CDP & ESRS Alignment Comparison: Climate Transition Plans
/Enhanced CDP and ESRS Interoperability = More Efficient Reporting
If you’ve been wondering how seamless the transition will be for companies currently disclosing environmental information to CDP to comply with the European Sustainability Reporting Standards (ESRS), CDP and EFRAG are set to provide more insights into this in 2025.
At COP29, EFRAG and CDP announced a significant alignment between CDP’s disclosure platform and the European Standards, specifically the ESRS E1 climate standard. The ESRS E1 standard, which is part of the broader framework under the EU’s Corporate Sustainability Reporting Directive (CSRD), focuses on climate-related disclosures. It guides companies in reporting information on their climate impact, greenhouse gas emissions, and climate-related risks and opportunities.
This interoperability, which results from joint mapping efforts, will be further detailed in a comprehensive guide expected early next year (Spring 2025) in preparation for the 2025 CDP disclosure cycle. By supporting the goals of the CSRD, this collaboration aims to ease the reporting burden for companies, with CDP acting as a key partner for ESRS adoption.
Sherry Madera, CEO of CDP, highlighted the importance of making environmental disclosure more efficient and valuable through the 'write once, use many' philosophy. She noted, “By collaborating closely with standard setters like EFRAG, we're working towards a more efficient global environmental disclosure ecosystem that benefits both reporting organizations and data users alike.”
Mapping Guidance for Companies
Looking ahead, CDP and EFRAG plan to further enhance the alignment of CDP’s questionnaire with ESRS E1 by publishing mapping guidance for the 2025 cycle and conducting market research to refine the alignment based on disclosers’ and data users’ feedback.
This mapping guidance will help organizations understand how the CDP questionnaire aligns with ESRS requirements, particularly ESRS E1. Although the ESRS E1-specific mapping document has not yet been released, it is expected to provide a detailed alignment of CDP questions to corresponding ESRS E1 data points, enabling companies to address both voluntary and mandatory reporting obligations where overlaps exist.
While the CDP questionnaire shares significant commonalities with ESRS E1, it should not be considered as fully satisfying all ESRS E1 requirements. Additional steps may be needed to ensure complete compliance. Therefore, we systematically compared the CDP questionnaire with ESRS E1, focusing specifically on Climate Transition Planning.
Climate Transition Planning
One area of strong alignment between CDP and ESRS E1 is the focus on Climate Transition Plans, which require organizations to disclose their strategic approach to transitioning to a low-carbon economy. According to CDP’s definition, a credible transition plan contains relevant information on how the organization plans to achieve its strategy of pivoting existing operations, assets, and the entire business model toward a trajectory aligned with the latest and most ambitious climate science recommendations.
ESRS E1: Mandates that companies outline clear, time-bound transition plans aligned with global climate goals, such as the Paris Agreement. These plans must address how the organization will reduce greenhouse gas emissions across its operations and value chain, integrate renewable energy, and implement low-carbon technologies.
CDP: Similarly, CDP aims to ensure that organizations disclose credible, actionable, and measurable climate transition plans that reflect their long-term commitment to reducing environmental impacts, aligning with global climate goals, and aligning business models with decarbonization pathways.
How do CDP and ESRS E1 align on transition plans?
The tables below compare the ESRS E1 requirements for Climate Transition Plans with the CDP questionnaire, highlighting their alignment and the extent of their shared focus on key aspects of transition plans. The tables detail the alignment on the following topics:
Full Alignment
GHG Reduction Targets
Decarbonization Levels and Key Actions
Investments and Funding
Sustainable Finance Taxonomy
Link to Business Strategy & Financial Planning
Feedback Mechanisms
Explanation of Progress
Date of Adoption of Transition Plan
Partial Alignment
Locked-in GHG Emissions
Fossil Fuel-related Investments
EU Paris-aligned Benchmarks
For reference, CDP questions from the 2024 questionnaire that specifically mention ‘Climate Transition Plans’ are:
5.2 – “Does your organization’s strategy include a climate transition plan?”
5.4 – “In your organization’s financial accounting, do you identify spending/revenue that is aligned with your organization’s climate transition?”
5.4.1 – “Quantify the amount and percentage share of your spending/revenue that is aligned with your organization’s climate transition.”
However, there are many other CDP questions (as detailed in the tables below) that are directly related to an organization's Climate Transition Plan. For example, these questions include financial planning elements of the transition and the climate-related targets that a company is setting or implementing.
In addition, there are other CDP questions (not included in the tables below) that also support transition planning. These include aspects such as emissions accounting, verification, climate scenario analysis, and value chain engagement on climate-related issues. While these questions are not tightly aligned with the core components of a Climate Transition Plan, they play a role in supporting its overall credibility.
