CDP 2026 Disclosure Response: An Australian...

The CDP 2026 submission window opens the week of 15 June, with the scored deadline the week of 14 September and a non-scored deadline the week of 26 October (CDP Disclosure 2026). For Australian reporters, that timing matters more than it used to.

This is the first CDP cycle where Group 1 entities have a published AASB S2 statement sitting next to their CDP response in public view. The NGER submission for the year just gone lands on 31 October, slap in the middle of the same window. Three disclosures, three audiences, one set of numbers underneath. Inconsistency between them is the first thing an investor or a regulator will see.

So this guide is not a CDP 101. It is a response framework for Australian companies who need the CDP numbers to reconcile to a regulated disclosure.

Two audiences: direct discloser vs supply chain respondent

The CDP response you write depends on why you got the questionnaire.

Direct disclosure is the version most Australian listed entities know. The questionnaire arrives via an investor request (CDP works for 700+ financial institutions managing roughly $142 trillion in assets). The response is public, it is scored, and it sits on the CDP scores page where anyone can read it.

Supply chain disclosure is the one catching mid-market companies off guard. A customer with a CDP Supply Chain program (CDP Supply Chain) sends the request. Major Australian buyers run these programs across construction, retail, banking and resources. Your response is visible to that customer, scored separately, and the data flows into their Scope 3 Category 1 calculation. The number you give them appears in their public disclosure with their name on it.

If your CDP request is supply chain, you are writing for a customer's auditor, not the public. But your number becomes their number, so the data quality bar is the same.

The 2026 questionnaire is one integrated document, not three

CDP changed structure in 2025 and the integrated questionnaire carries into 2026 (CDP Full Corporate Scoring Methodology 2025). The old separate climate, forests and water questionnaires are now one corporate questionnaire with 13 modules. Modules 1 through 6 are integrated topics (governance, strategy, risks and opportunities, environmental policy, business strategy, emissions methodology). Modules 7 through 11 cover specific environmental areas. Modules 12 and 13 are signoff and additional information.

The 2026 cycle adds an Oceans module and expands forests scope to include cocoa, coffee and rubber alongside cattle, soy, palm oil and timber (CDP 2026 questionnaire changes). Scoring still focuses on climate change, forests and water security.

For Australian reporters working from an AASB S2 statement, the structural overlap is direct. Module 1 governance maps to the governance section of your AASB S2 disclosure. Module 2 strategy maps to your strategy disclosures including scenario analysis. Modules covering Scope 1, 2 and 3 emissions feed from the same underlying data set as your AASB S2 metrics. Targets and transition plan disclosures sit in their own modules and have to reconcile to whatever you published under AASB S2 paragraphs 33 to 36.

The AASB S2 reconciliation problem

This is the part most response teams underestimate.

ASIC has signalled it will read sustainability disclosures as a connected set, not as separate documents (ASIC Regulatory Guide 280). A CDP response that quotes a different Scope 1 number from the AASB S2 statement, or a different boundary description, or a different methodology reference, gives a regulator a reason to look harder. The same applies to a customer's auditor reading a CDP Supply Chain response against the supplier's own annual reporting.

Three things have to match exactly across the AASB S2 statement, the CDP response and (where relevant) the NGER submission:

The absolute Scope 1 and Scope 2 numbers for the reporting period, including restated comparatives if you have any
The methodology references: GHG Protocol Corporate Standard, NGA Factors edition, AR5 or AR6 GWP values for the relevant gases, location-based or market-based for Scope 2
The organisational boundary description: what is in, what is out, what changed since last cycle

The wrinkle Australian reporters hit first is the GWP question. NGER uses AR5 global warming potential values; AASB S2 requires AR6 (AR5 vs AR6 GWP for NGER and AASB S2). CDP accepts either, but you have to disclose which. If your AASB S2 statement uses AR6, your CDP response must use AR6 (or explain the difference). Same goes for the Scope 2 method — if the AASB S2 disclosure presents both location-based and market-based numbers as required under paragraph 29(a)(v), so should CDP (Location-based vs market-based Scope 2 in Australia).

How scoring actually works

CDP's scoring is a four-tier progression: Disclosure (response is complete), Awareness (response shows the company recognises its environmental risks), Management (response shows processes and actions in place), Leadership (response demonstrates best practice). The final letter score runs A, A-, B, B-, C, C-, D, D-, with F for non-responders.

Each level has essential criteria. Miss one and you cannot score in that level, no matter how high your percentage points. A common Australian failure mode: a company hits the points threshold for Leadership on climate but has not had its Scope 1 and Scope 2 data third-party verified to the criteria required, so it caps at Management.

In 2024, only 2% of disclosing companies (515 out of 22,700+) achieved an A score (CDP A List 2024 release). Getting from C to B is largely a matter of completeness and consistency. Getting from B to A is about evidence of management action that an external assessor can verify.

The shortest practical path to a higher band is the one most Australian reporters skip: complete every essential criterion in the level below before chasing points in the level above.

Five questions Australian reporters consistently get wrong

These are the ones to draft early and review last.

Scope 3 boundary coverage. The questionnaire asks which of the 15 Scope 3 categories are relevant and which have been quantified. Most Australian responses underclaim. A "not relevant" answer for purchased goods and services or for use of sold products will be challenged. Better to claim relevant but disclose the quantification method honestly, including spend-based estimates flagged as such (Scope 3 categories explained, spend-based emissions accounting).

