CDP Disclosure: What Every Organization Needs to Know in 2025

Background

The Carbon Disclosure Project (CDP) was founded in 2000 to promote environmental transparency and accountability by making climate reporting and risk management a common practice. In 2013, CDP expanded its scope to include water security, forests, biodiversity, and plastics, reflecting a more comprehensive approach to environmental impact assessment.
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Key Takeaways

• CDP is a leading standard for voluntary environmental disclosure with over 23,000 companies participating each year, representing two-thirds of global market capitalization.
• CDP reporting requirements vary by industry and company size, but all participating companies must disclose emissions and energy consumption data.
• Third-party verification of scope 1, 2, and 3 emissions is critical to achieving a high score on CDP disclosures.
• Benefits for participating companies include customer traction, enhanced access to capital, energy cost savings, and benchmarking performance against peers
• Gravity streamlines CDP disclosure through direct API integration, allowing customers to collaborate on questionnaire responses and submit directly from the Gravity platform, using last year’s disclosure as a starting point.

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Who Discloses to CDP?

CDP disclosure is voluntary. Companies are the primary participants in CDP disclosure, with almost 23,000 companies, collectively representing two-thirds of global market capitalization, disclosing through CDP in 2024. Participants range from multinational corporations to small and medium enterprises (SMEs), for which CDP has developed a simplified questionnaire with fewer data points to streamline the reporting process. Manufacturing has particularly strong representation, comprising 39% of companies scored on climate by CDP. Companies can also participate in CDP's Supply Chain program, where they not only disclose their own environmental data but also request their suppliers to disclose.

Financial institutions also participate in CDP disclosure, including banks, asset managers, and private equity firms. Investors can report on their own operations and portfolio impacts, as well as request disclosure from portfolio companies.

In recent years, CDP disclosure has expanded beyond the private sector to include cities, states, provinces, and regional governments. CDP provides a dedicated platform for cities to disclose their environmental data, with more than 500 cities participating each year. In 2019, CDP partnered with ICLEI (Local Governments for Sustainability) to create a unified reporting system for local and regional governments as well.
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Benefits of CDP Reporting

CDP has become a leading global standard for environmental disclosure, with participation growing every year. As stakeholder expectations and regulatory requirements for environmental transparency continue to increase, CDP provides a framework for organizations to demonstrate their commitment to sustainability.

Organizations that embrace CDP as a strategic opportunity, rather than just a reporting exercise, can benefit in a variety of ways. Potential benefits of CDP disclosure include:

• Customer traction: Major companies like Nike, Airbus, Bank of America, Dell, and Microsoft are now asking their suppliers to disclose to CDP.
• Enhanced access to capital: Some investment funds require companies to have a CDP score of B or higher for inclusion in their portfolios.
• Energy cost savings: Measuring energy consumption and emissions allows companies to pinpoint energy efficiency opportunities and prioritize cost-saving projects.
• Benchmarking against peers: CDP scores allow companies to understand their relative environmental performance as compared to industry peers.
• Improved ESG ratings: CDP data is used by rating agencies such as Bloomberg, MSCI, and Euronext, influencing investment decisions.
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CDP Disclosure Requirements

The CDP questionnaire is customized based on company size, sector, and the relevance of specific environmental issues. The questionnaire includes a series of high-level questions, as well as sector-specific ones.
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Climate Change Questions

All companies participating in CDP disclosure must report on emissions and energy metrics, regardless of industry or company size. Climate topics include:

• Greenhouse gas emissions data (scopes 1, 2, and 3)
• Energy consumption 
• Climate-related risks and opportunities assessment (aligned with TCFD)
• Governance and strategy for addressing climate change
• Emissions reduction targets and initiatives
• Internal carbon pricing (if applicable)
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Water Security and Forests Questions

Companies are required to respond to questions on water security and forests if at least one of three conditions is met:

1. External Request: The company has been asked to disclose on these topics by an investor, customer, or financial institution participating in CDP disclosure.
2. Industry Impact Classification: CDP’s Activity Classification System (ACS) determines that a company's business activities have significant impact on forests or water. 
3. Self-Assessment: The company indicates during questionnaire setup that they have identified substantive forests or water-related issues in their operations.
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Additional Topics

CDP began incorporating biodiversity questions into its questionnaire in 2022 as part of its strategy to address broader environmental issues. CDP also introduced plastics-related questions in 2023, initially as part of the water security questionnaire. These topics were folded into CDP’s integrated questionnaire in 2024, but are not yet factored into the organization’s scoring methodology.
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Third-Party Verification

CDP encourages companies to have an independent organization verify the accuracy and thoroughness of the data they submit. Over the past several years, third-party verification has become a cornerstone of credible CDP disclosure, particularly for organizations aiming to achieve leadership status, and is now mandatory for companies seeking A-List recognition.

