CDP Reporting for Indian Listed Entities 2026 — Climate Change, Water Security, Forests + the SEBI Score-Sharing Restriction

CDP is the global voluntary disclosure platform of choice for environmental reporting — climate change, water security, forests, and (from 2026) ocean. For Indian listed entities, the response value comes from three sources: investor-signatory pressure, Western enterprise customer requirements via CDP Supply Chain, and the substantial data reuse with BRSR Core, IFRS S2, ESRS E1, and SBTi. This page covers the 2026 cycle timeline, the questionnaire updates, the SEBI score-sharing restriction (often missed), and the practical sequencing for an Indian listed entity preparing simultaneously for BRSR Core and CDP.

The 2026 cycle — diary dates

Per CDP’s Disclosure 2026 schedule:

Date	Event
27 April 2026	2026 questionnaire released
15 June 2026	Submission portal opens for respondents
14 September 2026	Scoring deadline — responses submitted by this date are scored in the public cycle
26 October 2026	Reporting window closes (post-scoring responses don’t get a public score)

Working back: data collection + stakeholder review needs 6-10 weeks; internal sign-off + audit-committee approval 2-3 weeks; drafting 4-6 weeks. Practical preparation starts in May 2026 at the latest to hit the 14 September scoring cutoff.

What changed in 2026 — three substantive expansions

Climate Change. Adaptation and resilience disclosures layered into existing climate sections. Alignment with IFRS S2 and TNFD framings strengthened. The questionnaire remains the most-substantial of the three scored themes.

Water Security. More detailed disclosure of wastewater treatment levels, discharge volumes, regulatory compliance, and pollutant-management practices. SBTN-aligned (Science Based Targets Network) freshwater targets now formally recognised within the scoring framework.

Forests — commodity expansion. Cattle, palm oil, soy, and timber were already scored; 2026 adds cocoa, coffee, and rubber to the scored commodities. For Indian agribusiness exporters in any of those commodity supply chains, this is a material new disclosure surface — supply-chain origin tracking and deforestation-conversion-free (DCF) attestation becomes scoring-relevant.

Newer unscored modules. Ocean-related questions added across themes; broader coverage of forests and other natural ecosystems; biodiversity and plastics remain unscored themes (visibility only, no public grade).

SME questionnaire. Expanded from 8 to 10 modules. SMEs can now achieve an ‘A’ score for Climate Change for the first time and can disclose on Forests and Water Security through new unscored modules. Relevant for Indian SMEs serving Western enterprise customers via CDP Supply Chain.

The SEBI score-sharing restriction Indian listed entities must understand

CDP’s 2026 guidance explicitly notes: to comply with the SEBI (Credit Rating Agencies) Regulations 1999, the use of CDP scores is restricted for Indian organisations with securities listed in India — these organisations must not share their CDP scores externally within India.

The underlying SEBI rationale: SEBI regulates rating agencies that issue securities-market ratings. An unregulated foreign score being marketed in India as if it were a SEBI-recognised rating creates investor-disclosure risk. The 2023 amendments to the SEBI (Credit Rating Agencies) Regulations 1999 — which introduced the ESG Rating Provider (ERP) regulatory framework — formalised that any ESG rating shared with Indian investors must come from a SEBI-registered ERP. CDP scores fall outside the SEBI-ERP universe and therefore cannot be presented as ratings for Indian-investor communication. The restriction applies to the score (A-list, A, B, etc.), not to the disclosure itself.

Practical implications for Indian listed entities:

• Can do: respond to CDP, disclose internally and to foreign investors / customers, reference CDP disclosure participation in Indian marketing (e.g. “BatchWise responds annually to CDP Climate Change”)
• Cannot do: publish or actively share the CDP score in Indian marketing materials, Indian-investor-targeted IR collateral, or press releases circulated in India
• Gray area: social media posts; advisable to refer to “CDP-disclosed” or “CDP-responding” status rather than the score itself

Confirm current applicability with your company secretary and external counsel before any Indian-facing communication that references CDP. This is the most-commonly-missed point in Indian CDP responses.

