Key takeaway
A great CDP response is a project, not a document. Companies that earn A-list scores treat the response as a 4-month cross-functional engagement with named roles, deadlines, sign-off authorities, and a project plan that runs parallel to other major reporting cycles. Companies that try to write the response in 2 weeks before the deadline get D-band results regardless of underlying performance. This lesson explains how to run the project, who needs to be involved, and the milestones that determine the outcome.
The four phases of a CDP response project
A typical Leadership-tier CDP project has four distinct phases over 4-5 months.
| Phase | Duration | Key activities | Output |
|---|---|---|---|
| 1. Scope and plan | 3-4 weeks (typically February-March) | Read the year's methodology; map last year's gaps; identify key changes; assemble team | Project charter, RACI, timeline |
| 2. Data and content | 8-10 weeks (April-May) | Collect data; verify emissions; draft answers module by module | First draft response with methodology disclosures |
| 3. Review and refine | 3-4 weeks (June) | Internal review; legal review; cross-module consistency check; sign-off | Final response ready for submission |
| 4. Submit and monitor | 1-2 weeks (early July) | Final review by leadership; sign-off; ORS submission; archive | Submitted response; project archive |
This pattern is typical for the July submission window (which CDP uses in most years). A company with a different cycle adjusts the timing accordingly.
Phase 1: Scope and plan
This is the phase most companies skip and most A-list companies invest in.
Activities:
- Read the current year's questionnaire and scoring methodology in detail
- Compare against your prior year response; note what changed
- Identify the questions where you scored at Disclosure or Awareness tier last year
- Plan upgrades for this cycle (focus on the highest-impact ones)
- Map data requirements to functional owners
- Set internal deadlines that work backward from the submission date
- Brief executive sponsors
Output: a project charter with RACI, timeline, and named upgrades.
The companies that take this seriously have a 30-page internal document by mid-March that lays out exactly what they will do. Companies that skip this phase write the response from a blank page in May.
Analogy
Phase 1 is like the architectural drawings before construction begins. A great house can be built from great drawings. A great house cannot be built from a vague vision. CDP responses work the same way: the structural plan determines what is possible, and that plan has to exist before the writing starts.
Phase 2: Data and content
This is the longest phase. Activities:
- Data collection. Pull emissions data from operations; energy data from utilities; supplier data from procurement; risk register from risk function; financial data from finance; HR data from people function; Board minutes from corporate secretary.
- Verification preparation. Engage with the verifier; provide data; respond to verifier queries.
- Drafting. Module by module, with named owners per module.
- Cross-checking. Numbers should reconcile across modules. Boundary should be consistent. Targets should be the same in Module 5 and Module 7.
The cross-functional discipline is critical. Common roles:
| Function | Responsible for |
|---|---|
| Sustainability lead (CSO or designate) | Overall response, Module 0-3, scoring strategy |
| Operations / EHS | Scope 1+2 data, energy data, verification interface, water data |
| Procurement / Supply Chain | Scope 3 data (especially Categories 1, 4, 11), supplier engagement, commodity disclosure |
| Finance | Internal carbon pricing, cost-of-capital, M&A diligence, financial planning integration |
| Risk function | Risk register, IRO process, scenario analysis |
| HR / People | Compensation alignment, training programmes, board diversity |
| Corporate Secretary / Legal | Board oversight documentation, sign-off process, disclosure consistency with regulatory filings |
| Communications / IR | Public statements, sustainability report alignment, investor disclosure |
The sustainability lead coordinates. Each functional contributor owns specific questions and provides data with documentation.
Phase 3: Review and refine
Three review passes happen in this phase:
Internal review by the sustainability team. Reading the full response front to end. Cross-checking. Cleaning up inconsistencies.
Legal review. Particularly for sensitive disclosures (lobbying, sector classifications, financial impact figures). Legal flags anything that could create disclosure risk in regulatory filings or litigation.
Executive review. The CEO, CFO, CSO, and risk function read the full response. They challenge assumptions, ask questions, and approve the final draft.
For larger companies, board sustainability committee review is also part of this phase. Some questions explicitly require board sign-off, and the board's review provides documentation for those.
Phase 4: Submit and monitor
The final review and submission is structured but lower-effort than the prior phases.
