By Lauren Anderson, Sustainability Analyst; Dr. White, Lead Trainer; Brian Noveck, EVP, Operations; Nancy Mancilla, President

For over 20 years, CDP has been asking companies to disclose their climate impacts, beginning with a mailed postcard.  As the reporting landscape evolves and expands, the demand for environmental disclosure continues to grow.  For the 2024 reporting year, over 700 financial institutions representing $142+ trillion in assets are requesting 33,000+ companies to disclose. This year, CDP rolled out a number of changes to their questionnaire, and the submission deadline is fast approaching (Oct. 2 for scoring purposes).   

Notable changes for this year:

CDP launched both a new disclosure framework and a new technology platform, designed to offer significant improvements in how organizations disclose and drive climate action. In addition to the introduction of a new, dedicated SME questionnaire, the most significant changes are reflected in the integration of environmental issues and additional alignment with standards and frameworks. Adjustments made to the technology platform and the timeline also require adjustments to organizational approaches to response development.  

Details on Integration and Alignment 

Over the years, CDP has broadened its scope to incorporate reporting information beyond climate to include deforestation, water security, biodiversity and plastics. The 2024 reporting year is the first year the questionnaire is integrated, removing the need for organizations to response to multiple questionnaires (when relevant). The climate change, water, and forest questionnaires have been integrated into one document so that previously redundant information requests across former separate questionnaires are eliminated. Instead, overarching questions related to governance, strategies, and dependencies, impacts, risks and opportunities (DIRO) are asked for environmental issues in general. When specific environmental issues are relevant or self-selected, organizations are also directed to enter related performance data. Similarly, organizations are offered separate scores for climate, forest and water responses. 

In addition to introducing the integrated framework, CDP made several additions and modifications to questions. Most of these stemmed from the goal to continue to align the questionnaire with evolving standards, such as the International Sustainability Standards Board’s IFRS S2 climate standard, the Taskforce on Nature-related Financial Disclosures (TNFD), European Sustainability Reporting Standards (ESRS) and the Accountability Framework initiative (Afi).  There are also a handful of new supply chain questions spread throughout the questionnaire rather than in a standalone module.   

To aid organizations in mapping and analyzing these additions and modifications, CDP has provided trainings, summary documents and a workbook with question-level changes that detail the adjustments and the drivers behind each.    

Technology 

Beyond the adjustments to the content of the questionnaire, CDP went a step further and developed a new disclosure Portal. The new system is intended to be more user-friendly, easier to navigate and offer increased self-service options and opportunities for collaboration.   

Timeline 

Due to the many adjustments to CDP’s questionnaire and online system, the 2024 response timeline was adjusted. Updated questionnaire guidance was offered starting in May and, for scoring purposes, the Portal will close on Oct 2. (adjusted from the original date of Sept. 18). Keep a keen eye on communications from CDP after this disclosure cycle as they’ve communicated an intent to realign with their more standard cycle (i.e., a July deadline).  

Challenges in Responding 

Regardless of where your organization is on its sustainability journey, responding to CDP’s questionnaire is challenging.  Notably, with this year’s changes, the need for additional data and content from your internal stakeholders has grown and there have been technology-related Portal issues throughout the launch of the questionnaire. At the same time, the methods to facilitate internal and external collaboration within the Portal remain limited, generally still requiring review outside of the platform.   

With these challenges in mind, we continue to communicate the importance of: 

• Gaining familiarity with new and integrated standards such as IFRS S2, TNFD, ESRS and AFi to be better prepared for response development 

• Creating a data management plan and/or documentation to ensure that completion of your performance metrics do not slow down the response process 

• Mapping out a response development and review timeline, agreed upon by all stakeholders 

We’re here to support you

ISOS Group and our broader Environ team provide services to many organizations responding to CDP. Our practices support: 

• Up to date training on CDP reporting 

• Development of performance data within our Scope 5 platform and by our consulting teams 

• Third-party verification of data submitted to CDP 

• Gap assessments of your organization’s past responses and scores 

• Response development and guidance 

• Services to get you farther along your reporting journey, including climate transition planning, target development support and energy management 

As the CDP scoring deadline draws near, make sure you plan for a debrief and review process after your submission is complete. Based on your reflections, if you’re considering support for CDP submission in future reporting cycles, reach out to our team to learn more about the level of service that’s right for your organization.