Most companies that score D or C on CDP are not lacking data - they are making avoidable mistakes in how they prepare, structure, and submit their responses. Over 20,000 companies now disclose through CDP, backed by more than $130 trillion in investor assets. The difference between a D and a B score is almost always process, not substance. This article breaks down the 8 most common CDP disclosure mistakes and gives you a clear path to fix each one.
CDP's scoring system is publicly documented. The CDP scoring methodology is published every year and is freely available. Yet most companies that score poorly have never read it. They respond to the questionnaire in good faith, submit their data, and are genuinely surprised when they receive a C or D. Understanding where the points come from - and where they are lost - is the first step to improvement.
If you want a full breakdown of the scoring system before reading this, see our CDP Scoring Guide for Indian Companies.
Why Your CDP Score Matters More Than Ever
Before we get to the mistakes, it is worth understanding the stakes. CDP is not a compliance checkbox. Your score is visible to:
- Investors. Over 740 institutional investors with combined assets exceeding $130 trillion use CDP data to assess climate risk in their portfolios. A low score signals poor climate governance.
- Procurement teams. Global corporations increasingly require CDP disclosure from suppliers. A D or F score can cost you contracts.
- ESG rating agencies. MSCI, Sustainalytics, and S&P Global pull CDP data directly into their rating models. A better CDP score lifts your overall ESG rating.
- Regulators. As climate disclosure regulation tightens globally - including in India with BRSR Core - CDP responses serve as evidence of climate risk management maturity.
In 2023, over 23,000 companies representing more than half of global market capitalization disclosed through CDP. Only 346 companies (roughly 2%) achieved A-list status. The vast majority scored C or below - largely due to the avoidable mistakes described in this article.
The 8 Most Common CDP Disclosure Mistakes
1 Starting Too Late
The CDP questionnaire typically opens in April and closes in late July - a window of roughly 16 weeks. Companies that wait until June or July to begin are setting themselves up for a weak response. The questionnaire is long, data collection from multiple departments takes time, and narrative questions require review and sign-off from senior leadership.
The best-performing companies begin preparation in January or February - well before the questionnaire opens. They use the time to review prior-year scoring feedback, update their emissions inventory, document governance actions, and align internal stakeholders. By April, they are filling in answers rather than scrambling to find data.
January-March: Preparation - review scoring feedback, update data, assign owners per section.
April: Questionnaire opens - begin drafting responses immediately.
May-June: Data verification, narrative drafting, internal review.
Late July: Submission deadline. Late or missing submissions receive F.
November: Scores released. Review feedback and begin planning for next cycle.
2 Treating It as a Data Dump
CDP is not just a data collection exercise. Companies that fill in their emissions numbers and leave narrative fields blank - or with one-line answers - score significantly lower than companies that provide context, strategy, and evidence alongside their data.
CDP is explicitly evaluating whether your company understands its environmental impact and is taking strategic action in response. A number without explanation is worth less than a number with a clear description of methodology, limitations, year-on-year trends, and what the company is doing about it.
For every data point you submit, ask: does this response show that we understand the issue and have a plan? If the answer is no, add narrative. Attach supporting documents - board minutes, policy documents, target records, methodology notes. CDP rewards evidence over assertion at every scoring level.
3 Ignoring Scope 3 Emissions
This is one of the costliest mistakes a company can make in CDP disclosure. Many companies report Scope 1 and Scope 2 emissions and skip Scope 3 entirely, believing it is optional. It is not - at least not if you want to score above C.
CDP's scoring methodology penalizes companies that do not engage with Scope 3 at all. At the Awareness level, CDP asks companies to identify emissions across their value chain. At the Management and Leadership levels, Scope 3 reporting is effectively required for competitive scoring. Skipping it caps your maximum achievable score.
You do not need to report all 15 Scope 3 categories perfectly from day one. CDP accepts partial Scope 3 disclosure as long as you explain which categories are most material to your business and why you have prioritized them. Start with the categories most relevant to your sector - typically purchased goods and services (Category 1) for most Indian manufacturers, and use of sold products (Category 11) for energy or automotive companies.
