CDP
CDP (formerly the Carbon Disclosure Project) - environmental disclosure platform · CDP
CDP runs a disclosure platform through which companies report environmental data, typically in response to requests from investors and from customers in their supply chain. It is not a standard-setter in the way the ISSB, GRI or ISO are: it collects and scores disclosures rather than issuing accounting rules. GRI publishes a mapping from GRI 102 and GRI 103 to CDP's climate change and energy questions, dated 21 October 2025.
What this means in Singapore
CDP is not part of Singapore's regulatory stack. SGX Practice Note 7.6 requires the issuer to select a sustainability reporting framework and names the IFRS Sustainability Disclosure Standards, the GRI Standards, the SASB Standards and the Integrated Reporting Framework as recognised choices. CDP is not among them - which makes sense, since it is a disclosure channel rather than a reporting framework. Responding to CDP does not discharge any SGX or ACRA obligation.
So why does it matter here?
1. It is often the first thing that forces a Singapore company to count. The regulatory phase-in is generous. All listed issuers report Scope 1 and 2 from FY2025, but the full ISSB-based climate package does not reach non-STI issuers below S$1 billion until FY2030, and large non-listed companies until FY2030, with Scope 3 voluntary for both. Meanwhile a single request from a multinational customer or an institutional investor can require a complete inventory now. For a great many Singapore companies, particularly suppliers in electronics, chemicals, logistics and food, the commercial deadline arrives years before the regulatory one.
2. The data it asks for is the data the regulations will ask for. Whatever the questionnaire looks like in a given year, it rests on the same foundations: a defined organisational boundary and consolidation approach, activity data with an audit trail, emission factors with a stated vintage, a base year with a recalculation policy, and Scope 2 reported on a location-based basis with any contractual instruments described. Building that once serves CDP, IFRS S2 under SGX Practice Note 7.6, a GRI content index and an SBTi submission. Building it four times is a common and avoidable mistake.
3. Singapore-specific disclosures travel with the numbers. Two in particular should accompany any Singapore Scope 2 figure wherever it goes, CDP included. First, the national grid emission factor is published as kgCO2 per kWh - carbon dioxide only, not CO2 equivalent - so a Scope 2 figure derived from it excludes methane and nitrous oxide from generation, and the exclusion should be stated. Second, no residual mix has been identified for Singapore, so a company making a market-based claim must disclose that an adjusted factor is not available and that this may result in double counting between electricity consumers.
4. Interoperability is real but conditional. The pattern across this hub is that one properly built greenhouse gas dataset can serve several audiences, but only if the conditions attached to each equivalence are met. The GRI and ISSB equivalence statement of June 2025, for instance, holds only where emissions are measured under the GHG Protocol Corporate Standard (2004) and the report carries cross-references showing where each disclosure sits. Assume similar conditions apply elsewhere, and check them rather than assuming a number can be lifted from one report into another.
5. Where to look. For what CDP currently asks and how it relates to the ISSB Standards, go to CDP's own site. For the mapping between GRI's climate and energy standards and CDP's climate change and energy questions, use the linkage document dated 21 October 2025 on GRI's global alignment page - and note that the corresponding water mapping dates from 2018 and is no longer a reliable guide.
How the framework works
What CDP is, and what it is not
CDP is a disclosure platform. Companies respond to environmental questionnaires, usually because an investor or a large customer has asked them to, and CDP holds and scores the resulting data. That is a different function from the other frameworks in this hub. The ISSB and GRI write disclosure standards. The GHG Protocol and ISO 14064 write measurement and verification rules. CDP is the channel through which a great deal of the resulting data actually reaches the people asking for it.
The scale of that dataset is what gives CDP its quiet influence. When GHG Protocol set out its case for eliminating the equity share consolidation approach in the December 2025 Corporate Standard progress update, the evidence it cited was that only 2 per cent of companies publicly disclosing emissions to CDP in 2023 chose the equity share approach. That is a small illustration of a general point: CDP responses are one of the few places where you can see what companies actually do, at scale, rather than what standards say they should.
CDP also sat as a peer reviewer on GRI 102: Climate Change 2025, alongside SBTi and ISO, with the GHG Protocol on the technical committee - so it participates in standard-setting as a stakeholder even though it does not set standards itself.
Why companies end up in it
For most Singapore companies, CDP arrives from outside rather than being chosen. The two common routes are:
- Investor request. Institutional investors ask portfolio companies to disclose through CDP, and non-response is itself visible.
