Greenhouse Gas (GHG) Inventory • GHG Protocol • EU CBAM Declaration • Product Carbon Footprint (PCF) Report • ESG Sustainability Report / IFRS (S1, S2
(How Can Companies Effectively Respond to CDP Disclosure Challenges? — A Full Analysis of the CDP Questionnaire Modules and Scoring System Based on the Latest Official Guidance)
Full analysis of CDP questionnaire module and scoring system Download original text (Bu-Jhen Low Carbon COPY RIGHT)
CDP scoring system full analysis PPT. Download (Bu-Jhen Low Carbon COPY RIGHT)
1.1 CDP's Origin and Global Influence
CDP (formerly known as the Carbon Disclosure Project) was established in 2000 and is a global non-profit organization dedicated to building the world's most credible environmental disclosure platform. Its purpose is to assist companies, cities, and governments in disclosing their impacts on climate change, water resources, and forest ecology, and to promote transformation and sustainable actions by enhancing information transparency. CDP was initially initiated by a group of investors with the aim of improving the quality of investment decisions in the capital market by disclosing corporate carbon risk information. Today, CDP has evolved from focusing solely on carbon disclosure to a global disclosure system covering both water resources and forest issues, and has become one of the important platforms for integrating international standards such as the TCFD and ISSB. As of 2023, more than 23,000 companies, including businesses, cities, and regional governments from 135 countries and territories, have partnered with more than 740 financial institutions (with total assets exceeding $136 trillion) to build the world's largest environmental database for investors, governments, supply chains, and civil society. (Table 1. CDP Organizational Profile and Global Reach)
Table 1. CDP Organization Profile and Global Influence/Sources/Bu-Jhen Low Carbon Strategy
In addition, CDP is also a co-promoter of sustainability initiatives such as RE100, SBTi, and We Mean Business, and maintains a high degree of coordination with disclosure agencies such as the GRI, ISSB, UNGC, etc., so that companies can simultaneously connect with multiple ESG frameworks through CDP's disclosures.
Practical supplement: CDP has become one of the world's most indicative non-financial disclosure systems, with more than 840 (2023) companies in Taiwan participating in the disclosure, of which about 30 are supply chain requests (such as Apple, Walmart, etc.).
The following is a comparison table of CDP's carbon disclosure role and key terms (Table 2. CDP_Global Advocacy Roles and Terminology Comparison Table):
Table 2. CDP Global Initiative Roles and Terminology Comparison Table/Data Sources/Bu-Jhen Low Carbon Strategy
1.2 International Alignment and Integration Trends:
The CDP questionnaire structure and scoring content of the TCFD, ISSB, GRI (TCFD, ISSB, GRI) questionnaire have gradually been integrated into multiple mainstream international disclosure frameworks and serve as transitional tools and disclosure platforms for enterprises to address international sustainability norms.
1.2.1 Integration with the TCFD Framework
Since 2018, the CDP questionnaire has fully corresponded to the four major disclosure theme frameworks proposed by the TCFD (Task Force on Climate-related Financial Disclosures) and embedded them in the design of each module as an implementation tool for global enterprises to establish climate financial disclosure logic. These four major disclosure themes include:
1.Governance: Focuses on the level of oversight and involvement of the board of directors and senior management teams in climate issues, such as whether climate risks are incorporated into decision-making and whether ESG performance reward mechanisms are in place.
2.Strategy: Explores how climate change materially affects a company's operations and business strategies, including climate scenario analysis, changes in market demand, and capital expenditure transformation.
3.Risk Management: Explains how companies identify, assess, and respond to physical and transitional risks brought about by climate change, and incorporates them into their overall risk management system (e.g., ERM).
4. Metrics and Targets: Discloses key indicators (KPIs) used to track climate-related performance, such as GHG emissions, carbon intensity, energy use ratio, etc., and explains their corresponding medium- and long-term carbon reduction goals and tracking methods.
Each module in the CDP questionnaire is clearly marked with its corresponding correlation fields (Mapping) corresponding to the TCFD framework, helping companies become familiar with the international climate finance language and gradually build the ability to connect with the ISSB/IFRS S2 climate disclosure standards. This approach not only reduces the cost of switching between multiple standards but also lays the data foundation for future compliance integration. According to the ISSB requirements, companies will need to disclose the actual impact of climate risks on their financial statements. CDP provides implementation guidance, allowing enterprises to gradually implement the transformation logic of climate information embedded in financial reports from the TCFD framework, serving as an important transition bridge.
1.2.2 Integration with ISSB/IFRS S2 Standards
CDP (Carbon Disclosure Program) was officially announced as one of the IFRS S2 disclosure support platforms at the end of 2023, and from 2024, its questionnaire content fully corresponds to the International Sustainability Standards Board (ISSB) Climate-related Disclosure Standards (IFRS S2). By completing the CDP questionnaire, companies can simultaneously meet IFRS S2's requirements for climate risk and opportunity disclosure, covering the following key areas:
1.Financial Impact Assessment: Disclose the impact of climate change on financial metrics such as corporate costs, profits, and cash flow.
2.Capital Expenditure and Operating Expenditure (CAPEX/OPEX): Describe the capital and operational expenditure plans required to address climate risks.
3.Climate Scenario and Sensitivity Analysis: Enterprises should conduct climate scenario analysis to assess the risks and opportunities under different climate change scenarios, conduct risk assessments under different climate scenarios, and analyze the company's sensitivity to these scenarios.
A. Scenario setting: Set different temperature rise scenarios (such as 1.5°C, 2°C, 4°C) for analysis based on international standards (such as IPCC scenarios).
B. Impact Assessment: Analyze the impact of each scenario on business operations, supply chain, customer needs, etc.
C. Sensitivity Analysis: Assess the impact of changes in key variables (such as carbon prices and energy costs) on corporate financial indicators.
These analyses help companies develop flexible strategies, enhance their ability to respond to climate risks, and demonstrate their climate resilience to investors. The CDP platform serves as an implementation interface for the ISSB standards, helping companies gradually adopt sustainable financial disclosure capabilities and improve their ability to identify, assess, and manage climate-related risks.
1.2.3 Correspondence with GRI Standards
CDP (Carbon Disclosure Program) and GRI (Global Reporting Initiative) each play important roles in the field of sustainability reporting, with slightly different disclosure purposes:
GRI: Focuses on the impact of companies on external society and the environment (impact-based), emphasizing corporate responsibility and impact on stakeholders.
CDP: Aligns with standards such as TCFD/ISSB, emphasizing the impact of environmental risks on corporate finances (financial-based), focusing on the impact of climate change on corporate operations and financial performance.
Although their focuses differ, they overlap on topics such as emissions, water resources, energy, and forests. Companies can integrate responses through questionnaire comparison tables to avoid duplication of operations and improve reporting efficiency.
CDP effectively integrates relevant sustainability disclosure standards and requirements (see Figure 1. Simple diagram of CDP, TCFD, IFRS S2, and GRI integration relationships)
Figure 1. Summary of the relationship between CDP, TCFD, IFRS S2, and GRI integration/data source/summary of Bu-Jhen low-carbon strategy
This integration relationship demonstrates that companies can meet the requirements of multiple sustainability reporting standards such as TCFD, IFRS S2, and GRI through CDP disclosures. (See Table 3: Chinese-English comparison table of key terms)
Practical Supplement: Many Taiwanese companies are currently completing climate disclosure through CDP while meeting ISO 14064, GRI 302/305, and SBTi requirements, becoming a core tool for integrating multi-platform information.
Table 3: Comparison table of key terms in Chinese and English/data sources/summary of Bu-Jhen low-carbon strategy
1.3 Stakeholder Expectations and Business Value CDP is not only a disclosure tool but also serves as a reference for international ESG investment, supply chain management, rating agencies, government regulation, and internal corporate transformation, affecting the following four categories of stakeholders:
1.Investors and Financial Institutions:
Hundreds of investment institutions around the world use CDP data to conduct integrated ESG analysis to strengthen asset allocation and risk control.
Assessing corporate climate risk exposure, carbon reduction strategy feasibility, and transformation capabilities serves as the starting point for assessing the "Climate Finance Value Chain."
2.Supply Chain Leaders:
Over 280 CDP supply chain members (e.g., Apple, Walmart, Unilever, and Microsoft) have listed CDP disclosure as one of the criteria for supplier selection or renewal.
Requiring suppliers to submit carbon inventories, risk responses, and reduction commitments helps promote the availability and consistency of upstream emissions data.
3.Governments and Regulators:
The EU CSRD, the US SEC draft, and the Singapore ESG Code have gradually adopted the TCFD/CDP framework as the basis for statutory climate information disclosure.
The Taiwan Financial Supervisory Commission also requires listed companies to disclose in accordance with the TCFD or ISSB frameworks, making CDPs an important training platform for companies to plan ahead of time.
4.Companies Themselves:
CDPs can serve as internal risk identification and target tracking systems, integrating emissions inventory, strategy formulation, governance reporting, and external communication purposes.