Scope 2 location-based vs market-based. AASB S2 paragraph 29(a)(v) requires location-based. Market-based is voluntary supplementary. CDP wants both where the company has any market-based instruments (PPAs, LGCs, GreenPower). Reporting only one when you have purchased renewables raises a scoring flag.

Carbon credit and offset disclosure. If the response claims carbon neutrality or progress toward a target using offsets, the questionnaire requires vintage, project type, registry, retirement evidence and the percentage of total emissions covered. Vague disclosure here is what the ACCC has flagged as greenwashing risk (ACCU carbon credits in Australia).

Internal carbon price. Claiming an ICP without methodology backing (shadow price vs implicit vs internal fee), price level, scope of application and how it informs investment decisions does not score. A flat "we use $50 per tonne" with no decision evidence is worth less than admitting you don't use one yet (internal carbon pricing).

Engagement with policymakers. Australian companies have to disclose direct and indirect (industry association) policy engagement on climate. Membership of an industry body that lobbies against climate policy, while the company publicly supports it, is the inconsistency most often picked apart by investors reading the response.

The supply chain disclosure question

If you are responding via the CDP Supply Chain program, the maths is different.

The customer asks for emissions attributable to their spend with you. The default allocation is revenue-based: your total Scope 1, 2 and relevant Scope 3 divided by total revenue, multiplied by their spend. Manufacturers often use mass-based allocation (per tonne shipped). Energy companies use physical allocation (per GJ supplied).

Whichever method you use, document it in the response. The customer's auditor will ask. And the number you provide flows into the customer's Scope 3 Category 1 disclosure, which is public under AASB S2. If your number is wrong, it is the customer's name on the greenwashing risk, not just yours (responding to customer sustainability questionnaires, how to collect Scope 3 data from suppliers).

The other thing to disclose carefully: your data quality. If the number is spend-based and uncertain to plus or minus 30%, say so. A customer's auditor would rather have an honest spend-based number with stated uncertainty than a precise-looking number with no methodology behind it.

What changes for second-year Group 1 and first-year Group 2 reporters

Group 1 entities are now in their second AASB S2 cycle. Year-on-year change in any CDP number that does not match the restated AASB S2 comparative creates a question. Restate the CDP prior-year if the AASB S2 prior-year was restated. The two have to move together.

Group 2 entities (financial years starting 1 July 2026) are drafting their first AASB S2 disclosure in parallel with this CDP response. The temptation is to use CDP as a low-stakes first draft of the climate disclosure. Do the opposite. The AASB S2 statement is the regulated document. Build it first, then feed the CDP response from the same source data (ASIC and AASB S2 enforcement surveillance, ASRS Group 2 lessons from month one).

For financial institutions, the PCAF-aligned financed emissions section of CDP is the one that has to reconcile to AASB S2 paragraph B58 disclosures. Asset-class-level emissions intensity that differs between the two documents will be questioned.

A practical eight-week timeline

Week	Focus
1	Confirm responder type. Pull AASB S2 source data. Lock the boundary description
2-3	Governance and strategy modules (1-3). Cross-check against AASB S2 governance and strategy sections
4-5	Emissions modules with methodology references. Verify Scope 1 and 2 reconcile to NGER and AASB S2
6	Targets and transition plan modules. Reconcile target language word-for-word to AASB S2 disclosure
7	Engagement, policy and signoff modules
8	Internal review against AASB S2 statement. CFO sign-off. Submit

Starting in week one of June puts the submission in by mid-August, well ahead of the 14 September scored deadline.

The audit trail that makes all three disclosures defensible

A CDP response that reconciles to AASB S2 and NGER depends on one thing: every number traces back to the source document it came from. The electricity bill, the fuel receipt, the gas invoice, the refrigerant log. If a third-party assessor asks where the Scope 2 number came from, you need to show the meter reads behind it within the same session, not next week.

Carbonly's document AI engine extracts emission data from utility bills, fuel dockets and supplier invoices across 8 file formats, stores the source document against the calculation, and locks the reporting period so the number you cite in CDP is the same number that appears in AASB S2 and NGER. The 5-tier material matching means a diesel docket and a CNG invoice land against the right NGA factor without manual classification. Both AR5 and AR6 GWP values are supported, so the NGER and AASB S2 versions can run from the same underlying data (CDP disclosure automation).

The platform does not write the CDP response for you. It gives you the source-document trail that lets a CDP assessor, an ASIC reviewer and an NGER auditor read three disclosures and see the same numbers.

Start with the reconciliation, not the questionnaire

Before drafting a single CDP answer, put the AASB S2 climate statement and the most recent NGER submission on the desk together. Highlight every Scope 1, Scope 2 and Scope 3 number. Note the methodology, the boundary, the GWP set, the Scope 2 method. The CDP response is then a translation of that data into the questionnaire structure, not a fresh calculation. The companies that get into trouble are the ones who treat CDP as a separate exercise.

If you would like to see how the same source-document trail can feed CDP, AASB S2 and NGER from one data set, get in touch at hello@carbonly.ai or join the waitlist.

Sources and further reading