CDP 2025 Wrap Up
Insights and strategies for the year ahead
12 December 2025
Insights
Table of contents
- Key observations from 2025
- Why CDP still matters
- Tips for aligning CDP with other disclosures
- Looking ahead
- How Anthesis can help
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The 2025 CDP disclosure season has officially concluded, and participating organisations should now have received their scores, signalling a notable improvement in process efficiency compared to 2024.
Last year’s cycle was marked by repeated deadline extensions, portal disruptions, and the introduction of additional essential criteria at multiple scoring levels for climate change, along with ex post facto changes to scoring thresholds. In contrast, the 2025 cycle delivered a more streamlined and predictable experience.
Key observations from 2025
CDP demonstrated a clear commitment to enhancing the user experience in 2025. The portal was more stable and, rather than introducing new questions, CDP focused on refining guidance and clarifying scoring methodologies. This approach reflects a shift toward consolidation and usability – though it came with trade-offs.
Users were required to actively search for scoring methodology and guidance updates, and the separate PDF containing version control tables lacked clarity and user-friendliness. As expected, the portal experienced some strain in the final days before the scoring submission deadline, a recurring challenge when many organisations make last-minute edits to their responses. Additionally, CDP continues to keep responses behind a paywall, restricting public access. While CDP states that this enables them to have better control over who uses the data and the intended purpose for use, it raises important questions about transparency.
Despite the turbulence of 2024 and the quest for stability in 2025, some longstanding practices remain unchanged, even with the introduction of the new website and portal. For example, CDP continues to reserve the right to change the scoring thresholds that determine final scores, effectively redistributing companies within the various scoring bands (D to A).
The scoring methodology itself also remains highly complex, incorporating question-level scoring guidance to achieve comparability across companies from vastly different sectors and with varying degrees of maturity regarding assessing, measuring, and managing environmental issues. Furthermore, companies with expertise in a given environmental topic, such as plastics, can be frustrated by how the questions within the topic are framed, the terminology used, and the lack of nuance in the question guidelines.
Why CDP Still Matters
Nevertheless, CDP remains a critical tool both for companies seeking to demonstrate environmental accountability and for investors evaluating sustainability performance when shaping capital allocation. CDP continues to push companies toward a holistic view of environmental issues and to develop strategies and governance processes to manage them effectively.
The smoother 2025 CDP season reaffirmed CDP’s relevance, perhaps even more so now, given regulatory rollbacks and delays in some jurisdictions of mandatory environmental disclosures. For companies that are in scope of climate-related environmental regulations, such as California Senate Bill (SB) 253, and countries adopting the International Financial Reporting Standards (IFRS) Foundation’s sustainability standards, CDP can serve as a starting point from which companies can develop their regulatory-compliant disclosures.
With your finalised 2025 CDP response in hand, the next step is strategic: how can you leverage your CDP disclosure for other voluntary and mandatory reporting requirements? CDP provides alignment resources for several leading standards and frameworks, including: IFRS S2 climate-related disclosures, European Sustainability Reporting Standards (ESRS), and the Task Force on Climate-related Financial Disclosures (TCFD), among others.
While especially useful for consistency across different reporting mechanisms, CDP’s reliance on predetermined options (drop-down lists, etc.) means that, in some cases, the content drafted within CDP’s questionnaire may require more explanation to meet regulatory requirements, while in other cases, the level of detail disclosed within CDP may exceed what is necessary to satisfy regulations. Understanding specific regulatory requirements is vital when leveraging a CDP response in drafting regulatory disclosure.
Tips for aligning CDP with other disclosures
For companies managing hundreds of pages of disclosure content across priority frameworks and regulations, aligning reporting to an internal unified narrative presents a challenge.
When considering how to streamline the process of aligning your CDP response with broader changes in the reporting environment, consider the following best practices:
1. Partner early with internal legal & finance functions
Engage your legal and finance teams before drafting your CDP response. This ensures alignment on topics or data points that may need to be adjusted or omitted in the CDP response (or other disclosures) based on the evolving regulatory landscape.
