CDP Reporting: A Technical Deep Dive into the 2025 Integrated Questionnaire

The Carbon Disclosure Project (CDP) is the most widely used carbon disclosure system for companies to disclose their environmental impacts. 

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As pressures from investors, customers, and regulators intensify, understanding the intricacies of CDP reporting is now a fundamental skill for businesses worldwide. This article offers a guide to navigating the CDP corporate questionnaire, covering each module to empower you with the knowledge needed for effective CDP reporting.

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CDP operates on an annual cycle, releasing questionnaires typically in the Spring with submissions due later in the Summer. The corporate questionnaire is structured into several modules, each addressing a specific facet of environmental stewardship.

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Your organization's unique path through the questionnaire will be tailored based on your sector, the environmental issues pertinent to your business, and the stakeholders requesting your disclosure.

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The 2025 Integrated Questionnaire: A Shift in CDP reporting

A significant transformation in CDP reporting occurred in 2024 with the introduction of a single, integrated corporate questionnaire. This merged the previous separate questionnaires for climate change, forests, and water security.

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The 2024 structure also incorporates questions related to plastics and biodiversity, although these themes are not scored in the initial year of integration. This shift reflects a growing recognition that environmental issues are interconnected and that assessing them in isolation can leave organizations exposed to risks in other areas. The integrated approach encourages a more holistic and balanced assessment of environmental performance.

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Furthermore, CDP continues to strengthen its alignment with globally recognized frameworks and standards. The questionnaire maintains strong alignment with the Task Force on Climate-related Financial Disclosures (TCFD) recommendations, covering governance, strategy, risk management, and metrics and targets. This strategic alignment positions CDP reporting as a crucial data input mechanism for a wide array of mandatory and voluntary sustainability disclosures worldwide.

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Modules 1-6: Laying the foundation

These initial modules of the CDP reporting process establish the groundwork, providing context and overarching information about your organization's approach to environmental issues. Accurate and thorough responses are crucial here.

Module 1: Introduction

This module establishes your organization's reporting parameters.

• Core Information: You must define your reporting year, reporting boundary, and specify the currency used for all financial information disclosed (mandatory per question 1.2). You will also indicate if you are providing emissions data for past reporting years.
• Reporting Boundary: Detailed guidance is provided (question 1.5) on defining the reporting boundary, comparing it to financial statements, explaining deviations, and reporting exclusions. The boundary defined here dictates the scope for subsequent data collection.
• Organizational Context: Your annual revenue and staff headcount determine eligibility for either the full or the SME version of the questionnaire. You will also indicate the percentage of revenue derived per business activity according to the CDP Activity Classification System (ACS). Familiarity with CDP ACS is vital, as it influences question relevance later (e.g., forests, water) and requires a license from CDP Worldwide for use.
• Key Consideration: Clearly state whether your CDP reporting boundary aligns with your financial reporting boundary and justify any differences.

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Module 2: Identification, Assessment & Management of Dependencies, Impacts, Risks & Opportunities

This module focuses on your organization's understanding of its relationship with the environment.

• Assessment Process: You will detail your processes for identifying and assessing dependencies on natural resources, the environmental impacts of your activities, and the climate-related risks (physical and transition) and opportunities you face.
• Theme Relevance: Your indicated business activities using the CDP ACS, alongside the ACS Industry Impact Classification, requests from authorities (like supply chain requestors), or self-assessment, determine the relevance of themes like forests or water.
• Key Consideration: Methodological clarity is essential. Detail the specific tools and frameworks used. Demonstrate a clear understanding of the distinctions between dependencies, impacts, risks, and opportunities.

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Module 3: Disclosure of Risks & Opportunities

Building on Module 2, this section requires disclosing specific environmental risks and opportunities that are identified as having a potential substantive effect, considering both inherent risk exposure and residual risk.

• Required Details: For each identified risk (physical/transition) and opportunity related to climate change, provide specifics: 
  
  • Time horizon (short, medium, long term)
  • Likelihood
  • Potential magnitude of impact, and
  • Estimated financial implications (e.g., increased operating costs, reduced revenue, capital expenditures).
• Response Strategy: Detail the cost associated with managing the risk or realizing the opportunity, and outline your organization's response strategies.
• Key Consideration: Specificity and quantification are key. Avoid generic descriptions. Provide company-relevant examples and quantify financial impacts wherever possible, referencing your organization's definition of "substantive" from Module 2.

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Module 4: Governance

Module 4 examines the organizational structures, roles, responsibilities, and processes governing the approach to environmental issues.

• Oversight Structure: Disclose details on board-level oversight, including whether a board exists, its composition (e.g., executive vs. non-executive directors), meeting frequency, diversity policies, and specifically, whether board-level oversight exists for environmental issues such as climate change and biodiversity.
• Responsibility: If oversight exists, identify the specific positions or committees responsible (e.g., CEO, CFO, CSO, a dedicated ESG/Sustainability committee) and detail the management roles involved in addressing environmental concerns.
• Key Consideration: Clearly map responsibility from the board down through management. Provide concrete details on governance structures and any incentive metrics used.

