CDP 2026: Bridging the Gap Between Data and Action

As a voluntary yet globally recognized disclosure system for environmental transparency, CDP maintains the most extensive database of corporate and municipal environmental impact data. The foundation of this system is an annually updated, integrated questionnaire that defines how organizations report their environmental data.

The 2026 CDP disclosure cycle marks a major shift towards a more comprehensive, nature-positive reporting landscape. As organizations face accelerating climate impacts and biodiversity loss, the market's need for high-quality, comparable intelligence is at an all-time high. CDP is evolving to meet this demand, focusing on strengthening the link between the data organizations report and the environmental actions they take.

Core Updates for CDP Questionnaire 2026

1. The Debut of Ocean Disclosure 

Recognizing the vital role of marine ecosystems in global economic stability, CDP is introducing ocean-related questions for the first time:

• Who it's for: All organizations using the full corporate questionnaire can "opt-in".
• Scoring: This content will not be scored in 2026, giving companies time to establish data collection processes.

In response to strong market demand and emerging regulations, CDP is expanding its framework to include the ocean, enabling organizations to surface critical data on the blue economy and marine biomes. This integration bridges a significant reporting gap, providing capital markets with the transparency needed to drive corporate action and protect vital aquatic ecosystems.

2. Expanded Forests & Nature Scope 

CDP is broadening its forests coverage to include commodities with significant deforestation and conversion impacts:

• New Scored Commodities: Cocoa, coffee, and rubber join timber, palm oil, cattle, and soy as scored commodities.
• Unified Scoring: All seven commodities will now contribute to a single, comprehensive forests score. Since they are all scored together now, one weak link can drag down the whole forest score.

CDP aims for a comprehensive reporting landscape where organizations manage all land-related dependencies and risks, specifically focusing on the elimination of ecosystem conversion within global supply chains. By prioritizing high-impact commodities like cattle, timber, cocoa, and rubber, the framework aligns with AFi and SBTN standards to drive transparency in protecting forests and natural ecosystems.

3. Enhanced SME Experience

Small and Medium Enterprises (SMEs) are seeing significant upgrades to their reporting journey:

• The "A List" is open: For the first time, leading SMEs can achieve an "A" score for Climate Change (previously capped at "B").
• New Nature Modules: SMEs can now disclose on Forests and Water Security through new (unscored) modules. The SME questionnaire now consists of 10 instead of 8 modules.

4. Continuous Framework Alignment

CDP is pursuing a  "write once, read many" approach:

• Updates to the 2026 questionnaire will strengthen the alignment with the TNFD recommendations, the GRI 303 Water & Effluents standard and the GHG Protocol Land Sector and Removals Guidance.
• Data disclosed once through CDP can be used to meet multiple market, regulatory and investor requirements while enabling disclosers to reduce their reporting burden.

New Metrics to Track

Before you start the 2026 disclosure cycle, be aware of some specific new data points:

• Ocean: Risk assessment for marine dependencies, priority locations, and ocean-related targets.
• Forests: Traceability and DCF (deforestation- and conversion-free) status for cocoa, coffee, and rubber.
• Water: Wastewater treatment levels, discharge volumes, and compliance with regulatory standards.
• Plastics: Metrics on reuse models (refill/return), packaging formats and packaging design for recycling or composting.
• Climate: Some changes in the energy-related activities section (that concerns energy consumption & purchases)
• Adaptation and Resilience: Richer data on how organizations are responding to physical environmental risks.

You can find the official key changes to the 2026 questionnaire here: Preparing for CDP’s 2026 disclosure cycle (as of Feb 2026).

Key Essential Criteria (EC) Updates for 2026

In 2026, CDP is not adding any entirely new essential criteria but is introducing several revisions to clarify existing requirements and reflect the updated questionnaire structure. These baseline requirements ensure a consistent minimum standard for transparency and environmental stewardship across all scoring levels.

• Climate Change (EC-CC1 & EC-CC2): Organizations (including Financial Services) must now assess the quality of their processes for identifying and managing environmental risks to be eligible for Leadership-level scoring.
• Executive Incentives (EC-CC4): A new allowance is introduced for organizations (such as state-owned entities) that cannot provide executive incentives due to legal restrictions in their operating jurisdictions.
• Expanded Forest Commodity Scope (EC-F12): Essential criteria for exclusions, origin, targets, and traceability will now apply to cocoa, coffee, and rubber, aligning them with the four existing scored commodities.
• Forestry Disclosure Threshold (EC-F3): To offer more flexibility for commodities early in their disclosure journey, the threshold for excluding a commodity due to small volume has been increased from 1% to 5%.
• Risk Assessment Focus (EC-F4 & EC-W5): For both Forests and Water Security, criteria regarding specific risk types and tools have been removed to encourage organizations to focus on high-quality assessments across their entire value chain and multiple time horizons.
• Tailings Dams (EC-W3/EC-W4): Criteria for the Coal and Metals & Mining sectors have been revised to require specific data in new columns rather than text fields to improve data comparability.

