POLICY & GOVERNANCE / VOLUNTARY FRAMEWORKS
CDP
The world's largest environmental disclosure platform. What it is, how the 2026 cycle works, what it unlocks, and what to understand before you engage.
In 30 seconds
CDP Worldwide is a UK registered charity running the global voluntary disclosure platform for corporate environmental reporting. Companies complete a single integrated questionnaire covering climate, water, forests, biodiversity, plastics, and ocean, with conditional routing so only relevant questions appear based on sector, size, and materiality. CDP scores responses from A to D- and publishes the results. Over 22,000 companies disclosed in 2025; financial institutions managing $110+ trillion in assets use CDP data.
CDP is not the government. It is not a regulator. It is a disclosure infrastructure organisation that has become, through investor adoption, the de facto standard for voluntary corporate environmental reporting globally.
The core value: A single CDP submission satisfies the information needs of IFRS S2, TCFD, and partially ESRS and TNFD simultaneously. For organisations facing multiple reporting obligations, this “write once, read many” positioning is its strongest practical argument.
Legal structure and organisation
The CDP brand covers two distinct UK legal entities, as well as a network of legally separate regional organisations worldwide. Understanding the structure is relevant when engaging commercially with CDP or when citing it in regulatory or investor contexts.
CDP Worldwide
Charity Commission registration 1122330 · Companies House number 05013650
The UK registered charity at the centre of the global network. Structured as a company limited by guarantee, the standard form for UK charities that need to enter contracts and employ staff. Its stated charitable purpose is to “conduct research and make those useful results available for the public benefit.”
CDP Operations Limited
Companies House number 06602534
CDP Worldwide's wholly-owned trading subsidiary. Its stated purpose, as documented in CDP's own annual reports, is “to generate funds from service-based activities to support the charity's activities.” CDP Operations Limited is a private limited company, not a charity. When organisations pay for services from CDP, those transactions go through CDP Operations Limited.
Beyond the UK, CDP operates through a network of legally separate regional entities: CDP North America Inc (a 501(c)(3) incorporated in Delaware), CDP Europe AISBL (a Brussels-registered non-profit association, operating under an intellectual property licence from CDP Worldwide), wholly-owned subsidiaries in Germany, India, and China, and further entities across Japan, Hong Kong, Singapore, Indonesia, Brazil, and other markets.
Both UK registrations are publicly searchable on the Charity Commission register and Companies House.
Six environmental themes: one integrated questionnaire
Since 2024, CDP has merged its separate climate, water, and forests questionnaires into a single integrated submission. Biodiversity, plastics, and ocean sit within the same framework. A setup flow at the start determines which questions appear, based on your sector, size, and which themes are material to your operations.
Step zero: choose your organisation type
When you first enter the CDP portal, you are asked to select one of three organisation types. This determines your questionnaire path entirely.
Scores remain separate: Even though it is one submission, CDP issues separate A–D– scores for Climate, Water, and Forests. Biodiversity, Plastics, and Ocean are currently unscored (2026). You can opt out of non-material themes during setup.
Scope 1, 2, and 3 emissions. Climate-related risks and opportunities (TCFD-aligned). Net-zero targets (SBTi alignment). Governance. Engagement with value chain.
The core questionnaire. Every CDP discloser completes this.
Water withdrawals and discharge. Water risks and dependencies. Stewardship actions. Catchment-level water quality.
Relevant for agriculture, food processing, beverages, manufacturing, mining.
Forest-risk commodities: timber, palm oil, cattle, soy, rubber, cocoa, coffee. Deforestation commitments and progress. EUDR readiness.
Relevant for food, retail, construction, and any organisation with a forest-risk supply chain.
Nature dependencies and impacts. Alignment with TNFD LEAP. Progress against Kunming-Montreal targets (30x30). Species and habitat commitments.
Fastest-growing questionnaire. Increasingly relevant for land-owning and supply chain-intensive organisations.
Plastic production volumes. Recyclability and reuse. Circular economy commitments. Extended producer responsibility.
Relevant for packaging, FMCG, retail, manufacturing.
Marine dependencies and impacts. Ocean health targets. Relevant for fishing, aquaculture, shipping, coastal tourism and infrastructure.
New for 2026. First full disclosure cycle. Relevant for coastal and marine-exposed operations.
The SME questionnaire
Launched in 2024 and now in its second full year, the SME questionnaire is a significantly simplified version of the full corporate questionnaire. Eight modules, climate-led, with integrated water and forests questions. No sector-specific questions. Built in collaboration with the SME Climate Hub.
| Organisation size | Recommended pathway |
|---|---|
| Under 500 employees AND under $50M revenue | SME questionnaire |
| Under 500 employees with $50M–$250M revenue; OR 500–1,000 employees with under $250M revenue | Full or SME depending on capacity |
| Over 1,000 employees OR over $250M revenue | Full corporate questionnaire |
2026 additions: expanded forest and water questions for SMEs (previously climate-only). The SME questionnaire is now a genuine multi-theme tool, not just a simplified climate form.
2026 disclosure cycle
CDP runs an annual cycle. The scoring deadline is the one that matters commercially: responses after that date appear in the database but are unscored.