Provide data and logical foundations for annual ESG reports, SBTi applications, RE100 commitments, and green financing applications.
Practical Recommendations:
First-time participants can first respond to the core questions of the Climate Change Module (such as governance, emissions, risks).
Those who have disclosed should closely track the annual questionnaire update and scoring weight adjustment (e.g., Scope 3, verification, scenario analysis, etc.), and plan the filling and data consolidation plan in advance.
Key Terminology Comparison:
1.ESG Integration,
2. Supply Chain Disclosure,
3.Climate Transition Risk,
4.Regulatory Preparedness,
5.Internal Climate Governance
CDP affects four categories of enterprises: stakeholders/data sources/Bu-Jhen low-carbon strategy compilation
CDP Climate Disclosure Discussion on International Sustainable Procurement/Data Sources/Summary of Bu-Jhen Low-Carbon Strategy
1.4 Global Architecture Integration Trends: CDP and IFRS S2 Integration
CDP (Carbon Disclosure Project) has adopted the TCFD (Climate-related Financial Disclosures) framework design questionnaire since 2018, and has been officially integrated with the IFRS S2 "Climate-related Disclosure Standards" issued by the ISSB (International Sustainability Standards Board) since 2024. This integration covers disclosure topics, formatting logic, data fields, and frequency of disclosure, making the CDP questionnaire one of the leading platforms for IFRS S2 practical applications.
According to the CDP 2025 Corporate Disclosure Questionnaire published by CDP in 2025, Module 7: Integration of Climate-related Issues into Business Strategy is regarded as the most critical module corresponding to IFRS S2, covering:
Identifying Climate Risks and Opportunities (corresponding to IFRS S2 §21–23)
Financial Impact Disclosure (corresponding to IFRS S2 §24–28)
Climate Transition Plans and Targets (corresponding to IFRS S2 §29–33)
The following table summarizes the correspondence between CDP Module 7 and IFRS S2
In addition, CDP also pointed out in "Scoring Methodology – Key Changes for 2025" that Module 7 will be one of the highest-rated modules in 2025. The questionnaire scoring logic has been incorporated into IFRS S2's "financial impact", "governance process", and "transformation action effectiveness". From a practical application perspective, if companies can clearly disclose their risk mechanisms, financial impact assessments, climate action plans, and long-term goals in Module 7, it basically corresponds to the full disclosure requirements of IFRS S2.
1️ .Identification of Climate Risks and Opportunities (§21–23)/IFRS S2 Standard Articles 21 to 23
The main purpose
is to explain how companies systematically identify potential risks and opportunities brought about by climate change, and explain the possible impact of these projects on business operations, supply chains, and financial conditions.
Key content:
Risks are divided into:
physical risks (such as extreme weather, floods, droughts, etc.)
Transition risks (policies and regulations, technological changes, market and reputation risks)
Opportunities include:
green market development, technological innovation, energy efficiency improvement
Explain the significance of each risk and opportunity Timeframe (short, medium, long-term).
The operating area or value chain location involved
2️ .Financial Impact and Economic Materiality Analysis (§24–28)
Main Purpose:
To disclose the possible impact of climate risks and opportunities on corporate financial statement items, including revenue, costs, capital expenditures, asset losses, insurance expenses, etc.
Key content: Analyze how climate-related variables (such as carbon prices, energy costs, and temperature rises) have a specific impact: The cost structure of operating income (such as carbon fees, rising raw material prices) impairment risks of fixed assets/intangible assets should be disclosed whether financial impacts have occurred, and the potential impact of quantitative predictions in the future should be explained if scenario analysis is used
3️ .Climate Transition Strategy and Metrics (§29–33)
Main Purpose: To describe the strategies, goals, plans, and metrics adopted by companies in response to the above risks and opportunities.
Key content: Whether a climate transition plan has been formulated , including decarbonization paths, R&D directions, procurement and investment policy adjustments, whether measurable targets (such as net-zero targets, SBTi certification) have been set, and whether there are internal oversight and performance tracking mechanisms to explain which metrics and KPIs are currently used to track the implementation of strategies
Additional Note: CDP Module 7 is a specific implementation questionnaire for the above three disclosure topics, and if the company fully responds to the questions listed in Module 7, it will cover all the disclosure requirements of IFRS S2 §21–33. Source: CDP, "CDP 2025 Corporate Disclosure Questionnaire", April 2025 CDP, "Scoring Methodology – Key Changes for 2025", April 2025 IFRS Foundation, "IFRS S2 Climate-related Disclosures", 2023
Table 4-1. Summary of theme modules/data sources/low-carbon strategies for medium and large enterprises
2.1 Module Structure Overview
CDP questionnaires are divided into modules based on different disclosure topics (climate, water, forests) and invited identities (subject to investor requirements, supply chain requirements, or voluntary disclosures), enabling companies to systematically respond to environmental impacts related to their business. Each module is subdivided into core sub-topics such as Governance, Risks and Opportunities, Targets & Metrics, and GHG Emissions, further demonstrating corporate management capabilities and information transparency.
The CDP questionnaire modules are categorized as follows:
Modules 1–13: Standard Corporate Modules are suitable for general listed companies, medium and large enterprises, and high-emission industries. It covers a complete structure such as climate governance, emission information, target management, energy use, water resources, forests, and supply chain participation. (Refer to Table 4: Medium and Large Enterprise Theme Module)
Modules 14–21: SME Modules are designed for SMEs with limited resources, simplified and focused on basic emissions, targets, risks, and energy use. (Please refer to Table 5: SME Theme Module) It can be used as a starting point for small and medium-sized enterprises to participate in ESG disclosure and connect with the transition stage of future upgrades to standard modules.
Sector-Specific Add-Ons Specific Add-Ons Specific industries such as FI Module, Power, Construction, Cement, Transportation, etc. may need to respond to additional modules. (Please refer to Table 6: Industry-specific Extended Theme Module) Some modules have a "dual questionnaire path" that dynamically adjusts the depth of questions based on the size of the enterprise and the characteristics of emissions.
CDP provides a "module guidance tool" to help enterprises confirm the list of modules that should be replied to before filling in, and it is recommended that enterprises complete module confirmation in the ORS system before officially filling in.
Practical supplement:
Most companies in Taiwan mainly reply to Modules 1-13, and if they are OEM, ODM, or component suppliers, they commonly participate in SME modules.
In the financial industry, the parent company mostly responds to the FI module uniformly, and if the subsidiary or investment target is not included in the boundary, it can be filled in without repeated reporting.
Key Terms:
Modules
SME: Small and Medium Enterprise
Sector-specific:
Add-on Questions:
Extended Question Modules:
ORS: Online Response System
Table 4: Summary of medium and large enterprise theme modules/data sources/Bu-Jhen low-carbon strategies
Table 5. SME Theme Module/Data Source/Bu-Jhen Low-Carbon Strategy Summary
Table 6: Summary of industry-specific extended theme modules/data sources/Bu-Jhen low-carbon strategies
Summary of the number of modules
1.General enterprise modules: 13 (Modules 1–13)
2. SME modules: 8 (Modules 14–21)
3.Industry extensions: Depending on the industry to which the company belongs, 1–3 modules may be added (depending on the industry)
Therefore, companies in specific industries may need to fill in more than 20 modules.
2.2 Functions of Each Module
The modules in the CDP questionnaire can be regarded as the skeleton of the disclosure logic, each consisting of a series of specific sub-topics, reflecting the company's complete disclosure capabilities in governance, strategy, management, and performance tracking. The following is an introduction to the core functional modules (please refer to Table 7. Questionnaire module function summary table):
1. Governance
discloses whether the board of directors and management are involved in climate decision-making.
Whether there is a sustainability team, ESG committee, or senior management responsible for climate issues.
Whether climate performance is included in the reward system.
ü Fill in suggestions: Provide meeting minutes, responsibility allocation, and KPI reward examples.
2.Risks & Opportunities
Identify short-, medium-, and long-term climate risks (physical/transitional) and their financial impacts.
Evaluate positive opportunities such as new markets, new technologies, or customer needs under climate change.
Whether there are regular updates on risk inventory mechanisms and quantified financial exposure.
ü Fill in Suggestions: List risk types (e.g., carbon fees, extreme weather), impact narratives, and activated response strategies.
3. Targets & Metrics:
Whether there are clear carbon reduction targets (short/medium/long-term) and whether they correspond to commitments such as SBTi and RE100.
Whether there is an annual progress tracking and target update mechanism.
Whether intensity indicators (such as carbon intensity tCO₂e/million revenue) and absolute values are tracked.
ü Fill in Suggestions: Provide target setting basis, base year, quantitative logic, and verification proof.
4.Emissions
Disclose corporate emissions (Scope 1 direct emissions, Scope 2 indirect electricity, Scope 3 supply chain, and external activities).
Whether to use GHG Protocol, ISO 14064, or other standard methods.
Whether to disclose activity data, emission factors (EF), and boundary settings.
Fill in suggestions: It is recommended to reply to Scope 1+2 first and gradually establish a Scope 3 category inventory.
