Preparing for CDP 2025: Early lessons and practical insights for climate disclosure success

“Starting early and engaging the right experts across your organisation makes all the difference. CDP 2025 isn’t just about compliance. It’s about building robust, future-focused sustainability management.” 

As the CDP’s 2025 reporting window opens, many organisations are facing new requirements, complex datasets, and heightened scrutiny. At Nexio Projects, we’ve supported early submissions and want to share actionable lessons to help your team maximise its score, avoid common bottlenecks, and leverage the CDP Reporting Framework as a pathway to deeper climate maturity. 

Tips for a comprehensive CDP submission

1. Engage data custodians early: Don’t leave it too late 

Critical insight: Initiate engagement with relevant data custodians and managers as early as possible. This is particularly vital for Modules 2, 3, 4, and 5, which require detailed and sometimes cross-referenced data. 

Why it matters: Early access to critical datasets mitigates the risk of missed deadlines due to late data delivery and supports more accurate, complete disclosures. 

How to do this: 

• Map your organisation’s “data landscape” to identify where each data type resides. 
• Set recurring touchpoints with responsible teams. 
• Clarify submission deadlines and dependencies at the outset. 

See our case studies for practical examples of cross-functional collaboration:

2. Allocate extra time and resources for Module 7 

Why Module 7 is different: It is the most comprehensive section of the CDP questionnaire, requiring: 

• A full organisational carbon footprint (Scopes 1, 2, and 3). 
• Detailed methodologies and explanations for any exclusions. 
• Disaggregated energy consumption data (by country, business line, facility, etc.). 
• Climate targets, additional metrics, and land management details. 
• Evidence of third-party verification or assurance. 

Practical tip: Treat Module 7 as a standalone project stream. Assign or second dedicated personnel and consider external support, particularly if this is your first complete submission. 

3. Scrutinise module guidance: Details make the difference 

Best practice: For Modules 2, 3, 4, 5, and 7, meticulously review the specific guidance for each question — particularly the final columns, which often request granular and referenced information. 

Action: 

• Create a module-by-module checklist capturing all dependencies and required detail. 
• Build in peer reviews before finalisation. 

4. Honour strict time boundaries: 2024 data only 

The 2025 CDP reporting cycle is a snapshot of your 2024 financial year. Including forward-looking developments from 2025 can cause inconsistencies and risk point deductions. 

Tip: Lock in your reporting boundaries and communicate them clearly to all stakeholders. 

 5. Distribute responsibilities tosubject matter experts 

Assign modules to internal experts, especially Modules 2, 3, 4, 5, and 7, to leverage specialised knowledge and ensure business language consistency. 

How?

• Hold kick-off sessions to clarify roles, terminology, and deliverables. 
• Implement structured internal review sessions to maintain alignment. 

6. Deep dive: Climate risk, business strategy, and governance 

For Modules 2, 3, and 5: 

• Define explicit time horizons for risks and opportunities. 
• Document robust processes for assessing dependencies, impacts, risks, and opportunities — including their interconnections. 
• Prioritise locations across your value chain. 
• Establish criteria for what constitutes “substantive effects.” 
• Identify financial effects and link them to aligned metrics. 
• Conduct and document scenario analysis. 
• Outline a climate transition plan integrated into business strategy and financial planning. 

For Module 5 (Business Strategy): 

• Link your climate transition plan to revenue streams. 
• Map activities to sustainable finance taxonomies and provide evidence of taxonomy alignment. 
• Showcase R&D activities for low-carbon products and services. 
• Include carbon pricing mechanisms and sustainable procurement policy frameworks. 
• Demonstrate systematic engagement with your value chain on environmental issues. 

For Module 4 (Governance): 

• Work closely with your legal team to review governance statements, accountability frameworks, incentive schemes, environmental policies, memberships, and lobbying disclosures. 
• Legal oversight helps avoid misrepresentation and reduces regulatory risk. 

7. Data integrity: Reconciling quantitative figures 

CDP allows only a 5% variance between sub-totals and aggregated figures. Exceeding this threshold leads to immediate point deductions. 

Recommendation: 

• Build reconciliation checks into your process for Module 7 and related modules. 
• Confirm that subtotals by country, facility, or activity precisely match the reported grand totals. 

8. Plan internal reviews and timelines: Avoid workflow bottlenecks 

Why it matters: Missed deadlines and rushed reviews increase the risk of errors and inconsistencies. 

Action points: 

• Schedule structured internal reviews with clear deadlines. You can use a Gantt chart to track built-in review points and key internal deadlines. 
• Factor in public holidays and annual leave to maintain momentum. 

9. Essential criteria: The gatekeepers to success 

Incomplete or incorrect responses to Essential Criteria questions can cap your score, regardless of the strength of the rest of your submission. 

Tip: Triple-check these questions for accuracy and completeness before final submission. 