Planning note: For a client engagement aimed at a scored first submission, work backwards from the week of 14 September. Allow at minimum 6–8 weeks for data gathering and response drafting. A first-pass review by early August is sensible.
Framework alignment
CDP positions itself as a “write once, read many” system: a single disclosure covering multiple regulatory and voluntary frameworks simultaneously. This is its strongest practical argument for organisations facing a crowded reporting landscape.
ESRS caveat: CDP aligns to the pre-Omnibus version of ESRS E1. The EU Omnibus package is changing ESRS E1 materially in 2025-26. Do not treat a CDP Climate submission as a complete ESRS E1 substitute without checking the current delta.
CDP's climate disclosure has been the foundational baseline for IFRS S2 since 2024. A CDP Climate submission is the strongest single step towards IFRS S2 compliance.
CDP aligned to all four TCFD pillars in 2018: governance, strategy, risk management, and metrics and targets. If your corporate buyers or investors require TCFD reporting, CDP Climate delivers it.
CDP aligns to the pre-EU Omnibus version of ESRS E1. The EU Omnibus is changing ESRS E1 materially in 2025-26. Do not assume CDP submission fully satisfies ESRS without checking the current delta.
CDP's Biodiversity questionnaire aligns with TNFD LEAP disclosure recommendations, but the alignment is partial. Nature-positive organisations will need TNFD work beyond CDP.
Alignment with GRI Climate Change, Energy, Water & Effluents, and Biodiversity standards. GRI serves an impact-reporting audience; CDP serves an investor audience. The two are complementary.
Scope 1, 2, and 3 definitions and accounting methodology. GHG Protocol is the foundation; CDP is built on top of it. You need GHG Protocol before you can complete CDP.
What disclosure unlocks
Supply chain credibility
Large companies submitting to CDP can reference their suppliers' CDP data in their own submission. A CDP submission makes you visible and usable to corporate procurement teams facing their own Scope 3 reporting obligations. This is the route from "local supplier" to "verified sustainable supplier" for institutional buyers.
Green finance eligibility
NatWest, Lloyds, and HSBC all offer preferential ESG lending products for businesses with verified sustainability credentials. CDP data is a prerequisite for most of these products. Some NEIRF and green bond instruments reference CDP disclosure.
Investor visibility
Over 540 financial institutions managing $110+ trillion in assets use CDP data to assess portfolio companies. CDP scores appear on Bloomberg terminals and feed into ESG data products used for capital allocation. A CDP submission connects you to this investor data infrastructure.
Regulatory preparation
If your corporate buyers face UK SRS or CSRD requirements, they will pass Scope 3 data requests down their supply chains. Building a CDP-compatible data foundation now means you are ready, rather than scrambling when the request arrives.
The SME pathway into disclosure
CDP does not sit in isolation. For smaller organisations, there is a coherent three-stage journey, from first awareness of climate action through to a scored annual disclosure.
Free UK on-ramp. Practical guidance on energy, travel, waste, and supply chain. Framed around cost savings and operational resilience. Government-endorsed (DESNZ-backed), delivered by the Broadway Initiative with FSB, BCC, CBI, and IoD. No commitment required.
Global commitment platform. Pledge to halve emissions by 2030 and reach net zero by 2050, joining the UN Race to Zero. 10,000+ businesses signed. Tools include an emissions calculator, climate action plan builder, and progress tracker. Built in collaboration with CDP; the SME questionnaire is the disclosure pathway for Hub signatories.
Annual disclosure and scoring. Eight modules. Scoring deadline week of 14 September. Aligned with IFRS S2, TCFD, and partially ESRS and TNFD. A score makes you visible in corporate supply chain data systems and investor ESG databases.
The Pandion view on CDP
We help clients navigate CDP. We are not CDP advocates. Here is our honest assessment.
Disclosure quality and environmental performance are not the same thing.
CDP scores measure how well you have disclosed, not how well you are performing. A company with detailed plans but minimal action can score higher than a company with excellent practices but limited reporting infrastructure. Use the discipline of disclosure to drive real data quality, not to optimise the score.
Pre-disclosure readiness is often more valuable than the first submission.
Many organisations benefit more from 12 months of building the data foundation (Scope 1 measurement, water accounting, nature baseline) than from rushing a first submission with incomplete data. A well-prepared first submission scores better, requires less rework, and reflects genuine practice.
Build the data foundation once. It serves multiple frameworks.
A Scope 1 carbon footprint, a water account, a biodiversity baseline, and a product traceability record satisfies 70-80% of CDP, TNFD, SBTN, and SBTi simultaneously. There is no need for a separate project for each framework.
Understand what CDP is for and who it serves.
CDP was built by and for institutional investors. Its questionnaires reflect investor information needs, not necessarily the most important environmental impacts for your specific organisation. Useful discipline, but not a neutral arbiter of environmental performance.
Know what you are working with operationally.