Table 7: Summary of questionnaire module functions/data sources/Bu-Jhen low-carbon strategy
Practice Supplement:
When scoring, CDP pays special attention to whether the data source, calculation methodology is transparent, and whether it is connected to internal governance decision-making mechanisms.
Logical correlation between modules: If governance is absent, risk management and goal setting will be difficult to reach a high level.
There is a logical association between risks, and if the governance module is incomplete, it is scored against the target module. Scoring focuses specifically on data sources, transparency, and governance relevance.
It is proposed to start with Scope 1+2 and gradually expand to Scope 3.
Key Term Comparison:
Climate Governance
Physical Risk / Transition Risk
Emissions Boundary
KPI: Key Performance Indicator
Intensity Metrics
2.3 CDP ORS Platform Introduction
Enterprises must log in to CDP's ORS (Online Response System) system to fill out and submit questionnaires. The platform is a cloud-based operation interface with multi-user collaboration functions and supports data integration, permission control and traceability tracking (see Table 8. ORS online system operation step sequence).
The core functions are as follows:
1.Questionnaire assignment and response management (Assignments)
can be filled out by the main window by assigning different departments or personnel according to modules or questions.
Each answer record will be marked with the modifier and update time, making it easy to track and review. Multi-department collaboration and permission setting The system can set role permissions (such as Viewer, Editor, Approver) to ensure consistent responsibilities.
2.Provide internal review process settings
support the distinction between the draft stage and the final submission stage.
3.Save progress and version management
All replies are automatically saved, allowing you to go back to the previous content.
Administrators can view historical versions and restore previous states to ensure data is not lost.
4. Third-party consultant collaborative review (Review Mode)
can authorize the consulting company to log in with a shared account to assist in draft writing and review.
Consultants use Review Mode to provide suggestions and annotations to avoid mistakenly changing formal answers.
ü Operational Suggestions: Enterprises can establish an "ORS Questionnaire Filling Working Group" at the initial stage of filling out the application and arrange platform operation training to accelerate collaboration efficiency.
Supplementary Terminology Comparison:
ORS: Online Response System
Assignments: Task Assignment
Review Mode: Review Mode
Version History: Version History
Role-Based Access Control (RBAC): Role permission control
2.3.1 SME Questionnaire Organization and Reporting Judgment Logic
To help small and medium-sized enterprises (SMEs) effectively participate in CDP disclosure, CDP has launched a dedicated SME questionnaire module covering Modules 14 to 21 starting in 2024, which is simplified and more closely related to the actual operations of SMEs.
SME Questionnaire Eligibility Criteria Companies can determine whether the SME Questionnaire is eligible based on the following self-determination criteria:
Annual revenue: Less than $2.5 billion (or EUR equivalent)
Number of employees: Less than 500
Sources of disclosure requirements: Only from CDP Supply Chain Members, Banks Program Members, Private Market Members Markets Member) or RE100 Program
If a company receives a disclosure request from a Capital Market Signatory at the same time, it will need to complete a completed corporate questionnaire. SME Questionnaire Module Structure
The SME questionnaire includes the following modules:
Module 14: Organizational Basic Data and Boundaries
Module 15: Risk and Opportunity Identification Process
Module 16: Material Risks and Opportunity Disclosure
Module 17: Governance and Senior Responsibility
Module 18: Strategy, Transformation Plan and Value Chain Engagement
Module 19: Greenhouse Gas Inventory Boundaries and Emission Data (S1–S3)
Module 20: Target Setting and Reduction Actions
Module 21: Signing and Confirmation
These modules are designed to be concise and have no department-specific issues, making them suitable for SMEs with limited resources. Questionnaire opening logic and authority type
In the SME questionnaire, each question is marked with "Tags", where "Authority Type" indicates which disclosure requesters will see the question:
Supply Chain: Visible only to businesses requested by supply chain members
All requesters: Visible to all disclosure requesters
This design ensures that businesses only need to respond to questions related to their disclosure requests, reducing unnecessary reporting burdens.
ORS online system operation step sequence/data source/Bu-Jhen low-carbon strategy
Small and medium-sized enterprises (SMEs) questionnaire logic and module structure summary/data source/Bu-Jhen low-carbon strategy
2.4 How to Participate in CDP and Membership Overview
2.4.1 Participation Channels & RegistrationRegarding the types of disclosure targets for participating in CDP's carbon disclosure program (please refer to Form 9. CDP Participation Methods and Membership System Summary Table).
Requested Entities: CDP sends out formal invitations every year based on the list of Investor Signatories and Supply Chain Members, and invited companies will receive a questionnaire invitation letter and login code to enter the ORS system to complete the application.
Voluntary Participants: Uninvited companies can register an account on the CDP official website, choose their own disclosure module, and fill in the report on the platform. It is especially suitable for companies that have not yet been required by investors but have ESG demonstration needs or target ratings.
CDP Members: Companies can apply to become CDP Standard, Silver, or Gold level members based on their disclosure needs and support levels, and enjoy exclusive resources, technical documentation, and fast support channels.
2.4.2 Disclosure Types
Voluntary Disclosure: Voluntary disclosure, usually by leading ESG companies or sustainable active strategists.
Self-Selected Disclosure: Companies choose to disclose the scope of the module and the content of the questionnaire (applicable to those who are not invited but are willing to disclose some data).
Request-Based Disclosure: Companies often have clear scoring and data usage pressures due to disclosure requests from investors or brand customers.
2.4.3 Roles and Responsibilities
General Disclosure of Disclosers: After being invited, log in to the ORS platform to respond to the questionnaire and complete the basic items.
Supply Chain Disclosers: Specifically for CDP SC module responses, additional performance data is often required to be submitted to the client for review.
CDP Members: Gold, Silver, and Standard tiers with dedicated advisory support, disclosure tools, data visualization resources, and strategic advice documents
2.4.4Membership and Fees
Membership levels vary from approximately £1,000–10,000 per year depending on the size of the company, its needs, and the type of disclosure.
From 2025, self-disclosing companies will also be required to pay an application fee (from about £850) if they are not invited. (See Table 10. CDP Fee Summary Table)
Members of certain tiers will have priority access to rating summaries, review recommendations, rapid implementation guidance, and dedicated training.
ü Practical Advice: It is recommended that companies proactively contact CDPs, consulting firms, or supply chain leading companies to confirm their disclosure types before filling out the report to avoid incorrect questionnaire qualifications or delays.
Supplementary Terminology Comparison:
Voluntary Disclosure:
Voluntary Disclosure Request-Based Disclosure
Self-Selected Module
Membership Tiers: Membership Tier (Gold/Silver/Standard)
Supply Chain Member: Supply chain leading companies (such as Apple, Walmart, etc.)
Table 9. CDP Participation Methods and Membership System Summary Table/Data Source/Summary of Bu-Jhen Low-Carbon Strategy
Table 10. CDP fee summary table/data source/summary of Bu-Jhen low-carbon strategy
3.1 Modules 1–6: Governance, Risk, Targets, Performance
Module 1: Governance
This module aims to understand the governance structure and decision-making mechanism of enterprises on climate issues.
Cover:
Does the board oversee climate-related risks and opportunities? (Board oversight)
Is senior management responsible for climate-related strategies and goals? (Management responsibility)
Are climate issues included in corporate risk management and reward mechanisms? (Incentives & oversight)
Key Notes: If the company can demonstrate that the board regularly discusses climate issues and has a reward system linked to ESG performance, the score can be upgraded to the Management or Leadership level.
Module 2: Risk and Opportunity Identification
This module focuses on how companies can identify, assess, and manage the physical and transitional risks posed by climate change.
Are short-, medium-, and long-term risks identified and classified? Do you take into account extreme weather events and regulatory changes?
Are opportunities coming from product transformation, low-carbon markets, etc.?
Common mistake: Describe only the "impact" of climate on operations rather than specifically identify risk events.
Module 3: Risk Management
Does the Risk Management Process incorporate climate risk into ERM (Integrated Risk Management)?
Does the risk assessment include risk severity, probability of occurrence, and financial impact?
Do you have an internal reporting and response process?
Practical Case: Buzhen Consulting assisted clients in implementing the "Three-Stage Risk Matrix" to clearly quantify the impact of risks on financial statements.
Module 4: Climate-related Business Strategy
This module examines whether companies incorporate climate risks into their operational strategies and financial planning:
Do they conduct climate scenario analysis (e.g., 1.5°C and 2°C pathways)?
Is climate change included in strategic planning (e.g., product development, capital expenditures)?
Do you disclose business resilience and transformation readiness?
Recommended: Using SBTi or IEA scenarios, disclosing financial soundness assumptions can improve the score.
Module 5: Target
Does Target Setting and Strategic Goals have clear carbon emission targets? (Covering Areas 1, 2, 3)
Is the Science Based Target (SBTi) adopted?
Do you disclose progress and performance tracking methods?
Reminder: Simply disclosing the percentage of greenhouse gas reductions (e.g., "2% per year") is insufficient, and it needs to correspond to the base year, category, and tracking mechanism.