Want to find out more about CDP’s essential criteria? Watch our climate expert break it down.

Q&A: Your CDP 2025 reporting questions answered 

Q1: Why is it important to engage data custodians early in the CDP reporting process, especially for Modules 2, 3, 4, and 5? 

A: Early engagement ensures timely access to critical datasets, mitigating the risk of missed deadlines due to late data delivery. Modules 2, 3, 4, and 5 often require detailed and sometimes cross-referenced information from multiple sources. Proactively involving data owners supports more accurate and complete disclosures, helping uphold data quality and boosting your final CDP score. 

Q2: What makes Module 7 particularly resource-intensive and how should we prepare? 

A: Module 7 is the most comprehensive section, demanding a full organisational carbon footprint, detailed methodologies, explanations for exclusions, Scope 1, 2, and 3 emissions, country-level data, climate targets, metrics, land-management practices, and verification. Allocate sufficient resources, time, and expertise—think of it as a mini project within your CDP submission. Consider both internal expertise and, where needed, external support. 

Q3: How can we ensure our answers are sufficiently detailed and cross-referenced, especially in Modules 2, 3, 4, 5, and 7? 

A: Meticulously follow the latest CDP guidance for each question—pay close attention to the final columns, which may request granular or referenced data. Map dependencies between modules, schedule peer reviews, and create a checklist of required details. Gaps in cross-referencing can negatively affect both quality and scoring. 

Q4: Why must we only report on the 2024 financial year during the 2025 CDP cycle? 

A: CDP scoring is based strictly on a snapshot of your organisation’s performance in the 2024 financial year. Including developments from 2025 or any forward-looking information can lead to inconsistencies in your disclosure and result in point deductions. Confirm that all contributors understand this temporal requirement to keep your submission CDP-compliant. 

Q5: What are best practices for distributing responsibilities and ensuring consistency in reporting? 

A: Assign modules to subject matter experts and relevant stakeholders, especially for those requiring significant domain knowledge. Clearly communicate roles, use centralised terminology lists, and hold regular review sessions to maintain a consistent voice throughout responses. This approach improves both reliability and business language consistency, supporting higher scores. 

Q6: For Modules 2, 3, and 5, what should our internal climate risk and business strategy assessments cover? 

A: 

• Define explicit time horizons for climate risks and opportunities. 
• Document processes for assessing dependencies, impacts, risks, and opportunities—including how these interact. 
• Prioritise value chain locations, set criteria for “substantive effects,” and link metrics to financial outcomes. 
• Provide scenario analysis results and present a transparent climate transition plan aligned with business strategy and financial planning. 

Q7: How do we ensure governance responses (Module 4) are accurate and compliant? 

A: Work closely with your legal department to review governance structure descriptions, accountability systems, incentive frameworks, environmental policies, external memberships, and lobbying disclosures. Legal review safeguards against misrepresentation and reduces regulatory risk. 

Q8: What are the risks if data subtotals don’t reconcile with the aggregates, especially in Module 7? 

A: CDP allows a variance margin of only 5%; exceeding this leads to immediate point deductions and can heavily impact your score. Rigorously check that all subtotals (by country, facility, etc.) precisely add up to the reported grand totals—build in reconciliation reviews before submission. 

Q9: What scheduling tactics help avoid workflow bottlenecks? 

A: Plan ahead—incorporate internal and public holidays into module planning and set clear deadlines. Scheduled internal review sessions and early engagement with data owners help maintain uninterrupted progress. 

Q10: Why are Essential Criteria questions so important and how should we approach them? 

A: These questions are gatekeepers to your CDP score ceiling. Incomplete or incorrect responses can drastically reduce your maximum achievable score, regardless of strengths elsewhere. Triple-check completeness and accuracy before submission. 

Feel free to adapt or expand the Q&A to address any specific queries or feedback you have received from clients during this year’s CDP reporting process. This approach reinforces critical learnings and offers actionable guidance, helping organisations deliver more robust and confident climate disclosures. 

Conclusion: From reporting to resilience 

CDP reporting is a powerful tool to enhance your organisation’s climate governance, risk management and investor trust. Approach the 2025 cycle not as a tick-box exercise, but a chance to invest in robust, future proofed sustainability management. 

How Nexio Projects can partner with you

 Nexio Projects is a sustainability consultancy in the Netherlands, guiding organisations worldwide in managing climate risks and achieving impactful environmental goals. As a sustainability expert and ESG advisory partner, Nexio Projects offers tailored sustainability services, including specialist CDP reporting support to help companies improve disclosure, boost scores, and align with climate leadership standards. Recognised as a Certified B Corporation and named among Europe’s top boutique ESG consultancies by Verdantix, our climate change consultants support businesses across industries to transition from compliance to purpose.

Ready to get started or need support refining your submission? Contact our expert team for personalised guidance and solutions. Let’s maximise your impact together. 

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