- Supply chain request. A large customer asks its suppliers to disclose. This is increasingly the route by which small and medium enterprises encounter formal emissions reporting for the first time - often before any regulatory requirement touches them.
That second route deserves emphasis in a Singapore context. A local manufacturer or service provider with no SGX listing and revenue far below the large non-listed company thresholds can still find itself needing a complete Scope 1 and 2 inventory, and increasingly parts of Scope 3, because a multinational customer has asked. Regulatory timelines are not a reliable guide to when a company will first need these numbers.
How it fits with the frameworks that do set rules
The practical relationship is that CDP asks for data that the standards define. A company that has built a GHG Protocol-conformant inventory, with a documented consolidation approach, a base year and recalculation policy, and location-based and market-based Scope 2 figures, has the raw material for a CDP response. A company that has not will struggle, because the questionnaire asks for the same underlying facts.
GRI makes the connection explicit through its linkage documents. Two are listed on GRI's global alignment page:
- GRI 102 and 103 to CDP Mapping - Climate Change and Energy, dated 21 October 2025. This is the current one, and it is aligned to the new GRI climate and energy standards rather than the old GRI 305 and 302.
- Linking GRI and CDP: Water and Effluents, dated 1 September 2018. This one is badly out of date and should be treated as historical context rather than as working guidance.
As with every mapping, check the date before relying on it.
On CDP and the ISSB Standards
This is the point where honesty is more useful than completeness. It is widely stated that CDP has aligned its disclosure system with the ISSB Standards. The research behind this hub does not include a primary CDP source establishing the nature or extent of that alignment, and rather than repeat a claim it cannot evidence, this page does not assert it.
What can be said from verified sources:
- GRI maps its climate and energy standards to CDP's climate change and energy questions, in a document dated October 2025.
- CDP was a peer reviewer of GRI 102: Climate Change 2025, which itself refers to the GHG Protocol Corporate Standard (2004) for measurement and uses the 15 Scope 3 categories from the 2011 Corporate Value Chain Standard.
- IFRS S2 requires measurement on the same GHG Protocol basis.
In other words, the frameworks converge on a common measurement layer, which is the practical foundation of any alignment between them. For the specifics of how CDP's current questionnaire maps to IFRS S1 and IFRS S2, go to CDP directly rather than to secondary summaries, including this one.
A practical note on following CDP
CDP's website is built as a client-side application, which means its news and insights listings do not serve readable content to simple automated fetchers, and its sitemap stamps the same timestamp across an entire section when that section is rebuilt. For anyone trying to monitor CDP announcements programmatically, that combination is a trap: an unchanged timestamp does not mean nothing has changed, and a changed one does not mean an article was edited. New-URL comparison is more reliable than timestamps.
Standards in this family
4 documents.
A platform through which companies disclose environmental data, usually in response to investor or customer requests, and through which that data is held and scored.
CDP collects environmental disclosures rather than writing accounting rules. That distinction governs how a company should approach it: the measurement questions are answered by the GHG Protocol and, where relevant, ISO 14064-1; CDP is where the answers are submitted.
Who asks, and why it matters. Requests reach companies through two main routes - institutional investors asking portfolio companies, and large customers asking suppliers. The supply-chain route is the one that most often catches Singapore companies outside the listed universe, and it does not wait for regulatory phase-ins.
Why the dataset carries weight. CDP responses are one of the largest bodies of evidence about what companies actually do in practice. GHG Protocol relied on exactly that when it argued for eliminating the equity share consolidation approach, citing that only 2 per cent of companies publicly disclosing emissions to CDP in 2023 chose that approach. Standard-setters use CDP data to test whether a proposed rule reflects reality.
CDP's role in standard-setting. It is a participant rather than an author. CDP was among the peer reviewers of GRI 102: Climate Change 2025, alongside SBTi and ISO, with GHG Protocol on the technical committee.
Practical advice. Treat a CDP response as an output of the inventory, not as a separate exercise. If answering it requires numbers you cannot trace to a documented method, a stated factor vintage and retained source data, that is a signal about the inventory rather than about the questionnaire - and the same gap will surface later under assurance.
Scope of this entry. The specific content, structure and scoring of CDP's current questionnaires are not documented in this hub's underlying sources and are not described here. Check cdp.net directly.
A linkage document published by GRI on 21 October 2025 mapping GRI 102: Climate Change 2025 and GRI 103: Energy 2025 to CDP's climate change and energy questions.