Module 6: Emissions Metrics
Does Emissions Metrics disclose absolute emissions and intensity indicators?
Is the GHG Protocol or ISO 14064 standard adopted?
Is there a distinction between emissions performance by operating unit, product line or country?
Advanced Disclosure Recommendations: Simultaneously disclose indicators such as carbon intensity (tCO₂e/million revenue) and the proportion of renewable energy use.
3.2 Module 7: Business Strategy and Climate Integration
This module is a new key module that mainly evaluates whether companies have substantially integrated climate-related issues into their core operations and long-term business strategies, not just risk disclosure or ESG compliance, but also examines the degree of integration at the "corporate strategy level".
Question design logic:
Does climate change issue be included in the core corporate strategy? (Strategy integration)
Is the business model or value proposition reevaluated due to climate trends?
Are there any adjustments to the operating model, investment direction or product strategy?
Has climate transition been made one of the sources of competitive advantage for businesses?
Key points: This module score will be based on whether the company has explained the evidence of adjusting its operating model or value chain in response to the climate transition.
Data types that can be included:
Corporate transformation plans (e.g., decarbonization, technology adoption, low-carbon supply chain transition),
management team annual strategy meeting minutes ,
summary of investor presentations, climate strategy statements and action plans ,
integration descriptions between ESG and financial statements (e.g., CAPEX allocation adjustments),
Practical recommendations:
In his practical experience, he assisted manufacturing clients in making low-carbon product development the main axis of their five-year technology layout and incorporating product carbon footprint into their sales strategies, which effectively obtained high scores from Module 7.
It is recommended that companies specify "how climate strategies drive resource allocation and decision-making", emphasizing the relationship between climate issues and revenue, brand, and R&D direction.
3.3 Modules 8–13: Emissions, Energy, Water, Forests, Supply Chain This module is an environmental disclosure focus, covering the dependence and impact of corporate operations on environmental resources, and closely corresponds to international computing and commitment frameworks such as the GHG Protocol, RE100, SBTi, and WRI.
Module 8: GHG Emissions
discloses corporate Scope 1, Scope 2, and Scope 3 emissions data.
Is the inventory conducted according to the GHG Protocol or ISO 14064:2018? Are direct and indirect emissions disclosed separately?
Is the source of activity data and emission factor clearly stated?
Is verification conducted?
Tip: The calculation method and data source of each emission source must be indicated, and the logic of organizational and operational boundary selection must be disclosed.
Module 9: Energy
Disclosure of the total amount of energy, type, source, and renewable energy consumption of the enterprise.
Is primary energy and secondary energy calculated? (Primary vs. Secondary Energy)
Does it include information on voluntary green power (such as self-built solar energy) and power purchase agreements (PPAs)?
Does it meet the definition of the RE100 framework?
Advanced recommendations: Energy intensity and improvement measures can be disclosed simultaneously.
Module 10: Water Security
discloses a company's water withdrawal, water consumption, recycling, and risk management strategies.
Is a Water Footprint Assessment Conducted?
Does it operate in a high-water pressure area and assess risks?
Are reduction targets set and governance measures implemented?
Common omissions: Failure to distinguish between operational and process water, or lack of geographic regional data support.
Module 11: Forests
is applicable to companies involved in the development of forest resources, palm oil, soybeans, timber, beef, and other supply chains.
Do you disclose supply source country and supplier information?
Is it promoting a zero deforestation policy?
Do you have relevant international certifications (such as FSC, RSPO)?
Tips: Those who are not directly involved in forest raw materials can indicate not applicable (N/A) to facilitate logical judgment of scores.
Module 12: Supply Chain Engagement
Does Supply Chain Engagement conduct carbon inventories, energy resource inventories, or disclosure requirements for suppliers?
Is there a supplier scoring mechanism?
Is climate performance incorporated into procurement decisions?
Consulting experience: Bu-Jhen Consulting has assisted clients in establishing the "Supplier Carbon Reduction Questionnaire System" as a basis for responding to this module and improving scores.
Module 13: Biodiversity and Waste
Does Biodiversity and Waste assess the impact of corporate activities on biodiversity?
Does the total amount of waste, its types and disposal methods be disclosed?
Is there a Zero Waste or Circular Economy policy?
Practical Advice: Even if it is not a high-emission industry, basic waste management measures and recycling achievements should be disclosed to demonstrate awareness of environmental responsibility.
3.4 Modules 14–21: SME Modules
This module is a questionnaire framework designed for small and medium-sized enterprises (SMEs) to help companies with limited resources disclose core climate information in a streamlined version while maintaining transparency and accountability standards.
The content of the module mainly covers:
Module 14: Company Information
Whether there is a substantial carbon reduction commitment and responsibility department such as the company's business scale, industry classification, geographical location , etc.
Module 15: Greenhouse Gas Emissions (GHG Emissions)
Focus on Scope 1 & 2 (Scope 1 & 2) Emissions Disclosure
Emphasize data sources (direct measurement vs bill estimate)
method description Optional Scope 3 basic information
Module 16: Risks and Opportunities
Whether the challenges and new business opportunities that climate change may bring to operations have been affected by climate events (e.g., flooding, extreme temperatures)
Module 17: Emissions Reduction Targets & Actions
Whether carbon reduction targets have been set Whether to adopt specific practices such as energy conservation, procurement of green electricity, and facility replacement
Module 18: Energy Use & Renewables
Whether the classification of energy sources (electricity, gas, diesel, etc.) is the use of renewable energy, such as self-built solar energy, purchase of green power certificates, etc
Module 19: Products & Supply Chain
Disclosure Whether the carbon impact of major products or services (qualitatively described or simplified) is focused on supply chain carbon emissions or disclosed in collaboration with suppliers
Module 20: Governance
Whether there are sustainability-related roles, internal leaders, or teams ESG Whether to include decision-making discussions or periodic reporting processes
Module 21: Verification
Whether there is internal or third-party verification of GHG data Whether data quality control is in place
Supplementary practical experience: ·
This module is especially useful for SME customers who are participating in CDP for the first time. ·
It is recommended to briefly organize current environmental protection measures, energy bill records, procurement, or facility upgrade plans to effectively correspond to the questionnaire structure.
3.5 Determine the three thematic modules based on their business activities
According to the latest guidelines of the CDP Carbon Disclosure Plan for 2025, companies need to decide whether to disclose the following thematic modules based on the environmental impact of their business activities when filling out the questionnaire (Table 11: Overview of the applicable objects of each major module order):
1. Climate Change
Disclosure Obligations: All companies are required to fill in the report, regardless of whether they are invited or not.
The content covers: governance, risks and opportunities, emissions data, goals and performance, etc.
Scoring Impact: The results of this module will affect your CDP score.
2. Water Security
Disclosure Obligations: Only if the company meets one of the following conditions:
a.Disclosure required by investees or supply chain members.
b.According to the CDP Activity Classification System (CDP-ACS), a business's business activities have a significant impact on water resources.
The content covers:
water resource management, risks and opportunities, goals and performance, etc.
Scoring Impact:
The results of the report will affect your CDP score.
3. Forests
A. Disclosure obligations: Only if the enterprise meets one of the following conditions:
a.Disclosure requested by investors or supply chain members.
b. According to the CDP Activity Classification System (CDP-ACS), the business activities of enterprises have a significant impact on forest resources.
B. The content covers: forest resource management, risks and opportunities, goals and performance, etc.
C. Scoring Impact: The results of the report will affect your CDP score.
Supplementary Explanation
CDP Activity Classification System (CDP-ACS): This system is used to assess the impact of a company's business activities on environmental topics (e.g., water resources, forests) to determine its disclosure obligations.
Self-Selected Disclosure: Even if companies are not required to disclose water security or forest modules, they can still choose to voluntarily disclose them to demonstrate their commitment to sustainable development.
Table 11: Overview of applicable objects for each major module order/data source/Climate group research of the Low Carbon Strategy
3.6 Module 13: Financial Impact and Climate Transition
Module 13 is the core module of the CDP questionnaire on the financial impact of climate change on companies and climate transition plans, covering the following three major topics:
1️ Climate Risk and Opportunity Identification (§21–23)
Companies need to explain how to identify potential risks (e.g., extreme weather, carbon emission policy changes) and opportunities (e.g., green markets, technological innovation) and explain the impact of these projects on business operations, supply chains, Possible impact of financial conditions.
2️ .Financial impact and economic materiality analysis (§24–28)
Disclose the possible impact of climate risks and opportunities on corporate financial statement items, including revenue, costs, capital expenditures, asset losses, insurance costs, etc. Companies should analyze how climate-related variables specifically affect operating income, cost structure, asset impairment risks, etc., disclose whether financial impacts have occurred, and quantify and estimate possible future impacts.
3️ .Climate Transition Strategies and Metrics (§29–33)
describes the strategies, goals, plans, and metrics adopted by companies to address the above risks and opportunities. This includes whether a climate transition plan is in place, measurable targets are set, internal oversight and performance tracking mechanisms are in place, and what metrics and KPIs are currently being used to track the implementation of the strategy.
