2026 CDP Response Cycle Series: What’s New and What’s Next?

The opening of the CDP’s 2026 response cycle is coming up on June 15, and the process is shaping up to look different than in past years.

CDP is a global non-profit with world’s most comprehensive environmental disclosure system, now entering its 25th cycle. Companies reporting to CDP represent over half of global market capitalization, which is good news for the climate: companies that choose to disclose observe a 7-10% reduction in direct emissions within two years reporting to the questionnaire.

In our previous post, we decoded the fundamentals of a typical CDP response cycle, exploring how it serves as a leading global system for ESG transparency and how its “Disclosure to Leadership” (D- to A) scoring framework drives corporate accountability. As we noted, CDP scores are used by investors and customers to assess risk and sustainability performance.

With that foundation, it is time to look at some changes coming with the next response cycle. CDP has been developing updates to the questionnaire, outlined in a report released earlier this year.

As we move into the 2026 disclosure period, which will be open from June to October, there are several updates that every sustainability lead needs to have on their radar. These updates are designed to keep CDP aligned with the evolving ESG reporting landscape, address data demands on topics like marine ecosystem’s economic impact, climate risk, and high-impact forest commodities, and provide standardized information for decision-making stakeholders.

Transitioning Climate Disclosure for New Global Standards

For the 2026 cycle, CDP is evolving its climate change questionnaire to maintain strict alignment with two sets of standards: the Climate Group’s RE100, which recently updated its technical criteria on using renewable energy, and a forthcoming standard from the GHG Protocol related to the land sector and land-based carbon removals.

• Who this change affects: All corporate disclosers, including small and medium enterprises (SMEs), which respond to a simplified version of the CDP questionnaire.
• The Impact: To acknowledge this transition, CDP will remove scoring for certain questions aligned with the older GHG Protocol Agriculture Guidance and streamline energy questions. The 2026 cycle serves as a critical transition period, preparing organizations for more rigorous quantitative reporting in future years.

Advancements in Water Security Disclosure

CDP is refining its water security framework to capture more granular data on wastewater management and integrate best practices for setting science-based targets. These updates increase alignment with global standards like the Global Reporting Initiative (GRI).

• Who this change affects: All organizations for whom water security is relevant, including those responding to sector-specific modules. For SMEs specifically, the questionnaire will include new, simplified water security metrics for the first time.
• The Impact: Disclosers will now provide specific data on wastewater treatment levels and discharge volumes, helping to benchmark performance against regulatory standards. Furthermore, the introduction of reporting options for Science-based Targets for Nature (SBTN) freshwater targets allow leading organizations to highlight their alignment with validated, science-based methodologies.

The Debut of Ocean Disclosure

For the first time, CDP’s 2026 questionnaire will include a dedicated Oceans module. This is a significant step in recognizing the role of marine ecosystems in global economic stability, and addresses a growing market demand for ocean data.

• Who this change affects: All organizations using the full corporate questionnaire can opt in to ocean disclosure. Organizations from high-impact sectors will be highly encouraged to report ocean-related information.
• The Impact: As with the climate disclosure updates discussed above, these questions will not be scored in the 2026 response cycle. This transitional period aims to assist organizations in identifying data gaps and establishing internal reporting processes.

Expanded Scope for Forests and Other Natural Ecosystems

CDP is broadening its coverage of forests and the types of commodities from forest and other land-based ecosystems in alignment with key standards and frameworks, such as the Accountability Framework (AFi) and SBTN. The 2026 questionnaire will include more commodities than in the past, to include those with high deforestation and conversion impacts.

• Who this change affects: All organizations identified as having a high impact on cocoa, coffee, and rubber will now see these commodities added to the disclosure requirements alongside the original four (cattle, palm oil, soy, and timber).
• The Impact: All seven commodities will contribute to a single, comprehensive forests score, requiring organizations to apply the same level of rigorous data collection, traceability, and target-setting across their entire forest-risk portfolio.

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Scaling Plastics Disclosure for a Circular Economy

The plastics module is evolving toward full alignment with the Ellen MacArthur Foundation’s Global Commitment on a circular economy through the introduction of new and modified questions.

• Who this change affects: All organizations responding through the CDP 2026 full corporate questionnaire will have the ability to opt in to plastics disclosure. However, it is not yet available for SME disclosers.
• The Impact: Similarly to the adjustments in climate and ocean disclosures, to support organizations as they establish data collection for these new metrics, plastics content will not be scored in the 2026 disclosure cycle.

Expanding Focus on Adaptation and Resilience

CDP is broadening its framework to capture critical data on how organizations are preparing for and responding to physical environmental risks. As nature loss and climate change present increasing material risks, this update aims to equip decision-makers with standardized information to manage uncertainty and unlock investment opportunities in adaptation.

• Who this change affects: The changes are relevant to all corporate disclosers. Updates across multiple modules provide the option to disclose how adaptation is integrated into risk assessments, governance, and financial planning.
• The Impact: To incentivize transparency in this area, CDP is implementing minor changes to scoring methodologies across modified questions.

Refinements and Clarifications Across the Full Questionnaire

CDP is also introducing several technical modifications to improve the clarity, comparability, and quality of disclosures. These revisions focus on refining reporting boundaries for specific commodities and aligning data collection with leading international sustainability standards. These changes streamline the reporting process by providing clearer guidance on what should be included or excluded from a disclosure.

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Natalia Menezes

Natalia Menezes is a Senior Sustainability Analyst at Governance & Accountability Institute. Her role includes supporting client needs through ESG data review, benchmarking research, and gap analyses. She is driven to help companies create positive and sustainable impacts for all their stakeholders.