This is the current and most useful bridge between GRI reporting and a CDP response, and notably it is aligned to the new GRI climate and energy standards rather than the superseded GRI 305 and GRI 302.
Why the vintage matters. GRI 102 and GRI 103 were published on 26 June 2025 and take effect for reports published on or after 1 January 2027. A mapping dated October 2025 is therefore written against standards that are effective for the reporting cycle most companies are now preparing for, which is unusual - most linkage documents lag their subject matter.
What it helps with. A company reporting under GRI and responding to CDP is being asked for the same underlying facts twice, in different shapes. The mapping shows where each GRI disclosure lands in the CDP structure, which reduces the risk of two inconsistent answers going out from the same organisation in the same year - a genuine problem that surfaces when different teams own the two processes.
Where it sits. It is listed among the linkage documents on GRI's global alignment page, alongside mappings to the ISSB, ESRS, TNFD, SASB, TCFD, the UN Sustainable Development Goals, HKEX ESG, SEBI BRSR and others. Each carries a date, and reading the dates is the single most useful habit when using that page.
Singapore angle. For an SGX issuer reporting under GRI, preparing for IFRS S2 and responding to CDP, three mappings do most of the work: this one, the GRI 102 and IFRS S2 equivalence statement of June 2025, and the earlier January 2024 GHG interoperability document for reports still prepared under GRI 305.
A linkage document dated 1 September 2018 mapping GRI water disclosures to CDP's water questions. It is now badly out of date and should be treated as historical context.
This mapping is included here for one reason: so that nobody uses it without noticing how old it is.
The problem. It dates from September 2018. Since then GRI has restructured its Universal Standards (effective 1 January 2023), renumbered its climate, energy and biodiversity standards out of the legacy series, and published new standards that did not exist when the mapping was written. CDP's own questionnaires have moved on as well. A mapping of that vintage cannot be relied on as a working guide.
The general lesson. GRI's global alignment page lists every linkage document with its publication date, and the spread is wide - from June 2025 for the ISSB equivalence statement and October 2025 for the CDP climate mapping, back to July 2020 for HKEX ESG and September 2018 for this one. The dates are displayed precisely so that users can judge staleness. Treat any mapping more than a couple of years old as a starting point for thinking rather than as an authority for a disclosure decision.
Water in a Singapore context. Water is genuinely material for many Singapore operations, from manufacturing and semiconductor fabrication to food and beverage, and GRI 303: Water and Effluents 2018 remains the operative GRI topic standard for it. If a company needs to reconcile GRI water disclosures to a CDP water response today, the sensible approach is to work from the current GRI 303 text and the current CDP questionnaire rather than from a 2018 crosswalk.
CDP's alignment with the ISSB Standards is frequently asserted. This hub's underlying sources do not include a primary CDP source establishing its nature or extent, so no such claim is made here.
It is common to read that CDP has aligned its disclosure system with the ISSB Standards, or that responding to CDP satisfies IFRS S2. Neither claim is evidenced by the sources behind this hub, and rather than repeat them, this entry sets out what can and cannot be supported.
What is established.
- GRI publishes a mapping from GRI 102 and GRI 103 to CDP's climate change and energy questions, dated 21 October 2025.
- CDP was among the peer reviewers of GRI 102: Climate Change 2025.
- GRI 102 refers to the GHG Protocol Corporate Standard (2004) for measurement and uses the 15 Scope 3 categories from the 2011 Corporate Value Chain Standard.
- IFRS S2 requires measurement on the same GHG Protocol basis, subject to the jurisdictional reliefs in paragraphs 29(a)(ii) and B24.
- GHG Protocol has used CDP disclosure data as evidence in its own standard revision work.
What follows from that. The frameworks share a measurement layer. A company that has built a GHG Protocol-conformant inventory has the substrate for an IFRS S2 disclosure, a GRI content index and a CDP response. That common substrate is the real basis of interoperability, and it is more durable than any particular questionnaire alignment.
What does not follow. It does not follow that a CDP response discharges an SGX or ACRA obligation. Singapore's requirement is to apply IFRS S2 and the climate-relevant provisions of IFRS S1 under Practice Note 7.6, on the phased timetable, and CDP is not among the frameworks Practice Note 7.6 names.
How to resolve the question. Go to CDP for its current statement of how its questionnaire relates to IFRS S1 and IFRS S2, and to the IFRS Foundation for any statement on its side. Where two organisations describe their relationship, read both descriptions - that is the standing advice throughout this hub, and it applies here more than anywhere, because this is a claim we could not verify.