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Module 5: Business Strategy

This module investigates how environmental considerations, particularly climate change, integrate into the organization's core business strategy and financial planning.

• Strategic Integration: Describe how climate-related issues are integrated into the overall business strategy. Detail the use of climate scenario analysis: frequency, specific scenarios employed (e.g., physical like RCP 2.6/8.5, transition scenarios), key assumptions, driving forces (policy, technology, physical impacts), timeframes, and how outcomes influence strategy, financial planning, and resilience.
• Mechanisms & Plans: Describe the use of internal carbon pricing mechanisms, if applicable. Detailed climate transition plans, including milestones, actions taken, and progress tracking. CDP recommends integrating transition plans concisely into mainstream filings, such as annual reports.
• Taxonomy Alignment: This module examines alignment with sustainable finance taxonomies, including the EU Taxonomy.
• Key Consideration: Demonstrate tangible links between climate analysis and strategic action. Provide detailed descriptions of scenario analysis methods and outcomes. Specify transition plan details.

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Module 6: Environmental Performance – Consolidation Approach

This section focuses specifically on the methodology used to define the organizational boundary for reporting quantitative environmental performance data.

• Methodology Choice: Provide a detailed rationale for the chosen consolidation approach (operational control, financial control, or equity share) used for reporting data like greenhouse gas (GHG) emissions. Base the choice on established standards like the GHG Protocol.
• Justification & Consistency: Justify the selection with reference to the company's operational structure and management practices. Consistency is vital; the approach must align with the Module 1 boundary definition and be applied uniformly across subsidiaries and all relevant performance data in subsequent modules, especially Module 7.

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Module 7: Environmental Performance – Climate Change

Module 7 is a core part of CDP reporting, focusing comprehensively on greenhouse gas emissions, energy, targets, and reduction efforts.

• Emissions Methodology and Exclusions: Describe the standard, protocol, or methodology (e.g., GHG Protocol) used for collecting activity data and calculating emissions. Detail any structural, boundary, or methodological changes in the reporting year affecting data comparability. For Scope 2, you must account for emissions using both a location-based method (grid average intensity) and a market-based method if you operate in markets with product or supplier-specific data (e.g., contractual instruments). To claim renewable electricity use for market-based figures, it must be sourced within the market boundary where it is consumed.
• Scope 1 Emissions: Report gross global Scope 1 emissions in metric tons of CO2e. CDP encourages breaking these down by GHG type (CO2, CH4, N2O, HFCs, PFCs, SF6, NF3) using consistent Global Warming Potential (GWP) factors, preferably the latest IPCC factors aligned with the GHG Protocol. Report emissions from biogenic carbon (e.g., biofuel combustion) separately from the Scopes.
• Scope 2 Emissions: Account for indirect GHG emissions from purchased/acquired electricity, steam, heat, or cooling, applying both location-based and market-based methods as required.
• Scope 3 Emissions: Identify and report on relevant Scope 3 categories (indirect value chain emissions). Determine relevance using GHG Protocol criteria and CDP's Technical Note on the relevance of Scope 3 categories by sector. This includes categories such as purchased goods and services, capital goods, and the use of sold products, among others. Note: Scope 3 Category 15 "Investments" for financial services is reported in Module 12. You may restate past Scope 3 data.
• Emissions Inventory Breakdown: Best practice involves providing breakdowns of Scope 1 and 2 emissions by factors such as subsidiary, country/area, business division, facility, and activity.
• Emissions Verification: Indicate the proportion of total reported gross global Scope 1, Scope 2, and potentially Scope 3 emissions subject to third-party verification/assurance. Provide details about the verification processes, relevant standards used (e.g., ISO 14064 3), and attach verification statements.
• Energy Data: Report all fuel (excluding feedstocks) consumed in MWh. Provide details on the consumption and generation of renewable electricity, steam, heat, or cooling, specifying sourcing methods and low-carbon technology types.
• Carbon Capture & Storage/Utilisation (CCS/U): If applicable, detail CCS/U activities, including injection and storage pathways, the amount of CO2 injected, and the consolidation basis used.
• Sector Specifics & Other Climate Info: Address sector-specific questions for high-impact sectors (e.g., agriculture, cement, electric utilities, metals & mining, oil & gas, transport OEMs) covering production data and related emissions intensity/efficiency metrics. Report on the sale of greenhouse gas products.
• Intensity Metrics and Product Emissions: Address sector-specific guidance for calculating revenue (e.g., capital goods). You may report product-level emissions and lifecycle emissions. Supply chain requests might require detailed product footprint information.
• Methane Emissions: For relevant operations (e.g., oil & gas, coal mining), describe methane reduction efforts, projects, collaborative initiatives, and Leak Detection and Repair (LDAR) programs. If LDAR is not conducted, explain why and future plans.
• Targets and Reduction Initiatives: Disclose emissions reduction targets (absolute, intensity, scope-specific). Detail emissions reduction initiatives and activities undertaken (beyond standard maintenance). If no active initiatives exist, explain why and outline future plans.
• Carbon Credits: Report on the retirement of project-based carbon credits, including details on project type, mitigation activity, number retired, purpose, vintage, and crediting program.