CDP_Module13_ Financial Impact and Climate Transition Mapping Table/Data Source/Bu-Jhen Low Carbon Strategy
3.7 SME Module Analysis (Modules 14–21)
To assist small and medium-sized enterprises (SMEs) in effectively participating in environmental information disclosure, CDP has launched a dedicated SME questionnaire module covering Modules 14 to 21 starting in 2024. These modules are designed to be simple and department-free, making them suitable for SMEs with limited resources.
SME Questionnaire Applicable Conditions
Companies can determine whether the SME Questionnaire is applicable based on the following self-determination criteria:
1.Annual revenue: Less than $2.5 billion (or EUR equivalent)
2.with less than 500 employees
3.Source of disclosure requirements: Only from CDP Supply Chain Members, Banks Program Members, Private Market Members Markets Member) or RE100 Program
PS. These three conditions must be met in order for a company to be recognized as an SME and eligible to complete CDP's SME questionnaire.
PS. If the company also receives a disclosure request from the Capital Market Signatory, it must complete a complete corporate questionnaire. It is recommended that companies carefully evaluate whether they meet the above conditions before filling out the questionnaire and choose the appropriate questionnaire version to ensure the accuracy and completeness of the disclosure.
Module Breakdown
The following is a brief description of Modules 14–21:
Module 14: Organizational Basic Data
Collect basic information about the enterprise, including organizational boundaries, operating regions, industry classifications, etc.
Module 15: Risk/Opportunity Identification and Review Process
describes the process and methodology for how companies identify and assess climate-related risks and opportunities.
Module 16: Disclosure of Material Risks and Opportunities Disclosure
Disclosure of significant climate risks and opportunities identified by the company, as well as their potential impacts.
Module 17: Environmental Governance Responsibilities
Explain the responsibility allocation and organizational structure of enterprises in climate governance.
Module 18: Strategy and Overall Transformation Plan
describes the strategy and transformation plan developed by the company to address climate change.
Modules 19–20: GHG Scope, S1/S2/S3 Emissions, Targets and Reduction Actions
Report on the company's greenhouse gas emissions data (Scope 1, 2, 3), as well as set emission reduction targets and action plans.
Module 21: Signing and Confirmation
The accuracy and completeness of the questionnaire content are confirmed by senior management of the enterprise.
Questionnaire opening logic and authority type (Authority Type) In the SME questionnaire, each question is marked with a "Tag", where the "Authority Type" indicates which disclosure requesters will see the question: Supply Chain: Visible only to businesses requested by supply chain members All requesters: Visible to all disclosure requesters This design ensures that businesses only need to respond to questions related to their disclosure requests, reducing unnecessary reporting burdens.
CDP_SME_Modules_14_21_ analysis table/data source/Bu-Jhen low-carbon strategy
The CDP scoring system is designed to identify companies at different stages of climate governance maturity. Its structure adopts four logical processes (Scoring Levels), and uses "Reply Depth" and "Data Quality" as the core scoring criteria:
The Four Scoring Levels ( Disclosure):
1.Determine
whether the company has responded to the question.
Whether specific data (such as emissions, target values, activity data) is provided.
Whether to supplement explanations, attachments, and sources.
ü It means that the enterprise has started information collation and internal data inventory.
2.Awareness:
Determine whether the company understands the potential risks and opportunities of the issue.
Whether it can identify potential climate factors that affect operations and financial performance (e.g., carbon taxes, extreme weather).
ü It shows that the enterprise is building an initial understanding of risks and opportunities.
3.Management:
Determine whether the company has formal systems, policies, or goals to deal with the issue.
Is there a mechanism for continuous tracking (e.g., KPIs, capex tracking, annual carbon reduction targets, etc.).
ü Reflect that companies have begun to proactively manage and institutionalize climate impact.
4.Leadership:
Determine whether the company has demonstrated industry-leading actions, such as science-based carbon reduction targets (SBTi), verification (third-party verification), and impact on the supply chain.
Whether there are strategic innovation actions or forward-looking governance structures.
ü Must have data verification, impact diffusion, and governance integration.
Grading Scale is assigned after evaluating the level of the score (see Table 12.
Table 12. Scoring Rating Statement Table/Data Source/Bu-Jhen Low Carbon Strategy
The actual rating is not only based on the score, but also on whether it meets the completeness of the module's responses and key questions (e.g., verification, Scope 3).
The scoring mechanism adds
that not all questions are scored, such as some background questions are only used for data statistics.
Each question has a corresponding scoring logic table (Scoring Methodology) and corresponds to a specific score range according to the company's response options.
The scoring priority is module body > reply quality > supplementary description and accessory support.
ü Recommendation: Enterprises can download the "Scoring Guidance" of the corresponding module before filling in the application, and use the self-assessment form to compare the corresponding grading conditions for each question.
4.1 Scoring Levels and Progression Logic (D → C → B → A)
Table 13. Scoring Rating and Logical Analysis/Data Sources/Bu-Jhen Low-Carbon Strategy
Note: Some questions are scored using weighted averages, and some are Yes/No with justification, and the scoring mechanism varies slightly depending on the module.
4.2 Module-Specific Scoring Criteria
Although each module of CDP constitutes the overall score, its weight in the scoring system will vary slightly depending on the company's industry, disclosure module version, and type of participation (supply chain vs. investor requirements). However, overall, the Climate Core module is a necessary condition to achieve Grade A.
Core scoring modules and their importance:
ü Special attention: Scope 3 emissions (including Categories 1, 4, 9, and 11) will not be eligible for A grade if they are not disclosed.
The quality of the supply chain module's responses will affect the ESG evaluation scores and renewal conditions of suppliers by large buyers (e.g., Walmart, Apple).
Table 14. Summary of the importance of core scoring modules/data sources/Bu-Jhen low-carbon strategy
The scoring mechanism adds t
hat not all questions are scored, such as some background questions are only used for data statistics.
Each question has a corresponding scoring logic table (Scoring Methodology) and corresponds to a specific score range according to the company's response options.
The scoring priority is module body > reply quality > supplementary description and accessory support.
ü Recommendation: Enterprises can download the "Scoring Guidance" of the corresponding module before filling in the application, and use the self-assessment form to compare the corresponding grading conditions for each question.
4.3 SME Scoring Checking Model and Scoring Criteria
To assist small and medium-sized enterprises (SMEs) in effectively participating in environmental disclosure, CDP has designed a simplified scoring model focusing on Modules 15 to 20 and only evaluating two levels, Disclosure and Awareness, and not the Management and Leadership levels.
Scoring Scope and Modules
The scoring scope of the SME questionnaire covers the following modules:
Module 15: Risk and Opportunity Identification Process
Module 16: Material Risk and Opportunity Disclosure
Module 17: Governance and Senior Responsibility
Module 18: Strategy, Transformation Plan and Value Chain Engagement
Module 19: Greenhouse Gas Inventory Boundaries and Emissions Data (Scope 1, 2, 3).
Module 20: Goal Setting and Reduction Actions
Module 14 (Organizational Profile) and Module 21 (Signature and Confirmation) are not included in the scoring.
Scoring Levels vs. Standards
CDP's SME scoring model evaluates only two levels:
1. Disclosure
assesses whether the business has provided the requested information.
For example, whether greenhouse gas emission data is filled in, whether the risk identification process is described, etc.
2. Awareness
assesses how well a company understands the information it discloses.
For example, whether the potential impact of risks on the enterprise is explained, whether the feasibility of emission reduction targets is analyzed, etc.
The score for each question depends on the completeness and depth of the responses. If the information is not provided or the answers are incomplete, the corresponding score will not be awarded.
Scoring Methodology and Calculation
CDP uses a proportional scoring method that scores businesses based on the proportion of information they provide in each question. For example, if a question has 4 sub-questions and the company answers only 2 of them in full, the question is scored half out of the full score. In addition, CDP also considers the quality of the answers. For example, for the description of the risk identification process, if the company only provides a simple process name, it may only receive partial points; Higher marks are awarded if the process steps, departments involved, frequency, etc. are described in detail.
Scoring Suggestions and Precautions
Completeness:
Ensure that all sub-questions of each question are answered to avoid losing points due to omissions.
Specificity:
Provide specific data and cases, avoiding only general descriptions.
Consistency:
Ensure consistent answers across different questions to avoid conflicting information.
Accuracy:
Provide accurate data and information to avoid deducting points for incorrect information.
4.4 New Scoring System and Key Changes
in 2025 CDP's 2025 scoring system has raised higher requirements for corporate environmental information disclosure on a stable basis. The following are the main changes and suggestions for enterprises to respond :
1️. Increasing Importance of Scope 3 Emissions Disclosure
CDP emphasizes the need for companies to fully disclose Scope 3 emissions, covering indirect emissions upstream and downstream of the supply chain. Businesses that do not disclose or have incomplete disclosures may be deducted points from the score.
