Insights · CDP · 5 min read

Why CDP reporting is no longer optional

By Andrew "Riz" Rizkallah · March 12, 2026

A customer asks your company to disclose through CDP. Suddenly, the sustainability lead needs General Ledger (GL) data from finance, facility information from operations, and answers about governance from leadership. The request has become a business deliverable with an owner, a deadline, and expectations to clarify.

CDP reporting is not a universal legal obligation. But when a customer or financial stakeholder requires it, treating disclosure as optional can leave that requirement unanswered. For sustainability and compliance teams, the practical priority is a complete, accurate response that meets the request.

What CDP reporting covers

CDP, formerly the Carbon Disclosure Project, runs an environmental disclosure system through which organizations share environmental information. Its questionnaire connects environmental impact with governance, risks, targets, and business strategy.

If you remember the standalone climate change questionnaire, update your preparation. CDP integrated climate change, forests, and water security into one corporate questionnaire in 2024. The full questionnaire also addresses biodiversity and offers additional environmental topics, including plastics. Your reporting pathway determines the questions presented. Eligible companies can use a simplified SME questionnaire.

That makes CDP disclosure broader than a carbon emissions total. Prepare to explain how your organization understands environmental risks, assigns responsibility, and measures environmental performance.

Why customer requests change the decision

CDP requests can come from supply chain customers, capital markets, banks, or participating initiatives. Companies can also volunteer to disclose.

When a request arrives, ask what the requester needs. Is completing a CDP submission sufficient? Is there an expected score, disclosure scope, or improvement milestone? Who will review the response? Establish those details before committing your team to work.

A customer’s CDP request may focus on getting supplier-specific emissions data to support its own Scope 3 calculations. Module 7, which covers climate-related environmental performance, provides information that can help customers develop supplier-specific emissions factors instead of relying on industry averages.

Clarify which data your customer needs and whether it also expects a particular CDP score. A request for emissions information and a requirement to achieve A-List performance are different commitments. Document the expectation, involve the person who manages the customer relationship, and build your reporting plan around the data, resources, and approvals needed to respond.

How CDP fits into sustainability reporting

CDP's climate disclosure aligns with the ISSB's IFRS S2 standard and incorporates the TCFD pillars of governance, strategy, risk management, and metrics and targets. It also provides mappings to other reporting standards.

For companies considering CSRD requirements, CDP data may support preparation for relevant environmental disclosures. CDP describes substantial alignment with the pre-Omnibus ESRS E1 climate standard, while revised mappings depend on regulatory developments. A CDP response does not establish compliance with every applicable sustainability reporting obligation.

Use environmental reporting and ESG reporting work to build a shared data foundation. Review each output separately for its reporting boundary, required detail, and approval process. Reusing information should still include a check that it answers the specific question.

Build a CDP reporting process your team can maintain

Start with the request and reporting scope

Review the CDP Portal, confirm the submission lead, and complete questionnaire setup. CDP uses that setup to determine applicable modules and questions.

Create a working plan that names the requester, reporting period, entities covered, internal reviewers, and approval date. Give each outstanding item an owner. Check requirements against the current disclosure cycle rather than copying last year's plan unchanged.

Organize data collection around the emissions inventory

Use the GHG Protocol to distinguish greenhouse gas emissions across the business:

  • Scope 1 covers direct emissions from owned or controlled sources.
  • Scope 2 covers emissions from generating purchased or acquired electricity, steam, heat, and cooling consumed by the company.
  • Scope 3 covers other indirect emissions across the upstream and downstream value chain.

Keep environmental data, source records, calculation methods, assumptions, and exclusions together. Assign owners for utility bills, fuel use, purchasing records, and supplier information. Review changes in facilities or organizational boundaries before comparing annual totals.

Track emissions reductions against a defined baseline and document the reasons for changes. A lower total needs context, including any changes to activity, coverage, or calculation methods.

Connect risk answers to business decisions

Work with operations, procurement, and leadership to describe climate risks and relevant environmental dependencies. Where forests or water security questions apply, involve the people responsible for sourcing, facilities, and risk assessment. Deforestation commitments need an explanation of implementation, not just a policy title.

For each answer, identify the underlying decision, responsible person, and supporting record. Resolve conflicting descriptions before final review.

Review the response against the scoring methodology

CDP scores assess disclosure completeness, awareness, management, and leadership. The full corporate questionnaire uses separate methodologies for climate change, forests, and water security.

Read the current scoring methodology alongside the reporting guidance. CDP generally scores information within the response; links and attachments are considered only where the methodology specifically requests them.

Provide the required detail in the answer itself. Use scoring feedback to identify concrete reporting and management improvements, then assign the follow-up work.

Plan for the scoring deadline

The scoring deadline and final response deadline serve different purposes. In 2026, CDP's published scoring deadline was September 16, with final closure scheduled for the week commencing October 26. Edits submitted after the scoring deadline are not scored.

Build time for review and approval before submission. For later cycles, confirm dates directly with CDP before setting your internal calendar.

Bring your CDP request to Greenplaces

Greenplaces supports CDP reporting by mapping requirements, compiling evidence, drafting responses, managing submission, and reviewing scorecards.

Bring your customer request, previous response, or outstanding data questions to a strategy call. Start with the requirement and your team's capacity, then define the support needed for the next submission.

Last updated October 16, 2026

Frequently asked questions

Is CDP reporting mandatory for every company?

No. Participation can be requested by stakeholders or undertaken voluntarily. Clarify any contractual requirement with the requester rather than assuming a universal obligation.

Does submitting guarantee a strong CDP score?

No. Submission and scoring are separate outcomes. CDP evaluates eligible responses against its methodology; completing the questionnaire does not guarantee leadership recognition.

Can smaller companies report through CDP?

Yes. CDP offers an SME questionnaire with fewer, simplified datapoints for organizations meeting its eligibility criteria. Confirm your pathway during setup.

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