Practical Tips for Responding Efficiently to the CDP Questionnaire in 2026

1. Start preparing at an early stage

Answering the CDP questionnaire requires close cooperation between different departments. Even if the submission is not due until mid-September, the preparation process should start early. Structured planning helps to avoid bottlenecks and improve data quality.

A) Gap analysis: where were gaps or problems in the last CDP scoring?

Before companies start collecting data, it is worth taking a detailed look at the last questionnaire submitted and the CDP scoring. Important steps:

• Evaluation of previous year's answers: Which questions were only partially or insufficiently answered?
• Scoring analysis: Which aspects contributed to the score or caused deductions?
• Comparison with current CDP requirements: Are there new priorities or stricter evaluation criteria?
• Identify optimization potential: Where can processes or data quality be improved?

Companies aiming for a better rating should pay particular attention to areas in which they received no or only limited points last year — for example, in climate strategy or the verification of emissions data. As a CDP Accredited Solutions Provider, we are familiar with typical weaknesses in scoring and can provide targeted support for optimization, as well as properly considering the updates of the 2026 disclosure cycle.

B) Collect & update ESG data

ESG data collection is one of the most time-consuming steps in the CDP process. It is particularly challenging to collect consistent and verified data from various company divisions and external sources:

• Identify relevant data sources: Which systems (e.g. energy reports, sustainability platforms) contain the required information?
• Calculate Scope 1, Scope 2 and Scope 3 emissions: For many companies, recording and validating Scope 3 emissions (indirect emissions from the supply chain) is the biggest challenge.
• Standardize sustainability indicators: Uniform definitions and measurement methods facilitate reporting and prevent inconsistencies.
• Observe Essential Criteria: CDP specifies minimum requirements for various questions that companies must fulfill in order to receive points. For example, an answer on climate strategy often requires detailed information on targets, measures, and progress measurement.

Tip: Companies with complex supply chains should contact suppliers at an early stage in order to obtain the necessary data for Scope 3 balancing.

C) Gathering documents & evidence

CDP attaches great importance to the verification and traceability of the information submitted. It is therefore crucial to compile relevant documents and evidence at an early stage:

• Strategies & guidelines: Climate strategy, emission reduction targets, ESG guidelines
• Certificates & reports: ISO standards, TÜV reports, Science Based Targets (SBTi) validations
• Risk assessments: Scenario analyses on climate risks, supply chain risks, physical and transitory climate risks
• Verified emissions data: External verification reports for Scope 1, Scope 2 and ideally Scope 3

It is particularly important for companies aiming for a CDP A rating to be able to provide external verifications. From 2024, full verification of Scope 1 and Scope 2 emissions will be mandatory — anyone wishing to achieve an A grade must also have at least one Scope 3 category externally verified.

2. Keep an eye on important deadlines

CDP sets a uniform deadline for all companies. Although the exact date for 2026 has not yet been published, the deadline is the week of September 14, 2026.

Tip: Schedule a sanity check 2-4 weeks before submission to avoid mistakes!

3. Avoid the most common pitfalls

Many companies lose valuable points due to avoidable errors in the questionnaire. Pay particular attention to the following stumbling blocks:

• Unfilled tables: Tables must be completely filled in, otherwise they will remain marked as "in progress".
• Use correct units: Check whether your internal data matches the CDP specifications.
• Observe response logic: Follow-up questions may be activated if you give certain answers.

Tip: CDP will increasingly check whether information on climate-related risks is consistent with financial reports and sustainability strategies.

4. Use CDP guidance effectively

CDP provides detailed guides for the individual question categories. These guides help you to better understand the requirements and to formulate answers correctly. Click here for the guides from the CDP Helpdesk.

Why ESG Software Makes the CDP Process Easier

Answering the CDP questionnaire is time-consuming and requires accurate and consistent data collection. Sunhat's Collaborative Proof Platform helps companies to make this process more efficient and significantly reduce the workload.

1. Automated data processing & intelligent linking

• Leveraging Answers Across ESG Frameworks: Sunhat enables answers from one ESG framework, such as CDP or ESRS, to be leveraged across others that ask similar questions. This allows for the targeted reuse of existing information, reducing the need for redundant data entry.
• Tagging & search function: The targeted tagging of answers means that relevant content can be found in the shortest possible time and used efficiently.

2. Optimized collaboration & error reduction

• Project management functions: Tasks can be clearly assigned, progress tracked and errors avoided thanks to a structured system — without time-consuming coordination by email.
• Versioning & data history: Previously submitted responses are saved and can be tracked and adjusted for future reporting cycles.

With Sunhat as CDP Accredited Solutions Provider you can make the CDP process more structured and time-saving, avoid redundancies and sustainably optimize your ESG reporting.

Prepare now & keep an eye on deadlines!

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