Response Recommendation:
Establish a comprehensive supply chain carbon emissions database covering all key suppliers.
Adopt digital tools for carbon emission data collection and analysis to improve data accuracy.
Cooperate with suppliers to promote their carbon emission inventory and emission reduction measures.
2️. Increased certification status requirements
CDP requires companies to conduct third-party verification of their greenhouse gas emissions data, especially Scope 1 and Scope 2 emissions data. Unverified data will affect a business's rating.
Response suggestion:
Hire a qualified third-party organization to verify carbon emission data.
Establish an internal audit mechanism to ensure data accuracy and consistency.
Regularly update carbon emission data to keep information up-to-date.
3️ Strengthening Financial Impact Disclosure Requirements
CDP requires companies to disclose the impact of climate change on their financial health, including revenue, costs, asset values, and more. Enterprises need to conduct risk assessments and provide relevant financial data and analysis.
Response Recommendations:
Establish a climate risk assessment model to quantify the financial impact of climate change.
Incorporate climate risk into corporate financial reporting and decision-making processes.
Collaborate with finance departments to ensure the integration and disclosure of climate-related information.
4️ Climate transition plan becomes a key point
CDP encourages companies to develop clear climate transition plans, set emission reduction targets, and describe implementation paths and timelines. Businesses that lack a transformation plan may be at a disadvantage in the rating.
Response Recommendations:
Establish science-based emission reduction targets and obtain relevant certifications.
Describe specific measures to implement the transition plan, including technology upgrades, energy transition, etc.
Establish monitoring and evaluation mechanisms to track the progress and effectiveness of transformation plans.
4.5 Common Pitfalls and Disclosure Mistakes
Even if companies invest in disclosure, many laggards still lose points due to poor reporting quality or missing key issues. This section summarizes the common reasons for deduction points and suggestions for improvement as follows: (See Table 15: Common Error Case Description Table)
Table 15. Common Error Case Description Table/Data Source/Summary of Bu-Jhen Low-Carbon Strateg
ü The judges value the completeness of the explanatory text and data traceability, especially in the three modules of Governance, Emissions, and Risks.
ü Errors in filling in are often due to unclear division of labor and unclear authority for data responsibility, so it is recommended to establish a clear internal questionnaire division mechanism first.
Not all questions are scored, such as some background questions are only used for statistics.
Each question has a corresponding scoring logic table (Scoring Methodology) and corresponds to a specific score range according to the company's response options.
The scoring priority is module body > reply quality > supplementary description and accessory support.
ü Recommendation: Enterprises can download the "Scoring Guidance" of the corresponding module before filling in the application, and use the self-assessment form to compare the
corresponding grading conditions for each question.
4.6 Practical Advice: How to Upgrade from D to B/A Grade? (Practical Tips for Score Improvement)
Based on the experience of Buzhen Low-Carbon Consulting and the logic of the CDP scoring mechanism, if a company
wants to gradually move from D level to B/A level, it can start with the following five strategies:
1.Establish a decision support structure (Governance First) starting from the governance module:
Establish a climate governance committee or cross-departmental working group with the participation of the board of directors or senior management.
Incorporate ESG or climate performance goals into performance appraisals and internal reward systems.
2.Strengthen emission data logic and verification:
Clearly disclose Scope 1 and 2 sources, emission factors, and calculation methods.
Conduct at least internal audits or partial third-party verification (e.g., ISO 14064-3, TAF).
3.Set Science-Based Targets:
Establish specific reduction targets using SBTi, RE100, and Net Zero project frameworks.
Clearly disclose the base year, target values, achievement progress, and tracking mechanisms.
4.Expand Supply Chain Management and Data Chain:
Design supplier ESG questionnaires, audit systems, or cooperation platforms.
Gradually collect Scope 3 basic data for Categories 1, 4, and 9 and include them in the scope of responses.
5.Introduce Leverage Advisory and Technology:
Seek third-party consultants (such as Buzhen Low Carbon Strategy) for pre-assessment and simulation scoring.
Utilize ORS filling out the report, module mapping diagram, and Scoring Guidance tool.
ü It is recommended that companies formally include reporting tasks in their annual ESG plans or risk management KPIs, and manage them from a systematic perspective to improve the quality of reporting and organizational memory.
4.7 Application and Practical Suggestions of Scoring Methodology
CDP rating grades from A~F Please refer to the table
CDP scoring methodology not only provides an assessment of the current status of enterprises in environmental
governance, but also guides enterprises on the path to improve environmental performance. Through scoring
methodologies, companies can:
1.Identify (identify) areas for improvement: The scoring results reveal the company's performance at all levels of disclosure, cognition, management, and leadership, helping companies understand where they need to be strengthened.
2.Develop Improvement Strategies: Based on specific indicators in the scoring methodology, companies can formulate targeted strategies, such as strengthening climate risk assessment, setting science-based targets (SBTi), and improving environmental management in the supply chain.
3.Enhance transparency and trust: Complete and transparent information disclosure helps build trust with investors and other stakeholders, enhancing the company's market competitiveness.
It is recommended that companies carefully read the relevant scoring methodology documents before filling out the CDP questionnaire and refer to the guidelines and best practices provided by CDP to ensure the completeness and accuracy of the responses. Additionally, companies should continue to monitor updates to CDP scoring criteria to ensure their environmental governance strategies align with international standards. The following is a detailed CDP (Carbon Disclosure Program) 2024 rating scale (A to F), compiled according to the latest scoring methodology, applicable to topics such as climate change, forests and water resources (please refer to Table 16. CDP rating comparison table).
Table 16. CDP rating comparison table/data source/Bu-Jhen low-carbon strategy
CDP (2025) Rating Criteria Detailed Table/Sources/Bu-Jhen Low Carbon Strategy
Note :
1.Businesses need to progress through each scoring stage and meet specific "prerequisites" to advance to the next level.
2. Businesses using the minimum version of the survey can get a maximum A- score and cannot enter the A grade.
3.CDP updates its scoring methodology annually, and companies are advised to regularly review the latest scoring criteria and guidelines.
CDP replied that it was not a one-day project, and the successful disclosure relied on cross-departmental cooperation, data inventory, and management mechanism integration. This chapter is based on the practical counseling experience of Buzhen Consulting to assist enterprises in building an annual reporting schedule and systematic preparation process.
5.1 Initial Readiness and Cross-Team Collaboration
1.Assign Responsible Units and Windows:
It is recommended that the Sustainability Department, ESG Committee Secretariat, Accounting Department, or Corporate Social Responsibility Leader serve as the responsible point to coordinate questionnaire planning, task assignment, and external contact.
2.Establish a cross-departmental working group:
It is recommended that the members include the environmental safety and health department (EHS), engineering and maintenance, procurement, legal affairs, brand and marketing, risk control, capital planning, and IT.
Shared platforms (such as Teams, Google Drive) can be created for data aggregation and audit record retention.
3.Take stock of past disclosures and scoring records:
Organize the CDP response version and score report from the previous year.
Mark deduction points and suggestion fields to turn them into improvement measures and project tasks for the current year.
4.Confirm whether to introduce consulting guidance:
For first-time participants, those with high pressure in the multinational supply chain, or those who need to respond to TCFD/ISSB simultaneously, it is recommended to outsource a consulting company to assist in questionnaire guidance, data collation, and simulation scoring.
Consultants can also assist in liaising with CDP officials, reviewing data formats, and benchmarking peer examples.
ü Practical reminder: It is recommended to simultaneously create a corresponding list of "Problem-Data-Source-Person in charge" during the inventory stage, and the subsequent filling process will be greatly accelerated.
5.2 Response Timeline and Project Planning
To ensure that the CDP questionnaire can be completed on time and with high quality, it is recommended that companies formulate an annual project schedule according to the following stages, combined with internal collaboration and consulting support. CDP Response Questionnaire Schedule:
Form 17. CDP Response Questionnaire Timeline/Data Source/Bu-Jhen Low Carbon Strategy
ü Note: For some companies disclosing for the first time, it is recommended to extend the overall operation timeline to 5-6 months to avoid compressing the space for review and optimization.
Practical Advice: You can set up a "progress dashboard" and monthly review milestones at the beginning of the project, and track progress in conjunction with ESG/financial meetings.
5.3 Calculation Methods, Emission Factors, and Data Quality
Successful responses to CDP questionnaires require data calculation and corroboration according to standard methods, and ensure that the data sources are consistent and traceable. The following are the recommended preparation data aspects and key calculation elements:
1.Organizational and Operational Boundary Setting:
Describes the organizational boundaries applicable to emissions calculations (e.g., operational controls, financial controls, joint venture ratios, etc.)
confirm whether the reporting coverage is consistent with the annual financial report
2.Emissions Data Calculation and Tables (GHG Emission Tables ):
Calculating Scope 1 (direct emissions), Scope 2 (indirect electricity), and Scope 3 (supply chain and value chain) according to the GHG Protocol
It is recommended to use Excel tables to summarize emission sources, activity data, and corresponding emission factors for each site.