"Scope 3 emissions represent on average more than 70% of a company's total carbon footprint. Ignoring them is not a disclosure gap - it is a strategic blind spot." - CDP Global, 2024 Insights Report
4 No Board-Level Governance Documentation
CDP scores governance heavily across all levels. At Awareness (C), companies must demonstrate that the board or senior management has oversight of climate-related issues. At Management (B) and Leadership (A), CDP requires evidence of board-level competence, climate metrics tied to executive incentives, and governance structures that integrate climate into strategic decisions.
The mistake is not that companies lack governance - most do have some form of board oversight. The mistake is failing to document it. Saying "the board oversees our environmental policy" scores poorly. Saying "the Board Risk Committee reviews our climate risk register quarterly, and 15% of the CFO's annual bonus is tied to emissions reduction targets" - and attaching the relevant policy document and board minutes - scores significantly higher.
Before submitting, ensure you can answer these questions with evidence:
- Which individual or committee at board level has responsibility for climate?
- How often does the board review climate-related performance?
- Are any executive compensation metrics tied to climate or emissions targets?
- What climate-related decisions has the board made in the past year?
5 Missing Third-Party Verification
Companies that submit self-reported emissions data without any form of external verification are leaving points on the table. CDP explicitly asks whether your emissions data has been verified by a third party, what level of assurance was obtained (limited or reasonable), and by whom.
Third-party verification - even limited assurance on Scope 1 and Scope 2 alone - signals data quality and credibility to both CDP and the investors and customers reading your response. At the Leadership level, verification is effectively required. But it also helps at the Management level because it demonstrates that your numbers can be trusted.
If full verification feels out of reach, start with limited assurance on your primary emissions data. This is less expensive than reasonable assurance and still makes a meaningful difference to your CDP score. Pair it with a clear description of your emissions calculation methodology and the standards you used (GHG Protocol, ISO 14064, etc.).
6 Not Setting Science-Based Targets
Many companies set reduction targets - but vague or internally defined targets score far less than Science Based Targets initiative (SBTi) validated commitments. CDP's scoring methodology gives highest marks to companies with SBTi-approved near-term and long-term targets aligned with 1.5C or well-below 2C pathways.
The difference in scoring between "we aim to reduce emissions 20% by 2030" and "we have SBTi-validated near-term targets aligned with a 1.5C pathway" is substantial. SBTi validation also brings additional credibility: it signals that an independent body has reviewed your target and confirmed it is consistent with the science.
If you have not yet committed to SBTi, at minimum set specific, quantified, time-bound targets with a clearly stated baseline year. "Reduce absolute Scope 1 and 2 emissions 42% by 2030 from a 2022 base year" scores far better than a vague aspiration. Then use the next disclosure cycle to formalize through SBTi.
CDP's scoring methodology explicitly rewards SBTi alignment. Companies with SBTi-validated targets consistently score higher in the "targets" module than those with equivalent but non-validated targets. SBTi commitment letters (submitted but not yet approved) also provide some benefit - begin the process early.
7 Copy-Pasting the Previous Year's Response
CDP updates its questionnaire every year - adding new questions, refining existing ones, adjusting scoring weights, and occasionally retiring questions that are no longer relevant. Companies that simply re-submit last year's response without reviewing the updated guidance miss new high-value questions entirely, and their answers to changed questions may no longer be responsive.
CDP also flags responses where narrative text is clearly stale - unchanged from the prior year despite new context. This signals low-quality engagement and is treated accordingly in scoring. Reviewers look for year-on-year progression: updated emissions figures, new initiatives, progress against targets, and responses to scoring feedback from the previous cycle.
The right approach is to use last year's response as a starting point - not a finished product. Read the updated questionnaire guidance documents (freely available on cdp.net), check which questions have changed, review your prior-year scoring feedback, and update every section with current data and new developments.
