CDP is raising the bar on climate and environmental disclosure

As the 2026 CDP disclosure cycle approaches, companies face an evolving landscape of environmental reporting expectations. With more than 23,100 organisations participating in 2025, CDP remains one of the most widely used global disclosure frameworks to share climate, water and forests data with investors, customers and regulators. Disclosure is no longer driven solely by voluntary sustainability goals. Market and regulatory pressures now require robust, transparent environmental data and strong governance of climate-related risks and opportunities.

In the 2025 cycle, CDP continued strengthening alignment with global baseline standards, including the IFRS Sustainability Disclosure Standards issued by the International Sustainability Standards Board (ISSB). With the implementation of IFRS-aligned requirements, such as the UK Sustainability Reporting Standards (SRS), CDP required responses to demonstrate greater consistency with financially material climate disclosures, governance structures and risk management processes.

The next phase of CDP disclosure

For 2026, CDP has published its timeline and is refining the questionnaire to strengthen alignment with global standards and frameworks such the GHG Protocol Land Sector and Removals Guidance, SBTN, TNFD, plastics disclosure and the GRI standards, supporting more consistent and interoperable reporting.

CDP is also widening environmental coverage, including first-time ocean-related questions. This reflects a critical environmental domain that remains underreported despite growing demand for data. Key dates include the release of the questionnaire and guidance in the week commencing 20th April and the scoring methodology released on the week of 27th April.

These revisions signal a clear shift: organisations will be expected to demonstrate how disclosure translates into meaningful action on climate, nature and resource security

How to prepare for the 2026 CDP cycle

Organisations that disclosed using CDP in 2025 will be familiar with the increasing complexity of the questionnaire, the time required to coordinate inputs across teams, and the challenge of ensuring consistent, decision-useful data. These experiences highlight where to focus ahead of the 2026 disclosure cycle.

• Strengthen environmental data systems

Treat environmental data with the same rigour as financial data. In many organisations, emissions data, particularly Scope 3, is dispersed across functions, reliant on manual consolidation and supported by inconsistent methodologies. This creates clear risks of gaps, inconsistencies and misalignment in disclosure.

With IFRS-aligned requirements such as UK Sustainability Reporting Standards (SRS) coming into scope, organisations will be expected to evidence decision-useful data. Gaps in data governance or methodology will become more visible and more difficult to defend.

As scrutiny of financially relevant information increases, weaknesses in data quality, governance and strategy will become more apparent to investors and other stakeholders. With continuity in the questionnaire structure, year-on-year comparability will further expose these gaps.

Use the 2026 cycle to formalise data governance, clarify methodologies and reduce reliance on manual processes to improve accuracy and credibility, particularly as organisations align with evolving standards such as the GHG Protocol Land Sector and Removals Guidance, SBTN and TNFD, which introduce additional data requirements and complexity.

• Build cross-functional governance

In practice, organisations often find that key data sits across different functions, with limited coordination or visibility. Sustainability teams may rely on inputs from finance, procurement or operations, but without clear ownership, this can create bottlenecks, delays and inconsistencies in disclosure.

Effective CDP responses depend on coordinated input across the organisation, from sustainability and finance to operations and supply chain, to ensure consistency, accuracy and strategic narrative alignment.

To address this, confirm clear internal ownership for each section of the questionnaire, align disclosure language with wider corporate reporting, and ensure leadership oversight is demonstrable and documented before submission.

• Stay ahead of evolving disclosures expectations

The expansion of CDP’s questionnaire scope to cover new environmental topics means teams need to stay informed and prepare to integrate these elements into reporting frameworks.

CDP’s scoring methodology places increasing emphasis on the quality and integration of disclosures. Greater scrutiny is applied to how organisations evidence governance oversight, link climate-related risks and opportunities to strategy, and substantiate targets with credible methodologies and progress tracking.

Monitor updates to both the questionnaire and scoring criteria as soon as they are released. Incremental narrative improvements alone will not be sufficient. Demonstrable progress, consistency and internal alignment are increasingly important.

• Use 2025 insights as a baseline

The continuity between the 2025 and 2026 questionnaires makes prior submissions a valuable reference point.

Many organisations lack a clear understanding of why points were gained or lost. CDP scoring is determined by specific criteria and methodological indicators, and without systematically mapping responses against these, it can be difficult to identify where gaps or inconsistencies exist.

Conduct a structured gap analysis against scoring criteria to identify targeted improvement opportunities and recurring gaps that may not be visible from CDP feedback summaries alone. Use this insight as a baseline to prioritise improvements and approach the 2026 cycle with clearer focus and direction.

• Use disclosure to inform strategy

CDP disclosure should not be treated solely as a scoring exercise. The process can highlight gaps between commitments and implementation, particularly where targets, risk management and governance structures are not clearly linked to strategic decision-making.

Use CDP as a diagnostic tool to identify gaps, strengthen internal alignment and better integrate environmental considerations into core business planning.

Act now to strengthen your 2026 CDP disclosure 

Focus now on preparing ahead of questionnaire release. Review your 2025 submission and scoring feedback in detail, and use this to conduct a structured gap analysis against the scoring criteria as soon as the 2026 questionnaire is available.

Confirm ownership across questionnaire sections and begin engaging internal stakeholders now. Validate key data points particularly where methodologies or assumptions were unclear in previous submissions to ensure consistency between governance, risk and performance disclosures.

Supporting organisations through CDP submissions, we consistently see the difference early preparation makes to both scoring outcomes and internal confidence. More structural enhancements, such as strengthening data systems or refining governance processes, may require a phased approach beyond submission.

Use the 2026 cycle to identify gaps and define a clear improvement roadmap, taking practical steps now while planning for deeper system changes over time.

To understand more, contact our team here.