It’s that time of year again. The time when your feed is flooded with sustainability professionals of all levels bemoaning the start of the annual CDP disclosure cycle.
We’ve all heard it: the argument that CDP is no longer valuable, that it’s a redundant exercise creating more busy work than impact, that regulation is taking its place…
But CDP isn’t dead, so maybe it’s time for a reframe.
For years, CDP was treated as an annual exercise in environmental housekeeping. Gather the data, answer the questions, submit before the deadline, wait for the score. Repeat. People learned how to maximise scores through language manipulation, using ‘for example’ and ‘as evidenced by’ like they were going out of style.
That approach is no longer viable, and the organisations still using it are falling behind.
CDP has evolved overtime, always at the forefront of disclosure, guiding organisations to push forward with their strategies. In 2026, CDP has matured into something more demanding and more consequential: a test of whether your sustainability strategy is genuinely fit for a climate- and nature-constrained world. The companies achieving strong scores aren’t doing so because they’ve mastered the questionnaire. They’re doing so because they’ve built the underlying strategy, data infrastructure and cross-functional alignment that CDP now expects to see evidence of. They aren’t chasing the A-list; they’re using the questionnaire to assess and evidence that their strategy is working. The distinction matters enormously.
What’s actually changed in 2026
The headline updates to the 2026 cycle are meaningful, but the more important shift is in what they signal collectively.
CDP continues to extend its scope well beyond climate. Ocean-related disclosures appear for the first time (unscored this cycle, but a clear statement of intent). Forests, biodiversity and ecosystems receive expanded coverage. Nature and plastics-related disclosures continue to develop, though also remain unscored. This reflects where investor demand and regulatory momentum are heading, and companies that treat these as future concerns are already behind the curve.
Physical risk and adaptation are increasingly critical. Identifying climate risks is now the minimum standard. What CDP is probing, and what investors increasingly want to understand, is how your organisation will actually respond when those risks materialise. Resilience is no longer a nice-to-have section of the disclosure; it’s central to the credibility of your strategy.
And across everything, alignment with ISSB (IFRS S1/S2), CSRD, TCFD and TNFD has deepened. CDP is increasingly positioned as preparation for mandatory reporting rather than an alternative to it. Smart corporates are using it as a bridge between where voluntary disclosure started and where regulatory requirements are heading.
CDP remains essential even as regulation expands
A reasonable question in 2026 is whether CDP still matters when CSRD obligations are live across much of Europe, and ISSB-aligned reporting is embedding itself globally. The answer is unambiguously yes, and not just because of the dilution of regulations that we’re seeing almost across the board.
CDP is structurally embedded in capital markets in a way that regulatory filings are not. Investors use it to compare companies across sectors and geographies using a consistent, independently scored methodology. That comparative function, the ability to see how your climate strategy stacks up against peers, not just whether you’ve met a disclosure threshold, is something regulation doesn’t replicate.
Companies that have built robust CDP responses over recent years find themselves significantly better positioned for compliance. The data, governance structures and strategic thinking required for strong CDP performance map directly onto regulatory requirements.
Increasingly, it’s also a supply chain requirement. Many companies disclose not because they’ve decided to, but because their customers or investors have asked them to. CDP’s supply chain programme continues to grow, and for businesses operating in global value chains, non-participation carries real commercial consequences.
Perhaps most significantly, CDP’s independent scoring remains a credibility signal that self-reported sustainability narratives cannot replicate. A strong score is harder to dismiss than a polished sustainability report. It tells the market something verifiable about the quality of your environmental management and how embedded your transition planning is in the strategy of your business.
Where companies need to focus this cycle
For organisations serious about their CDP performance and the underlying strategy it reflects, five areas deserve particular attention in 2026.
- Data quality over data volume: The era of demonstrating commitment through the sheer scale of disclosure is over. CDP, and the investors using it, are now scrutinising the quality and defensibility of emissions data, risk quantification and target tracking. Incomplete data disclosed with methodological transparency is more credible than comprehensive data of questionable provenance.
- Transition plans that stand up to scrutiny: A target without a credible pathway is increasingly a liability rather than an asset. CDP expects to see transition plans that are specific, financed and aligned to 1.5°C. Vague commitments are being scored accordingly.
- Resilience as a business strategy question, not a tick box exercise: Adaptation planning needs to move out of sustainability functions and into operational and financial planning. CDP’s increasing emphasis on physical risk asks how climate scenarios affect your assets, supply chains and revenue model, not just whether you’ve identified that they might.
- Nature and biodiversity readiness: The 2026 additions around oceans and ecosystems are unscored, but unscored doesn’t mean unimportant. Companies that begin building data systems and governance structures for nature-related disclosures now will be significantly better positioned when these become scored criteria, which the direction of travel makes inevitable.
- Cross-functional ownership: CDP cannot be owned by the sustainability team alone. The questions it asks span governance, finance, procurement, operations and supply chain. Organisations that have embedded sustainability into these functions answer CDP differently, and more credibly, than those treating it as a standalone reporting exercise.
A Strategic Approach for Success
The most forward-thinking organisations we work with have stopped asking “how do we answer CDP?” and started asking “what does our CDP response tell us about where our strategy needs to develop?”
Used well, CDP is a diagnostic: it surfaces gaps in risk management, transition planning and data infrastructure before those gaps become a problem in front of investors or regulators. It’s a rehearsal for mandatory reporting, a communication platform to signal credibility to capital markets, and a driver of internal alignment. A shrewd sustainability manager knows how to leverage the questionnaire as a mechanism for getting finance, risk, communications, and operations into the same conversation about the same material issues.
The organisations that will distinguish themselves through CDP in 2026 and beyond are the ones where the disclosure reflects a strategy that would survive scrutiny, whether or not CDP existed.
That’s a higher bar, and a better way to build a business for the long term.
If you’re approaching CDP this year and want to use it as a genuine strategic tool rather than a compliance exercise, we’d welcome the conversation. At Incendium, we work with organisations at every stage, from building data infrastructure to stress-testing transition plans to navigating the regulatory alignment questions that make CDP more complex and more valuable than ever.