The evolution of disclosure:
Carbon Disclosure Project (CDP)


Released on 30th April 2024, CDP has made changes to its platform and questionnaire to ensure the data collected drives action amongst the businesses that participate in the process. 

Key takeaways:

  • The newly released CDP Corporate Questionnaire does not mean that all companies will have to answer datapoints on all natural capital themes – the process will remain the same i.e. questions on forests and water will continue to be presented to companies based on how relevant these issues are to their business and activities.

  • Questions on the use of plastics have been presented to companies disclosing on water security. Questions on biodiversity have been presented to companies disclosing on climate. Neither of these questions will be scored in 2024, as respondents familiarise themselves with these significant changes to the questionnaire.

  • An integrated report doesn’t equate to an integrated score – companies will be scored separately on each climate, water and forests questionnaire (depending on what they want to disclose on)

Their Corporate Disclosure Framework document published shortly after the 2023 results went live in February 2024 details all key changes to CDP’s 2024 Disclosure Framework for the purpose of supporting companies and data users in understanding what to expect from the 2024 questionnaire process. 

Aside from scaling environmental data disclosure to align with relevant frameworks, the key takeaway for companies is that CDP has now integrated its questionnaire. What was once a separate questionnaire (for each of the three natural capital disciplines i.e. climate change, water security and forests), is now formed as a more intuitive format for preparers of this information and to encourage a shift towards holistic environmental management and prepare disclosers to respond better to meet the needs of markets, investors and regulatory demands.

Context behind an integrated approach

A key driver for the integrated approach is that the understanding that the climate crisis and nature go hand-in-hand. According to PwC’s analysis in 2023, more than half of the world’s economy – equivalent to about US$58 trillion – is at risk from nature and biodiversity loss. Simultaneously, six of the nine planetary boundaries have already been breached according to various scientists – nature risk is not just a financial risk it’s also an existential risk.

The Intergovernmental Panel on Climate Change (IPCC) and the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES) agree that climate and nature must be addressed simultaneously and in an equitable way. This includes conserving, protecting, and restoring ecosystems, adopting more sustainable agricultural and forestry practices, and pursuing a circular economy. In this context, it is more important than ever to accelerate corporate action on water security and deforestation and to act on the full range of environmental issues. CDP’s move to an integrated questionnaire format enables its stakeholders to better assess all environmental impacts in direct operational activity, supply chain, and financial decisions.

Interoperability matters

CDP has collaborated with leading reporting standards and frameworks bodies in an ongoing bid to reduce duplication of effort. The current status of associated alignment is as follows: 

  1. IFRS S2 Climate-related Disclosures – the 2024 questionnaire will be aligned with the IFRS S2 standard issued by the ISSB. 
  2. European Financial Reporting Advisory Group (EFRAG) – alignment with ESRS, and subsequently the CSRD due to forming part of the same legal framework, is under review. 
  3. Task Force on Nature-related Financial Disclosures (TNFD) – the questionnaire is currently partially aligned. 
  4. US Securities and Exchange Commission (SEC) proposed climate disclosure rule – alignment is under review following a ruling this month which requires the largest US-listed companies to publish their material operational and energy-related greenhouse gas (GHG) emissions and other climate-related financial information.

These collaborations will allow increased alignment, thereby reducing the reporting burden on companies and ensure corporate disclosures have the widest application in the market – driven by the highest ambition – and that they deliver consistent, comparable and decision-useful sustainability-focused data to capital markets, procurement teams and policymakers worldwide.  

Companies will be scored separately on climate, water and forests. However, there will be an increased focus on the inclusion of two new categories, biodiversity and plastics.

Moving forward

The CDP questionnaire may be formatted slightly differently, but the information CDP is requesting from companies and the actions it is looking to drive will remain fundamentally the same. 

CDP is looking to streamline this process and make it as smooth as possible while also taking into consideration the importance of addressing the nature crisis alongside climate crisis. 

For example, looking historically at some of the questions around governance, these were repeated across all three CDP questionnaires. Now, CDP will be combining these questions (where practicable) to offer a better user experience for disclosers and to encourage companies to think holistically about environmental management. In a similar vein, supply chain questions, presented to organizations within a companies’ supply chain, have also been spread throughout the questionnaire and are no longer in a standalone module.  

As far as scoring and ranking, companies will be scored separately on climate, water and forests – despite the questionnaire integration journey. However, there will be an increased focus on the inclusion of two new categories, biodiversity and plastics, which will remain unscored for 2024 but will likely feature looking ahead.

How Black Sun can help you

We understand the apprehension around a changing process, especially one as impactful as CDP. However, we also understand the importance of getting ahead of the curve and adequate preparation. Our range of services (including and not limited to the below) help prepare companies for the next CDP cycle and improve scores through improving sustainability strategies.

  • Transition planning: we have extensive experience in supporting companies in the development of strategic ambition and operationalization of its climate strategy. We can help you to understand specific actions needed to deliver on your climate commitments, the financial implications of this plan and how to embed it within your business by ensuring the necessary governance, ownership and control measures are in place.
  • Regulatory expertise: our experts remain abreast and ahead of emerging regulations and reporting frameworks (e.g. ISSB and CSRD), as we guide companies on the road to compliance and beyond.
  • Stakeholder engagement: our experts understand that to effectively implement change, mobilising key stakeholders is essential. We are proven communicators that have the ability to ensure all affected stakeholders (both internal and external) understand and are aligned to the company ambition, to ensure the smooth implementation of your transition plan.

If you would like to speaker to a member of our Advisory Team about preparing for the next CDP cycle please get in touch with our Head of Business Development, Naomi Hawkins

About Black Sun

Black Sun Global is an international stakeholder engagement agency that’s been helping global brands drive change for more than 30 years. At the forefront of corporate communications, we offer integrated solutions, covering strategy, reporting, ESG advisory and digital activation – all powered by insights, technology, and market-leading expertise.

By addressing stakeholder interests, we turn one-way communications into engaging two-way dialogues that deepen relationships, fuel innovation, and drive more sustainable business practices. 

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