regulatory and voluntary frameworks including CDP, EcoVadis, SBTi, and California Climate Accountability rules (SB-219/261/253). He speaks regularly on ESG and sustainability topics, having worked as a graduate research and teaching fellow focused on sustainable operations, circular economy and ESG reporting. He holds a B.S. in Industrial Engineering and an MBA from The Ohio State University, multiple patents in supply chain technology, and the Fundamentals of Sustainability Accounting (FSA) certification from the International Sustainability Standards Board.
