CDP (Carbon Disclosure Project)

What is CDP (Carbon Disclosure Project)?

CDP operates an annual disclosure cycle. Investors (640 institutions with USD 127 trillion in assets in 2025) and purchasing organisations request that companies respond to CDP's questionnaire. The questionnaire covers governance, risk management, strategy, targets, and emissions data across environmental themes. CDP then scores each response from D- to A based on the completeness, quality, and ambition of the disclosure.

The questionnaire aligns with multiple frameworks simultaneously. CDP incorporated the TCFD recommendations as its backbone from 2018, and now maps to IFRS S2, the GHG Protocol, GRI, and (from 2024) the ESRS. For CSRD reporters, this interoperability matters. CDP and EFRAG published joint mapping guidance showing how CDP climate questions correspond to ESRS E1 datapoints, allowing entities to prepare one dataset that serves both the statutory sustainability statement and the CDP response.

Scoring follows a four-tier structure. The Disclosure level (D/D-) rewards simply responding. The Awareness level (C/C-) rewards identifying environmental risks. The Management level (B/B-) rewards acting on those risks. The Leadership level (A/A-) rewards best practice, verified data, and ambitious targets. From 2025, A-list eligibility requires external verification of at least one Scope 3 category.

Worked example

Client: Danish maritime logistics company, FY2025, revenue EUR 140M, IFRS reporter, 950 employees. Henriksen received a CDP score of C in the prior year and wants to improve to B for FY2025.

Step 1 — Map CDP questions to existing ESRS disclosures

Henriksen is a CSRD reporter and has already completed its double materiality assessment identifying climate change as material under ESRS E1. The sustainability team maps its ESRS E1 disclosures (Scope 1: 42,000 tonnes CO2e from vessel fuel, Scope 2: 380 tonnes CO2e from shore-based electricity, material Scope 3 categories: upstream fuel production and downstream customer logistics) to the corresponding CDP climate questions using the CDP-EFRAG interoperability table.

Documentation note: record the mapping between ESRS E1 datapoints and CDP question numbers. Attach the interoperability table version used and note any gaps where CDP requests data beyond the ESRS requirement.

Step 2 — Address scoring gaps from the prior C rating

CDP's feedback report identified two gaps preventing a B score. First, Henriksen disclosed no board-level oversight of climate risks (CDP question C1.1). Second, the company set no quantitative emissions reduction target (CDP question C4.1). The sustainability committee drafts a board mandate for climate governance and a target to reduce Scope 1 intensity by 15% by 2030 against a 2023 baseline.

Documentation note: record the specific CDP questions where the prior-year response scored below Management level. Document the remediation actions taken (board mandate, reduction target) and the evidence supporting each (board minutes, target methodology memo).

Step 3 — Obtain verification of Scope 1 emissions

Henriksen engages its statutory auditor to perform limited assurance on Scope 1 emissions under ISAE 3000 (Revised). The auditor traces fuel consumption data from bunker delivery notes to the emissions calculation (42,000 tonnes CO2e using IMO default emission factors for heavy fuel oil). The verification statement is uploaded to CDP as supporting evidence.

Documentation note: record the assurance standard applied (ISAE 3000 Revised), the scope of verification (Scope 1 only for this cycle), the emission factors used, and the source documentation reviewed. Cross-reference to the ESRS E1 working papers for consistency.

Step 4 — Submit and reconcile with the sustainability statement

Henriksen submits the CDP questionnaire before the July deadline. The sustainability team reconciles the emissions figures reported to CDP with the figures in the ESRS E1 sustainability statement. Both report Scope 1 of 42,000 tonnes CO2e and Scope 2 (location-based) of 380 tonnes CO2e. A Scope 3 figure of 28,500 tonnes CO2e appears in both disclosures.

Documentation note: record the reconciliation between CDP-reported figures and the ESRS sustainability statement. Flag any differences and document their cause (timing differences in data cut-off, boundary differences between CDP and ESRS). File the CDP submission confirmation and the prior-year feedback report.

Conclusion: Henriksen's CDP submission is defensible because the data reconciles to audited ESRS figures, scoring gaps from the prior year were addressed with documented evidence, and Scope 1 verification meets the standard CDP requires for Management-level scoring.

Why it matters in practice

• Teams treat CDP disclosure and CSRD reporting as separate workstreams with independent data collection. This produces inconsistencies between the emissions figures reported to CDP and those in the sustainability statement. When an assurance provider identifies a material difference between the two, the entity faces questions about data governance that neither the CDP score nor the ESRS opinion can resolve in isolation.
• Companies aiming for CDP's A-list frequently obtain verification of Scope 1 and Scope 2 but overlook the 2025 requirement for external verification of at least one Scope 3 category. Without Scope 3 verification, the submission caps at A- regardless of the quality of other disclosures.

CDP vs. TCFD

The distinction matters because CDP absorbed the TCFD framework into its questionnaire from 2018 onward. An entity responding to CDP effectively addresses the TCFD recommendations within the CDP structure. With the ISSB (IFRS S2) now superseding the TCFD as the global baseline, CDP serves as the primary voluntary disclosure channel that bridges ESRS, IFRS S2, and the former TCFD recommendations.

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