Activities:
- Final readthrough by sustainability lead
- Sign-off collection (CEO or CFO depending on company governance, often both)
- Upload final response to ORS
- Archive a complete copy locally (PDF export plus Word documents and supporting evidence)
- Brief internal stakeholders that submission has happened
- Plan investor and customer communications around the submission
After submission, the team enters a quiet phase. The next cycle's planning starts in late September or October when the prior year's scorer feedback report arrives.
Common pitfalls in the project
- Starting too late. Beginning in May for a July submission means rushed data, missed verification windows, no executive review.
- No project plan. Treating CDP as a series of writing tasks rather than a project with milestones.
- Single-person ownership. When the sustainability lead is the only person who knows what is happening, capacity becomes the bottleneck.
- Skipping phase 1. Going straight to drafting without a strategic plan; result is a response that addresses last year's gaps but misses this year's new questions.
- Skipping legal review. Particularly risky for lobbying and policy disclosures; can create regulatory exposure.
- Not archiving evidence. When CDP scoring partners ask follow-up questions in autumn, the team often cannot find the source data.
Worked example: a project plan from a real-style schedule
Worked example
InfraCorp India (synthetic). 2026 cycle project plan.
February 2026, Week 1:
- Sustainability lead reads CDP 2026 methodology (3 days)
- Project charter drafted, RACI designed
- Executive sponsorship confirmed (CFO)
February 2026, Weeks 2-3:
- Cross-functional kickoff meeting
- Module ownership assigned
- Data requirements compiled
- Verifier engagement initiated (Bureau Veritas India for emissions verification)
March 2026:
- Internal data collection (energy, water, fuel)
- Supplier engagement programme metrics compiled
- Risk register reviewed and updated by risk function
- Materiality assessment refresh
April 2026, Weeks 1-2:
- ORS opens; access confirmed
- First-draft data uploads to ORS for early modules
- Verifier site visits begin
April-May 2026:
- Module-by-module drafting in shared documents
- Cross-checking across modules
- Verification statement received (mid-May)
June 2026, Weeks 1-2:
- Internal review by sustainability team
- Legal review (focus: lobbying, sector classification, M&A diligence claims)
- Executive review with CFO and CSO
- Board sustainability committee briefing
June 2026, Weeks 3-4:
- Final draft to ORS
- Stakeholder communications drafted
- Sign-off collection
Early July 2026:
- Final review by CEO and CFO
- Submission to ORS
- Archive copy created and stored locally
- Internal communications sent
Total project time: approximately 5 months from kickoff to submission.
This level of project discipline is what separates A-list responders from B-band ones. The work is the same; the structure makes it work.
Many companies use external sustainability advisors (CDP Accredited Solutions Providers, Big Four sustainability practices, specialty firms) to support the response. The advisor typically provides: methodology guidance, drafting support, technical content (especially for scenario analysis and verification), and review. Cost: typically USD 50,000-300,000 depending on scope. The trade-off: advisors can lift quality but should not write the response in isolation. The best results come from advisors as collaborators with the internal team, not as ghost writers.
Key Takeaways
- A CDP response is a 4-5 month cross-functional project, not a 2-week writing task; the project plan determines the outcome
- Phase 1 (scope and plan) is the most-skipped and highest-leverage phase; companies that invest 3-4 weeks in February-March consistently score better
- Phase 2 requires named functional owners across operations, procurement, finance, risk, HR, and legal; the sustainability lead coordinates
- Phase 3 review needs internal, legal, and executive passes; for larger companies, board sustainability committee review is also needed
- External advisors can lift quality if used as collaborators with the internal team; ghost-written responses are easily detected by graders
Knowledge Check
Test what you just learned
6 questions · check each one as you go
How long does a Leadership-tier CDP response project typically run?
Which is the most-skipped and highest-leverage phase?
True or false: A great CDP response is best handled by a single sustainability lead working alone.
Which functions should be involved in Phase 2 (data and content)?
Select all that apply
What does the typical Phase 3 (review) include?
Match each phase to its primary output.
Match each item to its pair
Phase 1 (Scope and plan)
Phase 2 (Data and content)
Phase 3 (Review and refine)
Phase 4 (Submit and monitor)