CDP 2026: A growing questionnaire. That’s good news, but...
CDP is adding an oceans theme, expanding its forest scope, and opening the A-list score to SMEs. Behind these changes lies a broader question: the ability of companies to keep up, year after year, with a questionnaire that never stops maturing.
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PAIs promised a common language for measuring investment impact.
Five years later, every stakeholder still speaks their own, and everyone is technically right, an observation I already made regarding SFDR PAIs last month. A similar point could be made about CDP.
With each cycle, the questionnaire expands, becomes more precise, and aligns with new standards. And that is genuinely good news. But as it continues to grow, CDP poses an operational question for companies: how can you keep up with this pace without it becoming a frantic annual catch-up exercise?
Sophie detailed in her review of the 2025 CDP cycle how CDP is establishing itself as a global environmental data infrastructure. I will focus here on what the 2026 cycle concretely changes for those who have to complete the questionnaire this year.
CDP in 2026: confirming its maturity
Since its inception, CDP has followed a consistent trajectory: starting from a climate-focused questionnaire to becoming a comprehensive environmental disclosure system, now covering climate, water, and forests. In 2026, a fourth theme is being introduced: oceans.
This expansion reflects a growing awareness that environmental risks are systemic and interdependent.
For 2026, the new ocean-related indicators are not yet scored. CDP is giving companies time to familiarize themselves with them before incorporating them into the scoring. This educational approach is worth noting.
This topic resonates with us directly: Ascend is a patron of Surfrider Foundation Europe, which works to protect the oceans, and we will be closely following the development of this new module in future cycles.
In the same vein, the scope of the Forests questionnaire is expanding significantly: cocoa, coffee, and rubber are joining the list of scored commodities (alongside cattle, palm oil, soy, and timber).
Five years after their introduction to the questionnaire, these commodities are now being scored, a sign that CDP believes companies have had enough time to structure their data on the subject.
Regarding scoring, there is a notable change: SMEs can now achieve an A score for the Climate questionnaire, which was impossible until 2025, when the maximum score available to them was B. This is a strong signal. CDP no longer wants to be seen as a tool reserved for large corporations.
CSRD alignment: a promise becoming reality
The most significant development of the last two years is not the questionnaire itself, but what is happening around it: the convergence between CDP and the European regulatory ecosystem.
In March 2025, CDP and EFRAG published an official mapping guide between the CDP questionnaire and the ESRS E1 (Climate) standard. Approximately 75% of the disclosure requirements in ESRS E1 align with CDP.
A company that rigorously completes the CDP Climate questionnaire already has a solid foundation for its CSRD climate-related obligations.
CDP is also working on an update to this mapping for the 2026 questionnaire and has committed to publishing new correspondences as soon as the post-Omnibus revised ESRS are formally adopted. The goal of this initiative is to reduce the reporting burden.
For sustainable finance professionals supporting their clients or portfolios through these processes, this convergence must be integrated into operational advice immediately. Responding to CDP is no longer a parallel exercise to CSRD. It is, in large part, laying the groundwork for it.
What the 2026 questionnaire requires
Behind the apparent stability of the 2026 questionnaire lie scoring changes that deserve attention. CDP itself indicates that the changes are limited and that 2025 responses remain a solid foundation, but the scoring criteria have shifted on specific points.
The modules on physical risks (modules 4 and 5) now expect an explicit treatment of resilience and adaptation: how the organization is concretely preparing for climate shocks, whether they be extreme weather events, resource shortages, or supply chain disruptions. This is no longer a matter of narrative strategy.
CDP is asking for concrete and comparable financial data. Purely qualitative responses, which may have sufficed in 2025, are now penalized.
Similarly, emissions verification is becoming stricter: scopes 1, 2, and at least one scope 3 category must now fall within the assurance scope. This is not a trivial change for companies that had previously only covered their direct emissions.
This is one of the classic CDP traps: the text of the questions may seem unchanged from one year to the next, but the scoring criteria evolve continuously. The difference between a B and an A is often found in these scoring subtleties that only a careful reading of the methodology reveals.
Keeping up the pace
CDP is growing. This is a positive development: it means the framework is adapting to the real-world complexity of environmental issues, incorporating new priorities (nature, oceans, adaptation), and converging with major regulatory standards.
However, this maturity comes with an operational cost. Each cycle introduces new indicators, new verification requirements, and new scopes.
At Ascend, part of my job is to ensure that the frameworks integrated into Harnest are up to date, and that the links between data points across different frameworks (CDP, ESRS, GRI, etc.) remain consistent from one cycle to the next.
When CDP adds a module, it’s not just another line in a questionnaire: it’s a mapping that must be re-verified against everything that already exists elsewhere.
It is deep, often invisible work, but I am proud to ensure that the companies using Harnest don't have to do it themselves every year.
They don't have to wonder if their framework is up to date: the information to be provided is guided, the audit trail shows exactly where they stand, and the history feature allows them to track their progress.
And if they report across multiple frameworks, they don't have to look for the same information twice.