8 Not Using CDP's Own Guidance Documents
This is perhaps the most ironic mistake on this list. CDP publishes comprehensive, free guidance documents for every questionnaire it runs. These include the scoring methodology, question-by-question guidance, sector-specific notes, and examples of high-scoring responses. Yet the majority of companies that score poorly have never read them.
The CDP guidance documents are specific about what each question is looking for, what evidence is expected, and how responses are scored. Reading the scoring methodology before you begin - not after you receive your score - changes how you approach every section of the questionnaire.
Make it a rule: before answering any question, read the CDP guidance for that question. For high-stakes sections (governance, targets, verification), read the scoring rubric and ensure your answer addresses every criterion. This alone can add several points across the questionnaire.
How to Go from D/C to B/A: A Practical Path
Improvement is systematic, not random. The table below maps where most companies sit and what they need to do to reach the next level.
| Current Score | Primary Gap | Key Actions to Move Up | Realistic Timeline |
|---|---|---|---|
| F / No response | Not disclosing at all | Submit any response - even an incomplete one. Register on the CDP Online Response System and answer as many questions as possible. | This cycle |
| D / D- | Incomplete responses, missing data | Answer every question. Report Scope 1 and 2 using GHG Protocol. Name board responsible for climate. Identify at least one risk and one opportunity. | 1 cycle |
| C / C- | No targets, thin governance evidence, no Scope 3 | Set quantified emissions reduction targets. Document governance with evidence. Begin Scope 3 for material categories. Conduct a basic climate risk assessment. | 1-2 cycles |
| B / B- | No SBTi, no verification, limited Scope 3 | Commit to and validate SBTi targets. Obtain third-party verification on Scope 1-2. Expand Scope 3 reporting. Link executive pay to climate metrics. | 1-2 cycles |
A realistic path from D to B is two to three disclosure cycles for most companies - provided they use CDP's scoring feedback each year to guide improvements. Companies that jump straight from D to B in one cycle typically have a sustainability team that has done significant behind-the-scenes work before their first submission.
For detailed support, our CDP disclosure service covers everything from questionnaire preparation to score improvement strategy. You can also explore the O₂log glossary for definitions of CDP-specific terms.
Frequently Asked Questions
The most common reason is incomplete responses - leaving questions blank or unanswered. CDP's disclosure level scoring is primarily a completeness check. Even if your data is imperfect, providing an answer with a note explaining limitations scores better than leaving a field empty. The second most common cause is starting too late and rushing through narrative questions with generic text.
Yes. While Scope 3 is not required to achieve a D or C score, ignoring it entirely caps your maximum achievable score at B. CDP explicitly requires Scope 3 disclosure - at minimum the most material upstream and downstream categories - to qualify for Leadership level scoring. Companies that skip Scope 3 entirely also lose points in the Awareness section where CDP asks about value chain emissions.
Third-party verification has a significant positive impact, particularly at the Management and Leadership levels. CDP explicitly awards higher scores to companies that have had their emissions data verified by an accredited external body. Even limited assurance on Scope 1 and Scope 2 data - rather than full reasonable assurance - makes a meaningful difference. Companies seeking an A score almost always have at minimum limited assurance on their primary emissions data.
You can use last year's response as a starting point, but you should never submit it unchanged. CDP updates its questionnaire every year - adding new questions, changing question wording, and adjusting scoring weights. Submitting stale responses means you will miss new high-value questions entirely, and CDP flags responses where narrative text has not been updated as evidence of low-quality engagement. Always review the updated guidance documents and scoring methodology before each cycle.
The fastest path from C to B is to set a specific, quantified emissions reduction target with a baseline year and submission date, then document your climate governance more thoroughly. Many companies sitting at C already have informal targets and some governance - the gap is documentation and evidence. Attach board minutes, policy documents, and target records. Also ensure you have at minimum basic Scope 3 reporting for your most material categories. These three steps - targets, governance evidence, and Scope 3 - move most C-band companies to B within one cycle.
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Our team helps Indian companies identify exactly where they are losing CDP points and build a response strategy to move up the scoring bands. See our CDP disclosure services or get in touch directly.
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