Why the 2026 cycle matters more than usual
The CDP 2026 corporate questionnaire introduces the largest set of structural changes since the 2024 consolidation. New environmental themes enter the system, the scope of forests scoring is widened, water security becomes more granular, and the questionnaire itself adapts to each respondent based on size, sector and risk. Understanding these changes early is the difference between a smooth submission and a scramble in September.
The headline message: the questionnaire still rewards the same fundamentals (data quality, governance evidence, verification, quantified targets and initiatives) but the surface area of what counts is broader. Companies that prepared for the 2024 and 2025 cycles already have most of the foundation. The work in 2026 is to extend it.
Ocean disclosure enters the questionnaire
For the first time, ocean related questions are part of the corporate questionnaire. The implementation is deliberately gentle. Ocean is integrated into the existing structure rather than being a separate module. Full corporate respondents may opt in. Disclosure is unscored in 2026, allowing companies time to build the data collection infrastructure before scoring begins, expected from 2027.
The expectation is highest for companies in high impact sectors (shipping, fisheries, offshore energy, coastal infrastructure) or with material ocean dependencies, impacts, risks or opportunities. Even unscored, the disclosure starts to set benchmarks investors and regulators will look at next year.
Forests scoring expanded to cocoa, coffee and rubber
The forests module now scores three additional commodities: cocoa, coffee and rubber, alongside cattle products, palm oil, soy and timber. This is a substantial widening of scope, particularly for food and beverage companies, automotive (rubber), and consumer goods sourcing chocolate or coffee.
Companies already disclosing on traceability for the first four commodities will need to build the same data architecture (geolocation, certification, deforestation free verification, supplier engagement) for the new three. The architecture is identical; the work is in the supply chain mapping. For broader context on forests requirements, see the CDP Forests guide.
Water security: more granular and SBTN aligned
Water security remains a scored theme and gets refinement rather than expansion. The 2026 cycle asks for more detail on:
- Wastewater treatment levels at facility scale
- Discharge volumes by destination and treatment status
- Regulatory compliance with water permits
- Pollutant management practices
The notable opening: freshwater targets developed using Science Based Targets Network (SBTN) methodologies and validated by the Accountability Accelerator are now recognised in the scoring. Leading organisations can use SBTN aligned targets to demonstrate scientific rigour, paralleling how SBTi targets work for climate.
Plastics: broader, still unscored
Plastics disclosure expands with new and revised questions on:
- Reduction and reuse models
- Packaging formats by material and weight
- Design for recycling and composting
- End of life pathways
Plastics remains unscored in 2026 but the data collected is increasingly visible to investors and customers. Companies in packaging-intensive sectors (consumer goods, retail, food, beverages) should prepare full disclosures even though scoring has not yet been activated.
Adaptive questionnaire structure
The 2026 questionnaire actively routes each company only to the questions that apply to it, based on size, activities and risk. This is a structural change. Previously, every respondent saw the same questionnaire and skipped non applicable sections. Now the system pre filters.
The benefit: less noise in the response, less risk of accidentally answering a non material question incorrectly. The implication: the routing depends on accurate intake data in C1 and C2. Misclassifying activities or risk categories at the start can hide questions you should be answering, with downstream scoring consequences. Spend more time on C1 and C2 than in previous cycles.
SME A score for climate change
For the first time, SMEs that demonstrate leading actions can achieve an SME A score in Climate Change. In 2025 the highest SME score was B. This is a meaningful change for small and mid sized suppliers who use CDP scoring as a procurement signal: an A score now demonstrates leadership on equal footing with larger respondents.
SMEs also get new (unscored) modules for forests and water security. The pattern matches the corporate trajectory: introduce unscored disclosure first, build the data baseline, then bring it into scoring in subsequent years.
What it means for your 2026 plan
The practical priorities shift slightly from previous years:
- Audit your forests scope: if you source cocoa, coffee or rubber even indirectly, factor them into your traceability and supplier engagement plan now.
- Decide on ocean opt in: high impact sectors should opt in even though it is unscored, to set a credible baseline.
- Accelerate water granularity: wastewater and pollutants data is harder to retrofit; start collecting now.
- Validate questionnaire routing: spend more effort on the C1 and C2 intake to make sure the system shows you the right questions.
- For SMEs: the A score is now reachable. Treat the cycle as a real strategic disclosure, not a tick box.
For the broader scoring methodology that still underpins the 2026 cycle, see the CDP scoring methodology. To see how Dcycle structures the canonical data layer that feeds the climate, water, forests and (from 2026) ocean and plastics outputs from one source, request a demo.
Final thought
CDP 2026 is not a step change in difficulty. It is a step change in scope. The fundamentals that scored well in 2024 and 2025 still score well. The companies that will move bands in 2026 are those that extend the architecture they already built (governance, verification, quantified targets and initiatives) into the new themes and refined modules. The sooner that extension starts, the smoother the September deadline.