For the 2023-2024 reporting cycle, CDP significantly raised the verification threshold required for leadership scores. Companies must now have third-party verification covering 100% of their Scope 1 and Scope 2 emissions, up from the previous 70% requirement. Additionally, leadership-level scores require verification of at least 70% of emissions from a minimum of one Scope 3 category.
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Scoring Methodology and Benchmarks

CDP grades disclosures on a scale from A to F, evaluating both transparency and performance on environmental issues across governance, strategy, risk management, metrics, and targets. The scoring levels include:

• A/A- (Leadership): Implementation of best practices in sustainability management
• B/B- (Management): Implementation of several actions to address environmental issues
• C/C- (Awareness): Recognition of environmental impacts and risks, including addressing some environmental issues
• D/D- (Disclosure): Basic transparency in reporting, but a need to take action to address environmental issues
• F: Failure to provide sufficient information

CDP provides several mechanisms for benchmarking companies against industry peers, allowing organizations to understand their relative environmental performance in context. CDP's A-List represents the highest level of environmental leadership and serves as a benchmark within each sector. Companies can gauge their relative performance by comparing their score with sector peers who have achieved A-List status. 
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Reporting Timeline and Process

The CDP disclosure cycle follows an annual schedule, though the exact timing of each step varies from year to year. Key dates for 2025 are as follows:

• Spring 2025: Updated questionnaires and reporting guidance released
• June 16, 2025: Online response system opens for submissions
• September 16, 2025: Deadline for submissions that will receive a score
• Fall 2025: Scores released to participants

Companies must register with CDP and designate a submission lead, and they may need to pay an administrative fee depending on their size and location. Companies required to pay an administrative fee need to do this before submitting their response.
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How Gravity Can Help You Disclose to CDP with Confidence

Companies disclosing to CDP face multiple challenges, from collecting comprehensive data across operations to calculating emissions and translating disclosure into action. Whether you're a first-time discloser or aiming for A-List status, having the right tools and support is essential.

Gravity has been named an accredited solutions provider (ASP) with CDP, meaning CDP recommends Gravity as a preferred provider to the more than 23,000 companies participating in its disclosure system. CDP has also recognized Gravity as its first Sustainable Finance ASP in North America for the company’s track record in supporting private equity firms and other financial institutions. Read more about Gravity’s accreditation here.

Here's how we can support you:

• API integration: Gravity streamlines disclosure to CDP for its customers by integrating with the non-profit’s API. Beginning in the 2025 disclosure cycle, Gravity customers can collaborate on their CDP answers and report to CDP directly from the Gravity platform, including emissions data, energy consumption, and narrative questions.
• Draft responses: If you disclosed to CDP last year, Gravity will pull forward the answers to key questions to give you a starting point for this year’s questionnaire drafts.
• Collaboration & progress tracking: Gravity empowers you to assign parts of your CDP disclosure to colleagues or other stakeholders - no login required - and track progress against reporting deadlines.
• Repurposed responses: Gravity maps similar questions across reporting frameworks and automatically provides draft answers based on your previous responses, accelerating reporting to CDP and frameworks with overlapping questions. 
• Efficient data collection: Calculating emissions data across scopes 1, 2, and 3 is often the most time-consuming element of CDP reporting. Gravity's utility bill scanning feature and direct API connections process thousands of documents instantly — without manual error. Our supplier engagement solution and customizable surveys enable efficient collection of value chain data, essential for the highest CDP scores.
• Target setting and progress tracking: Gravity's platform supports the development and monitoring of science-based emissions reduction targets — a critical component for achieving Leadership-level CDP scores. Our analytical tools help you model various reduction scenarios and track progress against targets in real-time.
• Verification support: CDP’s scoring methodology places significant emphasis on third-party verification, particularly at the Leadership level. Gravity's platform maintains comprehensive data trails, attaches supporting evidence for each data point, and streamlines the verification process by keeping all documentation in one place.
• Energy cost savings: Gravity empowers its customers to go beyond reporting and take action by using energy use data to identify energy efficiency opportunities with positive ROI. We accelerate implementation by connecting customers to a network of trusted vendors, allowing customers to turn CDP reporting into a driver of business value.

Frequently Asked Questions

1. What is CDP? 

CDP is a global non-profit organization that runs a voluntary environmental disclosure system for companies, cities, states, and regions, encouraging transparency on climate change, water security, and deforestation.

2. What type of companies disclose to CDP?

A diverse range of organizations disclose to CDP, including public and private companies of all sizes, from multinational corporations to small and medium enterprises (SMEs). In 2023, approximately 23,200 companies worldwide, representing two-thirds of global market capitalization, participated in CDP disclosure. 

3. How often do companies need to report to CDP?

CDP reporting occurs annually, with questionnaires typically opening in Q2 and submissions due by September for scoring. Reporting cycle timing varies from year to year.

4. What information needs to be reported to CDP? 

Companies typically report data on greenhouse gas emissions, climate change strategy, water usage, deforestation impacts, and increasingly on biodiversity and plastics.

5. How does CDP relate to other sustainability reporting frameworks? 

Many of the core metrics within CDP’s questionnaire align with other major frameworks, including the International Sustainability Standards Board (ISSB), Task Force on Climate-related Financial Disclosures (TCFD), Global Reporting Initiative (GRI), and Sustainable Accounting Standards Board (SASB).

6. How are CDP scores determined? 

Scores are determined based on disclosure completeness, management actions, and leadership in environmental practices, with grades ranging from A to F.

7. Can small companies participate in CDP?

Yes, CDP has introduced a simplified SME questionnaire with fewer data points to help smaller organizations streamline their sustainability reporting.

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