3.Other environmental and operation-related data:
energy consumption (fuel, electricity, spontaneous renewable energy),
water consumption and recycling rate, capital expenditure (CAPEX),Operating expenses (OPEX), climate-related risk event records (such as flooding, power cuts),
climate transition (carbon fees, ETS operating burdens, carbon credit assets, etc.)
4. Governance and carbon reduction action supporting data:
Climate governance framework documents, risk control flow charts, carbon reduction strategy reports, and
implementation progress tracking records can be included in records with internal presentations, meeting minutes, or board issues to prove the degree of integration,
5.supply chain carbon inventory tools and questionnaire data
If participating in the Supply Chain Module, it is recommended to compile the supplier's ESG questionnaire results or GHG data in advance, which can be combined with EEIO tools, supplier carbon footprint reports, or self-designed templates (such as the Buzhen Consulting version)
ü Comparison of main terms:
Activity Data: Activity data (such as usage, mileage, fuel consumption)
Emission Factor: Emission factors (such as CO₂). e / l)
Operational vs. Financial Control: The basis for selecting the boundary between operational control and financial control
5.4 Case Studies from Bu-Jhen Low Carbon Strategy
First, the data quality of high-weight modules (e.g., Governance, Emissions, Risks) is reinforced, a traceable supporting folder structure (operated with the ORS auxiliary system) is used to calculate the accuracy requirements of the answers to the scoring system (the rating conditions for each question of the questionnaire are listed as). KPI) to practice the ORS filling system in advance to avoid mistakes in the final stage.
6.1 CDP Evolution and Upcoming Changes
1.The questionnaire is fully aligned with IFRS S2 (ISSB) trends: CDP has been officially announced as one of the IFRS S2 implementation support platforms, and it is expected that the questionnaire will enhance the following content in the future:
Quantitative disclosure of the financial impact of climate risks (e.g., revenue impact, capital expenditure adjustments)
Climate scenario simulation and sensitivity analysis
Clarification of manager performance linkage and board supervision
2.Introduction of double materiality: The questionnaire design gradually incorporates the spirit of the EU CSRD, which not only evaluates the impact of climate on the company (financial standard) but also focuses on the impact of the company on the environment and society (impact standard).
3.Scope 3 Category Disclosure and Verification Enhancement: It is expected that key upstream, midstream, and downstream items such as Categories 1, 4, 9, and 11 will gradually be changed from "optional questions" to "required items for scoring", and disclosure of data sources, calculation logic, and verification methods will be required.
4.Expansion of the Non-Carbon Issues Module:
Natural Capital and Biodiversity: Starting from 2024, CDP has included forests and water resources and has begun to pilot "nature-related disclosures" (such as TNFD-equivalent modules)
Biodiversity risks, land use impacts, and regional water risk identification will be included in the scoring module
ü It is expected that in the next three years, CDP will no longer just be a climate disclosure questionnaire, but will transform into a cross-domain sustainable governance integration survey
6.2 Integration with ISSB/IFRS S1 & S2
1.CDP as the IFRS S2 Questionnaire Disclosure Platform: Starting in 2024, CDP will officially become one of the implementation tools for the IFRS S2 climate disclosure standard developed by the ISSB (International Sustainability Standards Board). By completing the CDP questionnaire, companies can synchronously meet the compliance requirements of IFRS S2 for climate disclosure.
2.CDP Questionnaire Content Corresponds to IFRS Framework Enhancement: The ISSB focuses on the comparability and consistency of climate-related financial information, and the CDP Questionnaire will continue to strengthen disclosure in the following aspects in the future:
The correlation between capital expenditure (CAPEX) and
climate reduction strategies illustrates the quantitative assessment of financial impact, such as climate risk changes in tax rates, cost increases, and insurance premium increases
the consistency and integration between climate information and corporate statutory documents (such as financial reports and annual reports).
3.ISSB emphasizes risk financialization and information integration: CDP translates the TCFD framework and IFRS S2 requirements into specific reporting items through modular design, providing enterprises with a step-by-step implementation path.
ü Professional advice: If Taiwanese companies have already implemented the TCFD or are about to cooperate with the ISSB framework implemented by the Financial Supervisory Commission, they can prioritize CDP as an export of standardized disclosure data, taking into account financial market communication and legal compliance responses.
1.The questionnaire is fully aligned with the IFRS S2 (ISSB) trend: CDP has officially announced itself as one of the IFRS S2 implementation support platforms, and it is expected that the questionnaire will strengthen the following content in the future: quantitative disclosure of the financial impact of climate risks (e.g., revenue impact, capital expenditure adjustments), climate scenario simulation and sensitivity analysis, manager performance linkage, and board oversight
2.Introduction of Double Materiality: The questionnaire design gradually incorporates the spirit of the EU CSRD, not only assessing the impact of climate on companies (financial-based) but also focusing on their impact on the environment and society (impact-based).
3. Scope 3 Category Disclosure and Verification Enhancement: It is expected that key upstream, midstream, and downstream items such as Categories 1, 4, 9, and 11 will gradually be changed from "optional questions" to "required items for scoring", and disclosure of data sources, calculation logic, and verification methods will be required.
4.Expansion of Non-Carbon Topics Module: Natural Capital and Biodiversity: Starting in 2024, CDP has included forests and water resources, and has begun to pilot "nature-related disclosures" (such as TNFD corresponding modules) to include biodiversity risks, land use impacts, and regional water risk identification into the scoring module.
ü It is expected that in the next three years, CDP will no longer be just a climate disclosure questionnaire, but will transform into a cross-domain sustainable governance integration platform.
6.3 Taiwan Companies' Strategy and Competitiveness
1.Upgraded from ESG disclosure to part of the corporate governance framework:
It is recommended that companies formally incorporate their climate strategies into regular discussions among the board of directors, supervisors, or senior management.
Set up a dedicated unit responsible for annual disclosure, verification data preparation, and cross-platform reporting (such as CDP, ISSB, GRI).
2. Introduce standardized data and tracking systems:
Establish an internal database of GHG, energy, climate risks, and targets, and modularize and electronically manage data for each module.
Ensure that the data supports multi-platform disclosure and scoring requirements (e.g., CDP questionnaire + IFRS S2 financial integration report).
3.Strengthen cross-departmental collaboration and supply chain cooperation:
Promote supply chain carbon disclosure and carbon reduction education, send ESG questionnaires, conduct audits, and conduct data inventory.
Incorporate key suppliers into targeting and verification mechanisms to strengthen Scope 3 entity visibility.
4.Utilize external resources to enhance disclosure maturity:
Make good use of professional consulting firms (such as Buzhen Low Carbon Strategy) for data auditing, CDP simulation scoring, and industry benchmarking analysis.
Build a questionnaire filling plan and version management system with third-party technical assistance tools to improve flexibility and efficiency in responding to CDP updates.
ü Practical Advice: Enterprises should incorporate CDP into the overall blueprint of their sustainability governance strategy as soon as possible, transforming "disclosure" into corporate competitiveness.
1.CDP Becomes the IFRS S2 Questionnaire Disclosure Platform: Starting in 2024, CDP will officially become one of the implementation tools for the IFRS S2 climate disclosure standard developed by the ISSB (International Sustainability Standards Board). By completing the CDP questionnaire, companies can synchronously meet the compliance requirements of IFRS S2 for climate disclosure.
2.CDP Questionnaire Content Corresponds to IFRS Framework Enhancement: The ISSB focuses on the comparability and consistency of climate-related financial information, and the CDP Questionnaire will continue to strengthen disclosure in the following aspects in the future: The correlation between capital expenditure (CAPEX) and climate reduction strategies illustrates the quantitative assessment of financial impact, such as climate risk changes in tax rates, cost increases, and insurance premium increases, and the consistency and integration between climate information and corporate statutory documents (such as financial reports and annual reports).
3. ISSB emphasizes risk financialization and information integration: CDP translates the TCFD framework and IFRS S2 requirements into specific reporting items through modular design, providing enterprises with a step-by-step implementation path.
ü Professional advice: If Taiwanese companies have already implemented the TCFD or are about to cooperate with the ISSB framework implemented by the Financial Supervisory Commission, they can prioritize CDP as an export of standardized disclosure data, taking into account financial market communication and legal compliance responses.
The questionnaire is fully aligned with the IFRS S2 (ISSB) trend: CDP has officially announced itself as one of the IFRS S2
implementation support platforms, and it is expected that the questionnaire will strengthen the following content in the
future:
quantitative disclosure of the financial impact of climate risks (e.g., revenue impact, capital expenditure adjustments),
climate scenario simulation and
sensitivity analysis, manager performance linkage, and board oversight
2.Introduction of Double Materiality: The questionnaire design gradually incorporates the spirit of the EU CSRD, not only assessing the impact of climate on companies (financial-based) but also focusing on their impact on the environment and society (impact-based).
3.Scope 3 Category Disclosure and Verification Enhancement: It is expected that key upstream, midstream, and downstream items such as Categories 1, 4, 9, and 11 will gradually be changed from "optional questions" to "required items for scoring", and disclosure of data sources, calculation logic, and verification methods will be required.