In early 2024, CDP reduced its global workforce by approximately 20 per cent, from around 541 staff across 15 countries. CDP's own public statement cited operating costs growing faster than income, and framed the reduction as releasing resources for technology investment. In the 2025 disclosure cycle, CDP publicly acknowledged a scoring error in which 'not applicable' responses were incorrectly marked as 'unanswered', causing a number of organisations to receive lower scores than they had earned. CDP identified the issue after scores had been published, resolved it, and issued corrected scores. Both are matters of public record, drawn from CDP's own statements. They are relevant when planning the timeline and contingency for a CDP engagement: for a first submission aimed at a scored result, allow time for post-publication review before using a score in any external communication.
The voluntary case for CDP has weakened as mandatory requirements have spread.
Company disclosures to CDP fell in 2025, the first decline in the organisation's 25-year history. The primary cause is likely the spread of mandatory disclosure requirements: more than 40 jurisdictions now have live or forthcoming obligations that substantially overlap with what CDP measures. A University of Zurich study found that mandatory disclosure rules reduce the probability of voluntary CDP participation by around 5.5 per cent. If your organisation is already in scope of CSRD, UK SRS, or IFRS S2-based requirements, those obligations take precedence and should be addressed first. CDP's strongest remaining case in that context is as a supply chain engagement platform and a benchmarking tool, not as the primary route to environmental disclosure.
Pre-disclosure readiness
Many organisations are not ready to disclose, and that is fine. The data foundation you need for a credible CDP submission is the same foundation that serves every other framework. Building it carefully, before you submit, is almost always more valuable than a rushed first score.
For a small land-owning organisation, for example, the most valuable first step is not submitting a CDP questionnaire: it is commissioning a Scope 1 carbon footprint (covering fuel, livestock, and any other direct sources) and a biodiversity baseline. Those two data assets, once measured, simultaneously satisfy the foundational requirement for CDP, SBTi target-setting, and TNFD dependency disclosure. Three frameworks, one piece of work.
The pre-disclosure data foundation
Alternatives and context
The mandatory landscape
The frameworks below are not alternatives in the sense of being a choice. If your organisation is in scope, they are legal obligations. CDP participation does not satisfy mandatory reporting requirements: as of 2026, no UK or EU regime has formally recognised a CDP submission as equivalent on a blanket basis.
Applies to quoted companies, large unquoted companies, and LLPs meeting size thresholds. Covers Scope 1 and 2 emissions, energy use, and an intensity metric. Embedded in the directors' report and subject to the same audit framework as financial reporting. Substantial overlap with CDP's climate questionnaire.
Covers climate, biodiversity, water, resources, pollution, social, and governance matters. Requires assurance. Applies to large EU companies and large EU subsidiaries of non-EU groups. Substantially supersedes voluntary disclosure for in-scope organisations. CDP may remain useful as a data collection mechanism feeding ESRS disclosures, but does not substitute for them.
The UK's SDS is based on IFRS S2 (climate) and will be mandatory for premium-listed companies. CDP aligned its 2023 climate questionnaire to IFRS S2: a CDP submission supports IFRS S2-aligned reporting but does not substitute for it in regulated contexts.
Mandatory for UK premium-listed companies, large companies, and financial institutions. Embedded within CSRD/ESRS and UK regulatory requirements. CDP's climate questionnaire has incorporated the TCFD four-pillar structure since 2018. If mandatory TCFD-aligned reporting already applies, a CDP submission overlaps substantially but is not a substitute.
Voluntary frameworks: what else exists
These frameworks serve different audiences and purposes from CDP. In most cases they complement rather than replace it.
GRI Standards
Global Reporting Initiative
The oldest comprehensive sustainability reporting framework. GRI is stakeholder-centric rather than investor-centric: its standards focus on an organisation's impacts on people and planet, not on how environmental issues affect the business. Often used alongside CDP rather than instead of it. CDP targets investor information needs; GRI targets a wider audience including employees, communities, and civil society.
SBTi
Science Based Targets initiative
Not a disclosure platform. SBTi validates whether a company's proposed emissions reduction targets are consistent with limiting global warming to 1.5°C. CDP co-founded SBTi; CDP's questionnaire asks whether companies have set validated science-based targets. If setting a credible climate target is the objective, SBTi is the relevant body. Progress is then disclosed through CDP or regulatory channels.
EcoVadis
Supply chain sustainability ratings
A commercial platform covering environment, labour, ethics, and sustainable procurement. Used by large buying organisations to assess suppliers. A CDP score and an EcoVadis rating serve different audiences: CDP is investor-facing; EcoVadis is procurement-facing. Relevant if your corporate customers use EcoVadis in their supply chain due diligence.
B Corp Certification
Administered by B Lab
A comprehensive certification assessing governance, workers, community, environment, and customers. B Corp is not a disclosure framework: it requires organisations to meet verified performance standards and embed accountability into their legal structure. Does not satisfy mandatory disclosure requirements. Most relevant for organisations seeking to make environmental and social commitments operating constraints, not just reporting obligations.
Where to go next
Framework overview
How CDP relates to TNFD, SBTi, SBTN, UK SRS and the full framework landscape
Corporate reporting
How disclosure frameworks connect to corporate strategy and measurement
Disclosure data flows
How disclosed data moves from companies to investors and regulators