GHG Reduction: Full Alignment | |||
|---|---|---|---|
ESRS E1 |
CDP Question |
Alignment |
|
| E1-1 paragraph 16(a) | 5.2, 7.53.1, 7.53.2, 7.54.1 7.54.2, 7.54.3 | Both ESRS E1-1 and CDP focus on aligning targets with a 1.5°C trajectory while ensuring measurable progress to enhance credibility. | |
Details | |||
|
ESRS E1 Requirement: Requires explanation of how GHG targets are compatible with the limiting of global warming to 1.5°C in line with the Paris Agreement. CDP Questionnaire: CDP question 5.2 asks if the company's climate transition plan is aligned with 1.5°C world or a different temperature alignment. CDP’s target questions (7.53.1, 7.53.2, & 7.54.1, 7.54.2, 7.54.3) request detailed information about emission reduction targets, including their scope, baseline, progress, and alignment with science-based pathways. | |||
Decarbonization Levels and Key Actions: Full Alignment | |||
|---|---|---|---|
ESRS E1 |
CDP Question |
Alignment |
|
| E1-1 paragraph 16(b) | 5.2 | Both ESRS E1-1 and CDP emphasize actionable steps to reduce emissions, focusing on technologies, product/service changes, and value chain activities. | |
Details | |||
|
ESRS E1 Requirement: Requires disclosure of decarbonization levers (e.g., new technologies, product/service changes) and key actions planned, including changes in the undertaking’s product and service portfolio and the adoption of new technologies in its own operations, or in the upstream and/or downstream value chain. CDP Questionnaire: Companies are asked to detail the activities in their transition plan, including decarbonization strategies and actions needed to meet the plan's goals. This includes changes within their operations, value chain, products, services, business models, and engagement efforts. | |||
Investments and Funding: Full Alignment | |||
|---|---|---|---|
ESRS E1 |
CDP Question |
Alignment |
|
| E1-1 paragraph 16(c) | 5.4, 5.4.1, 5.4.2, 5.3.2 | Both ESRS E1-1 and CDP require detailed financial disclosures and emphasize sustainable finance mechanisms. | |
Details | |||
|
ESRS E1 Requirement: Requires an explanation and quantification of the undertaking’s investments and funding supporting the implementation of its transition plan, with a reference to the key performance indicators (KPIs) of taxonomy-aligned CapEx, and where relevant the CapEx plans, that the undertaking discloses in accordance with Commission Delegated Regulation (EU) 2021/2178. CDP Questionnaire: Questions 5.4, 5.4.1, and 5.4.2 explore the financial aspects of a company's climate transition, asking if its spending or revenue supports its transition goals (5.4), how well aligned its spending/revenue is with those goals (5.4.1), and how much is tied to sustainable activities under recognized taxonomies like the EU Taxonomy (5.4.2). Additionally, question 5.3.2 examines how environmental issues have influenced the company's financial planning, including developing a transition plan. | |||
Sustainable Finance Taxonomy: Full Alignment | |||
|---|---|---|---|
ESRS E1 |
CDP Question |
Alignment |
|
| E1-1 paragraph 16(e) | 5.4.2 | Both ESRS E1-1 and CDP promote alignment with recognized standards to ensure transparency and accountability in financial activities supporting the transition. | |
Details | |||
|
ESRS E1 Requirement: For undertakings with economic activities that are covered by delegated regulations on climate adaptation or mitigation under the Taxonomy Regulation, an explanation of any objective or plans (CapEx, CapEx plans, OpEx) that the undertaking has for aligning its economic activities (revenues, CapEx, OpEx) with the criteria established in Commission Delegated Regulation 2021/2139. CDP Questionnaire: Requests quantification of spending/revenue linked to eligible and aligned activities under a recognized sustainable finance taxonomy, such as the EU Taxonomy Regulation. | |||
Link to Business Strategy & Financial Planning: Full Alignment | |||
|---|---|---|---|
ESRS E1 |
CDP Question |
Alignment |
|
| E1-1 paragraph 16(h) | 5.2 | Both ESRS E1-1 and CDP emphasize the integration of climate transition planning into an organization’s overall business strategy and financial planning. | |
Details | |||
|
ESRS E1 Requirement: Requires an explanation of how the transition plan is embedded in and aligned with the undertaking’s overall business strategy and financial planning. CDP Questionnaire: Question 5.2 outlines the essential elements of a credible climate transition plan, including its integration with overall business strategy and financial planning, alignment with a 1.5°C trajectory, support from credible science-based targets, incorporation of a well-defined feedback mechanism, and inclusion of verifiable and quantifiable KPIs. | |||
Feedback Mechanisms: Full Alignment | |||
|---|---|---|---|
ESRS E1 |
CDP Question |
Alignment |
|
| E1-1 paragraph 16(i) | 5.2, 4.1.2, 4.3.1 | Both ESRS E1-1 and CDP request transparency in disclosing whether the plan has been either overseen or there is a feedback mechanism in place. | |
Details | |||
