What CDP’s 2026 Changes Signal About the Future of Corporate Disclosure

Guest post by: Hana Beckwith, ESG Analyst at Novisto

Every CDP cycle brings adjustments, but the scale of what’s changing for 2026 sets this year apart. New topics, expanded commodity coverage and tighter alignment with frameworks like the ISSB’s IFRS S2, the CSRD and TNFD all point in the same direction: CDP is moving further from a standalone questionnaire and becoming a shared reference point for how environmental performance gets measured across the reporting landscape. For organizations still treating CDP as a once-a-year form to update, that shift changes the calculus considerably.

Why this cycle is different

The through-line across this year’s updates is a push toward disclosure that regulators, investors and standard-setters can actually use, rather than disclosure that simply demonstrates good intentions. That means more granular questions, closer scrutiny of underlying data, and scoring that rewards evidence over ambition. Organizations that carry forward last year’s answers with only minor edits are likely to see their scores stagnate or slip, not because their performance has worsened, but because the bar for what counts as strong disclosure has moved.

The changes that matter most

Four developments stand out. First, CDP has introduced questions on ocean-related impacts and dependencies for the first time. They are unscored this cycle, which gives companies in shipping, coastal infrastructure and offshore energy a low-risk window to build out data collection before the topic is inevitably scored in a future year.

Second, the Forests module now covers seven high-risk commodities instead of four, adding cocoa, coffee and rubber alongside cattle, palm oil, soy and timber. Because Forests is scored as a single aggregate, a weak answer on any one commodity can affect the overall module score, even where a company’s response on its traditional commodities is strong.

Third, the Climate, Water and Plastics questionnaires all ask for more specificity. Climate questions now probe how adaptation and resilience are embedded in governance, strategy and financial planning, not just whether a strategy exists. Water Security draws closer to the GRI 303 standard with more detailed questions on discharge and pollution management. Plastics, still unscored, has expanded to track packaging formats and reuse models more closely aligned with Ellen MacArthur Foundation definitions.

Fourth, and easy to overlook, the scoring methodology itself has shifted at the margins. Essential criteria, the minimum requirements that cap a company’s score if missed, have been adjusted in several sections. Missing an essential criterion can limit the maximum score achievable regardless of the quality of the rest of the response, which makes reviewing this year’s methodology at a question level a higher priority than it might have been in past cycles.

Preparing before the deadline arrives

With the scoring deadline landing in mid-September, organizations that wait for the disclosure window to open before assessing what’s changed are already behind. The more effective approach treats CDP preparation as a standing process rather than a seasonal one: reviewing the updated methodology against last year’s submission, mapping which new data points are needed for oceans and the expanded forest commodities, and assigning ownership across the business well ahead of time. Data on newly scored commodities, in particular, often sits with procurement or supply chain teams rather than sustainability functions, so early coordination matters.

Where scores tend to slip

Several recurring mistakes show up across disclosure cycles, and 2026’s changes make them more costly. Reusing prior-year responses without reviewing it against updated guidance is the most common. Overlooking an essential criterion, particularly one that’s shifted this year, is another. Misunderstanding how questions are scored, whether proportionally or on a best-response basis, can also leave points unclaimed even when the underlying data exists. And leaving fields blank rather than providing a “no” with context tends to cost more than a qualified, honest answer would.

A broader signal

As mandatory reporting regimes expand, some have questioned what a voluntary framework like CDP still offers. CDP remains one of the few mechanisms that lets companies benchmark environmental performance against peers on a comparable basis, and its continued alignment with ISSB, CSRD and TNFD means the underlying data effort increasingly serves multiple reporting obligations at once. The 2026 changes are less a one-off adjustment than a preview of where corporate environmental disclosure is headed: more granular, more interconnected, and less forgiving of disclosure that isn’t supported by reliable, well-governed data.