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Modules 8-13: Expanding the scope with forests, water and more

Beyond climate change, CDP reporting encompasses other critical environmental themes, reflecting an integrated approach.

Module 8: Environmental Performance – Forests

• Focus: Addresses your organization's dependency on forest risk commodities (e.g., palm oil, cattle products, soy, timber), impacts on forests, and efforts to address deforestation and conversion of other natural ecosystems.
• Reporting Requirements: Disclose volumes for relevant commodities and detail any exclusions. Report on forests-related policies, commitments (including no deforestation/conversion with cutoff dates), targets, traceability systems, and the use of third-party certification schemes.

Module 9: Environmental Performance – Water Security

• Focus: Centers on your organization's water management practices, interactions with water resources, and water-related risks and opportunities.
• Reporting Requirements: Provide aggregated company-wide volumetric data (megaliters/year) for water withdrawals, discharges, and consumption. Facility-level data and water intensity metrics for specific products may be required. Information on discharge quality might also be requested.

Module 10: Environmental Performance – Plastics

• Focus: (For non SME disclosers) Addresses the organization's approach to plastic polymers.
• Reporting Requirements: Report the total weight of plastic polymers sold and percentages of different content types (e.g., virgin, recycled). Your strategy towards a circular economy for plastics may also be covered.

Module 11: Environmental Performance – Biodiversity

• Focus: Examines the impacts on biodiversity and management efforts, particularly relevant for organizations with mining operations. Financial services companies may be asked to measure the impacts of portfolio biodiversity.
• Reporting Requirements: For mining, provide information on projects near biodiversity important areas, implementation of Biodiversity Action Plans (BAPs), and rehabilitation efforts.

Module 12: Environmental Performance – Financial Services

• Focus: A sector-specific module for financial institutions covering the environmental performance of financial products and services.
• Reporting Requirements: Includes questions on financed emissions (Scope 3 Category 15), alignment with sustainable finance taxonomies, portfolio impact metrics, verification of financed emissions, and progress against sector-specific environmental targets.

Module 13: Further Information & Sign-off

• Focus: Provides an opportunity for additional relevant information not covered elsewhere and includes the crucial sign-off.
• Reporting Requirements: Indicate which modules and data points (across various environmental themes, not just emissions) have been verified by a third party, specifying the standards used. This module contains the final sign-off of your CDP reporting response, confirming its accuracy and completeness.

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Transparency through comprehensive CDP Reporting

Effective CDP reporting is more than just filling out a questionnaire; it's a strategic exercise that reflects your organization's commitment to environmental transparency and action.

Success requires attention to several key areas:

Top tips for technical CDP reporting

• Robust Data Systems: Accurate and complete data is foundational, especially for energy consumption, Scope 1 and 2 emissions, and the increasingly scrutinized Scope 3 value chain emissions (Module 7).
• Methodological Rigour: Correctly understanding and applying methodologies for the consolidation approach (Module 6), Scope 2 dual reporting (Module 7), Scope 3 calculations (Module 7), and verification standards (Module 7 & 13) is crucial.
• Governance Integration: Clearly demonstrating board oversight and management accountability (Module 4) signals that environmental issues are treated strategically.
• Quantification: Moving beyond qualitative descriptions to quantify the financial impacts of risks and opportunities (Module 3) and the benefits of reduction initiatives (Module 7) enhances credibility.
• Strategic Alignment & Value Chain Engagement: Demonstrating how climate considerations and scenario analysis influence strategy (Module 5) and proactively engaging the value chain on environmental performance (Modules 5, 7, 8) are vital components.

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By understanding the technical details and requirements of each module, as outlined in this guide and the comprehensive resources provided by CDP, your organization can produce a thorough and insightful CDP reporting disclosure that meets stakeholder expectations and drives meaningful environmental progress.

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How Arbor closes the gap on CDP reporting

Arbor’s platform makes CDP reporting simple from start to sign-off. Our team runs a gap check, organizes data, and auto-calculates Scope 1, 2, and 3, the data you need to complete a CDP report.

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Why companies trust us

• Master Module 6 & 7: GHG Protocol-aligned engine delivers verified Scope 1, 2, 3 numbers and an audit trail.
• Expert-led support: Have an expert partner guide you through Modules 1-5 and 8-13.
• One transparent price: No surprise bills.

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