2. Develop a cross-disclosure topic appendix
Disclosures vary by depth, breadth, and topics covered. For example, CDP is an expansive disclosure that allows companies to cover a wide variety of topics, often at a more granular level than other raters, rankers, and disclosure frameworks.
Evaluating company disclosures by the topics covered, or not covered, within each allows for later alignment across disclosures. For example, this can be a crosswalk document that identifies the location of key topics within each disclosure. By documenting the question, page, or section numbers where scenario analysis is named or referenced in each disclosure, you can efficiently update and align all content when a change occurs. This process can also support efficient updates, especially when combined with a change repository.
3. Maintain a change repository
Documenting changes to topics, data points, or regulatory language on an ongoing basis can support an efficient and accurate update process. This documentation can be especially helpful when leveraging external consultants who may not be present when changes to language are decided throughout the year. For example, when changes are made to management processes, the change repository can ensure that updates are flagged for integration across your annual sustainability report, TCFD report, CDP response, and other disclosures as applicable.
4. Reassess CDP scoring priorities
Changes in resource availability or developments in the ever-shifting reporting landscape can be a cause for re-evaluation of your priorities in completing a CDP response. Evaluating the needs of your CDP response’s priority audience(s) can inform your ultimate decision on whether to, for example, reduce certain elements of your response or submit for a score for the first (or last) time:
- Are your customers requesting CDP supply chain disclosures to complete their own Scope 3 inventory? Do customers consider CDP scores or responsiveness as part of their purchasing process?
- Is access to and/or the cost of capital affected by CDP scoring?
- Have investors engaged with your company via Capital Markets requests or direct inquiries regarding your score, or specific questions?
- Have elements of your CDP response and/or score been a significant touchpoint with internal stakeholders and champions?
The above list is not exhaustive and should be tailored to your unique business environment. However, these questions provide a framework for determining whether and where to dial back your CDP response to align with regulatory disclosures, which may be more limited or conservative in the amount of information disclosed.
Looking ahead
CDP has released key dates and relevant information about the 2026 disclosure cycle. Disclosers will have 13 weeks to complete their responses – from the time the response window opens in mid-June to when it closes for scored responses in mid-September. CDP has also announced an ambitious plan to release scores to disclosers and relevant stakeholders, and to make scores available on the website by the end of November, just one week after unscored corporate responses are due. Moreover, CDP will continue to deepen alignment with global standards, including the Task Force on Nature-Related Financial Disclosures. As such, disclosers will see the addition of Oceans and an enhanced Forest disclosure and scoring of additional forest-related commodities, including cocoa, coffee, and rubber.
Aside from these changes, CDP will continue to score three environmental issues: Climate Change, Water Security, and Forests. Disclosers can expect minimal changes to the essential criteria. CDP remains focused on improving the portal experience and aims to expand data uploading capabilities and add an AI assistant, although the timing of the AI assistant is yet to be confirmed.
While these changes signal CDP’s continued efforts to promote stability, given regulatory uncertainty and an increasingly challenging voluntary reporting environment, corporate disclosers will be focused on how to tell their sustainability stories in a way that satisfies multiple and diverse internal and external stakeholders in 2026. Aligning CDP disclosures with broader regulatory and internal messaging remains a priority as companies navigate increasingly complex reporting requirements.
To set yourself up for success in responding to CDP in 2026, organisations should consider strategies such as early engagement with legal teams, tracking changes to topics that are newly or no longer approved for disclosure throughout the year, and revisiting CDP scoring priorities to ensure alignment with stakeholder needs. Taking these steps throughout the year can help ensure consistency across multiple frameworks and lighten the CDP reporting lift.
How Anthesis can help
As an Accredited Solutions Provider for the CDP, Anthesis is proud to support over 80 CDP reporting responses each year across a variety of sectors and all questionnaire themes. We guide clients new to the reporting process, support existing reporters to maximise scores, and support CDP leaders’ efforts toward target setting, environmental stewardship, and innovation.
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