4.Expansion of Non-Carbon Topics Module: Natural Capital and Biodiversity:
Starting in 2024, CDP has included forests and water resources and has begun piloting "nature-related disclosures" (such as TNFD's corresponding modules)
include biodiversity risks, land use impacts, and regional water risk identification in the scoring module
It is expected that in the next three years, CDP will no longer be just a climate disclosure questionnaire, but will transform into an integrated platform for cross-domain sustainable governance.
CDP replied that it was not a one-day project, and the successful disclosure relied on cross-departmental cooperation, data inventory, and management mechanism integration. This chapter is based on the practical counseling experience of Buzhen Consulting to assist enterprises in building an annual reporting schedule and systematic preparation process.
6.4 Does the SME questionnaire cover forest, water and biodiversity disclosures?
According to CDP's official note, the SME questionnaire mainly focuses on climate change-related issues, covering Modules 14 to 21, including basic organizational information, risk and opportunity identification, governance structure, strategy and transformation plan, greenhouse gas emissions data, target setting and reduction actions, and signing confirmations. As for issues such as forests, water resources and biodiversity, CDP's SME questionnaire does not include related questions. These topics are predominantly present in the full corporate questionnaire and are subject to the following factors:
1.Source of disclosure requirements: If a company receives a request for disclosure from a CDP capital markets signatory, supply chain member, bank plan member or private market member, it may be necessary to complete a complete corporate questionnaire covering issues such as forests, water resources and biodiversity.
2.Industry impact classification: CDP determines the impact of a company's business activities on forests and water resources based on the Activity Classification System (CDP-ACS) to determine whether to request disclosure.
3.Self-assessment: Companies may be required to disclose information if they indicate that they have identified material issues related to forests or water resources in their survey settings.
4.Voluntary Disclosure: Even if not required, companies can choose to voluntarily disclose information related to issues such as forests, water resources, or biodiversity.
It's important to note that these criteria apply primarily to the full enterprise questionnaire and not to the SME questionnaire. For SMEs, if they only receive disclosure requests from supply chain members, bank plan members, private market members, or RE100 programs, and meet the applicable conditions of the SME questionnaire (annual revenue of less than $2.5 billion and less than 500 employees), they can choose to complete the SME questionnaire without disclosing forests, water resources, and biodiversity. However, if a company wishes to proactively disclose these issues or receives a request for disclosure from a signatory to the capital market, it is required to complete a corporate questionnaire and provide the appropriate information according to the relevant requirements. It is recommended that companies carefully evaluate the source of their disclosure requirements and business activities before filling out the questionnaire, and choose the appropriate questionnaire version to ensure the accuracy and completeness of the disclosure.
Appendix A-1: Module 13 Extended Explanation - Biodiversity, Land Use, and Waste Management
Module 13 Enhancement Explanation: Biodiversity, Land Use, Waste Management
Although Module 13 covers "Other Environmental Issues", it is becoming increasingly important and is expected to account for a higher proportion in the score in the future. The following are common questions and suggestions for biodiversity, land use, waste management, and other aspects in the CDP questionnaire:
The Biodiversity Impact
questionnaire asks companies whether they identify actual or potential negative impacts on biodiversity from their operations.
The recommended content includes: whether the operation site is close to the protected area, whether it interferes with ecological habitats, whether it uses rare resources, etc.
Example: The operation base is adjacent to a wetland reserve, and a rainwater recycling system has been installed to reduce emissions.
Land Use & Conversion
focuses on whether corporate development activities cause the loss of natural habitats, carbon sink loss, soil damage, etc.
It is recommended that enterprises fill in "whether land use changes have been involved in the past five years" and "whether they have adopted the principle of low-impact development".
Example: No new expansion plans have been added in the past three years, and land development has been approved by the EIA and the original habitat compensation plan.
The Waste Management
questionnaire will ask about the total amount of waste generated, treatment methods, and reuse ratios.
It is recommended that the applicants be classified into "hazardous and general waste", "internal reuse and external recycling".
Example: A total of 120 tons of waste were generated in 2024, with 70% of it being recycled by qualified recyclers.
Integration with TNFD and Biodiversity Trends:
It is expected that in the future, CDP will further integrate the TNFD (Working Group on Nature-related Financial Disclosures) framework to introduce the logic of natural asset risk and impact disclosure.
It is recommended that enterprises prioritize the relationship between their operational activities and land/ecology and gradually incorporate them into the natural asset disclosure framework.
It is recommended that first-time disclosure companies adopt a simplified response in Module 13, focusing on known risks and ongoing resource management measures to avoid overly empty answers.
Appendix A-2. Glossary: Chinese-English Terms
Appendix B.-1 Module Summary Reference Sheets
Appendix C. Scoring system brief table and comparison
Appendix D. Questionnaire Logic and Timeline Flowcharts
CDP questionnaire design is logical and coherent in module structure, and it is recommended that enterprises draw logical flow charts during the startup stage, corresponding to the following three types of logical axes:
1.Logic path flow design (Question Flow ):
Each module starts the next question (logical skip question design) according to the answer conditions (e.g., Q0.1 organizational characteristics)
If a specific category is not checked, subsequent modules will be automatically skipped (if no water topic is selected, the Water Module will not appear)
2.Filling in the logic suggestion flow chart:
Step 1: Complete the Q0.1~Q0.5 Basic information and organizational boundary setting (including subsidiaries, sites, and operational boundaries)
Step 2: Complete the Governance and GHG Emissions modules (Scope 1, 2, 3)
Step 3: Enter the Targets, Risks & Opportunities, and Performance Indicators modules
Step 4: Disclose value-added modules such as water resources, forests, and supply chains according to the industry
Questionnaire filling order:
1. Q0 Basic questionnaire information (including organizational boundaries, subsidiaries, and operating sites)
2.Governance module (board governance and responsibility)
3.GHG emissions module (Scope 1/2/3 data and calculation methods)
4.Targets module (reduction targets, SBTi, RE100)
5.Risk and opportunity module (climate risk classification, financial impact).
6.Value-added modules: Fill in one or more of the following according to the characteristics of the company:
Water Module
Forests Module
Supply Chain
Timeline Summary:
📅 April: Questionnaire official launch and briefing session
📅 May~July: Data preparation and module drafting
📅 August: Consultant/senior management team review and cross-check
📅 September: Launch of the ORS system Completion of formal submission
📅 October~November: Review, optimization, and internal report planning
Appendix D. Overview of the logical flow chart and submission schedule of the questionnaire module
ü Appendix E. Latest Membership System and Application Instructions (2025 Official Website Data Summary) (CDP Membership Reference)
n CDP Membership Types: Divided into three levels: Standard, Silver, and Gold, providing different levels of technical support, response guidance, and information feedback.
n Application method: Companies can apply for membership through the CDP official website and select the type of participation (investor disclosure, supply chain disclosure, voluntary disclosure).
n Summary of member benefits:
u Priority access to technical documentation and filling assistance templates
u Dedicated consultant support and troubleshooting services (specific levels)
u Access to training and international initiatives provided by CDP
n Fee structure: Depending on the size of the company and the scope of participation, some self-disclosers will be required to pay a processing fee (e.g., starting from £850) in 2025.
n Supply Chain Member Roles: Large buyers such as Apple and Walmart are already CDP Supply Chain Members and can require their suppliers to participate in the disclosure process and provide regular performance feedback.
ü Appendix F: Pre-Disclosure Self-Assessment Checklist The following are ten internal self-assessment indicators recommended by enterprises before formally filling out the CDP questionnaire, to help assess data maturity and organizational readiness:
Appendix I: Reference Notes and Source Attribution
1 . CDP Questionnaires and Reporting Guidelines (2025 Edition)
CDP. "Questionnaire and Reporting Guidance 2025." CDP, 2025, https://www.cdp.net/en/disclose/question-bank. Our Question Bank+3CDP: Turning Transparency to Action+3CDP: Turning Transparency to Action+3
2. CDP Scoring Methodology (2024 Edition)
CDP. "Scoring Guidance for Companies." CDP Help Center, 2024, https://help.cdp.net/en-us/knowledgebase/article/KA-01083. CDP Help Center+1 CDP Help Center+1
3. CDP Climate Change Questionnaire (2023 Edition)
CDP. "Climate Change Questionnaire 2023." CDP Guidance, 2023, https://guidance.cdp.net/en/guidance?cid=46&ctype=theme&idtype=ThemeID&incchild=1µsite=0&otype=Questionnaire&tags=TAG-13071%2CTAG-605%2CTAG-599.
4. CDP Climate Change Scoring Methodology (2023 Edition)
CDP. "Climate Change Scoring Methodology 2023." CDP Guidance, 2023, https://guidance.cdp.net/en/guidance?cid=46&ctype=theme&idtype=ThemeID&incchild=1µsite=0&otype=ScoringMethodology&page=1&tags=TAG-605%2CTAG-13071