|
ESRS E1 Requirement: Requires disclosure of whether the transition plan is approved by the administrative, management, and supervisory bodies. CDP Questionnaire: CDP question 5.2 focuses on feedback mechanisms to track the plan's progress, while question 4.1.2 highlights the board's role in approving climate transition strategies, and question 4.3.1 highlights the executive management’s responsibility for developing a climate transition plan. | |||
Explanation of Progress: Full Alignment | |||
|---|---|---|---|
ESRS E1 |
CDP Question |
Alignment |
|
| E1-1 paragraph 16(j) | 5.2 | Both ESRS E1-1 and CDP request transparency on tracking and reporting progress on climate transition plans. | |
Details | |||
|
ESRS E1 Requirement: Requires explanation of progress in implementing climate transition plan. CDP Questionnaire: Asks for description of progress against transition plan disclosed in current or previous reporting year. | |||
Date of Adoption of Transition Plan: Full Alignment | |||
|---|---|---|---|
ESRS E1 |
CDP Question |
Alignment |
|
| E1-1 paragraph 17 | 5.2 | If a company doesn't have a transition plan in place but intends to develop one, both ESRS E1-1 and CDP request that the company provide a timeline. | |
Details | |||
|
ESRS E1 Requirement: In case the undertaking does not have a transition plan in place, it requires indication of whether and, if so, when it will adopt a transition plan. CDP Questionnaire: CDP question 5.2 provides explicit options for organizations to disclose whether they have a transition plan, are planning to develop one within the next 2 years or do not plan to develop one within the next two years. | |||
Locked-in GHG Emissions: Partial Alignment | |||
|---|---|---|---|
ESRS E1 |
CDP Question |
Alignment |
|
| E1-1 paragraph 16(d) | 5.2, 3.1.1 | The ESRS E1-1 requirement emphasizes qualitative assessments and specific management plans for locked-in emissions, including the risks they pose. CDP does not explicitly call for qualitative assessments of locked-in GHG emissions but expects companies to demonstrate how their transition strategies address climate risks and dependencies. | |
Details | |||
|
ESRS E1 Requirement: Requires a qualitative assessment of the potential locked-in GHG emissions from the undertaking’s key assets and products. This shall include an explanation of if and how these emissions may jeopardize the achievement of the undertaking’s GHG emission reduction targets and drive transition risk, and if applicable, an explanation of the undertaking’s plans to manage its GHG-intensive and energy-intensive assets and products. CDP Questionnaire: Question 5.2 asks whether the company’s strategy includes a climate transition plan, which CDP expects to be based on a thorough assessment of climate-related risks and opportunities impacting the company. CDP question 3.1.1 seeks detailed information on climate-related risks, their potential financial impact, and the company’s strategies to manage these risks. | |||
Fossil Fuel-related Investments: Partial Alignment | |||
|---|---|---|---|
ESRS E1 |
CDP Question |
Alignment |
|
| E1-1 paragraph 16(f) | 5.2 | Both ESRS E1-1 and CDP request transparency about fossil fuel-related activities. However, ESRS E1-1 emphasizes disclosure of financial activities, while CDP emphasizes a commitment to cease those activities. | |
Details | |||
|
ESRS E1 Requirement: If applicable, it requires disclosure of significant CapEx amounts invested related to coal, oil, and gas-related economic activities. CDP Questionnaire: Asks if the climate transition plan commits to ceasing spending/revenue generation from activities contributing to fossil fuel expansion. | |||
EU Paris-aligned Benchmarks: Partial Alignment | |||
|---|---|---|---|
ESRS E1 |
CDP Question |
Alignment |
|
| E1-1 paragraph 16(g) | 5.2 | Partial alignment as CDP questionnaire does not explicitly request companies to disclose whether they are excluded from the EU Paris-aligned benchmarks. | |
Details | |||
|
ESRS E1 Requirement: Requires disclosure of whether the undertaking is excluded from the EU Paris-aligned benchmarks. CDP Questionnaire: Question 5.2 asks whether the company’s strategy includes a 1.5°C-aligned climate transition plan demonstrating alignment with the Paris Agreement's objectives. | |||
As the ESG reporting landscape evolves, KERAMIDA’s expertise will empower clients to navigate CDP’s questionnaire with ease and leverage the interoperability between CDP and ESRS E1. As a CDP Gold Accredited Provider, KERAMIDA will continue to closely follow updates from CDP and EFRAG, ensuring clients stay informed and aligned with the latest reporting standards.
For information on how we can assist your organization, contact us or call (800) 508-8034 to speak with one of our reporting experts today.
Author
Anastasia Kyrmanidou, Ph.D.
Senior Sustainability Analyst
GRI Certified Sustainability Professional
KERAMIDA Inc.
Contact Anastasia at akyrmanidou@keramida.com
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