How CDP maps to BRSR Core — the data-reuse playbook

BRSR Core’s nine quantitative attributes overlap substantially with CDP scored themes:

BRSR Core attribute	CDP theme overlap
GHG Footprint (Scope 1, 2, 3 intensity per revenue)	Climate Change — full overlap
Water Footprint (withdrawal, intensity per revenue)	Water Security — full overlap
Energy Footprint (intensity per revenue)	Climate Change — partial (energy module within CC)
Embracing Circularity	Not in CDP scored themes; appears in voluntary modules
Employee Wellbeing + Safety	Not in CDP; BRSR-specific
Gender Diversity	Not in CDP scored themes
Inclusive Development	Not in CDP
Fairness with Customers / Suppliers	Not in CDP scored themes
Openness of Business	Not in CDP

For entities running both BRSR Core (mandatory) and CDP (voluntary), the data preparation should be sequenced once, harvested for both:

1. GHG inventory build — Scope 1, 2, 3 per GHG Protocol Corporate Standard + Scope 3 Standard; ISAE 3410 / SAE 3410 assurance applied for BRSR Core reasonable assurance
2. Water inventory build — site-level withdrawal + discharge data; aggregate intensity calculation
3. Energy inventory build — total energy, renewable share, intensity per revenue
4. Climate targets — SBTi-validated targets (highest-credibility for both BRSR Principle 6 narrative and CDP Climate Change scoring)
5. Governance documentation — board oversight, committee structure, executive remuneration linkage; same evidence pack for both
6. Risk management — TCFD-aligned scenario analysis covering at least 1.5°C and >2°C; reusable across CDP, IFRS S2, and BRSR

Indian listed entities running this multi-framework playbook report ~60-70% data reuse across BRSR Core, CDP, IFRS S2, ESRS E1, and SBTi. The differences are presentation format and disclosure granularity, not the underlying numbers.

The four scoring levels — what A vs D actually means

CDP scoring runs across four progressive levels for each scored theme:

Level	Bands	What it measures
Disclosure	D-, D	Reporting the relevant data — minimum entry bar
Awareness	C-, C	Understanding the impacts, risks, and opportunities
Management	B-, B	Good environmental management practices in place
Leadership	A-, A	Best-practice performance — typically SBTi-validated, third-party assured, with demonstrated transition execution

Approximately 2-4% of disclosing companies globally achieve an A-list score on Climate Change in any given year. Indian Climate Change A-list performers in recent cycles include Wipro, Tech Mahindra, HDFC Bank, Tata Consultancy Services, Tata Steel, and Jio (Reliance Jio Infocomm, 2023) — listings vary by year. Verify current Indian A-listers on the CDP A-List page before citing externally. Improvement from D to B typically takes 2-3 disclosure cycles of structured effort; B to A requires substantive performance improvement, not just better disclosure.

Evidence map — what the scoring assessor expects

Although CDP does not mandate third-party assurance, assured data scores materially higher. The evidence universe:

• GHG inventory — Scope 1, 2, 3 per GHG Protocol; ISAE 3410 / SAE 3410 assured at limited (preferred reasonable) assurance level
• Climate targets — SBTi-validated near-term + (where applicable) long-term net-zero targets; from 1 January 2028, the SBTi V2 Corporate Net-Zero Standard becomes mandatory for new validations and includes a mandatory transition plan requirement
• Climate governance — board-level oversight charter, committee structure, climate-linked executive remuneration policy
• TCFD-aligned scenario analysis — at least 1.5°C and >2°C scenarios; short / medium / long horizons; documented assumptions, financial impact assessment where material
• Water inventory — site-level data with intensity calculation; water-stress mapping for operating geographies
• Forest commodity origin tracking — for in-scope sectors, supply-chain origin data with DCF attestation

For Indian entities preparing simultaneously for BRSR Core (mandatory) and CDP (voluntary), sequence the BRSR Core assurance engagement first (under SAE 3000 (Revised) for the Core attributes) — the assured numbers feed CDP directly.

CDP Supply Chain — when customer-specific deep-dives kick in

CDP Supply Chain is the customer-requestor program through which large buyers (Microsoft, Walmart, BMW, Unilever, etc.) request disclosures from their suppliers. If a key customer is a CDP Supply Chain requestor, your response is scrutinised at a higher rigour than the general investor-facing response:

• Customer-specific scoring methodology may apply
• Customer-specific data points (allocated emissions per customer, customer-specific reduction targets)
• Sometimes a parallel separate questionnaire layered on top of the general one

For Indian SMEs and mid-caps serving Western enterprise customers, the CDP Supply Chain response is increasingly a procurement-condition rather than a voluntary nice-to-have. Combined with BRSR Value Chain Verification for Indian-listed-customer relationships, the disclosure surface covers most cross-border procurement requirements.

When CDP requires a standalone workstream above BRSR-data-reuse

Three triggers push CDP out of the data-reuse pattern into a dedicated workstream:

1. Western enterprise customer CDP Supply Chain requirement — customer-specific data and rigour above the public scoring baseline
2. Sector-specific deep-dive — energy utilities, financial services (financed emissions), agriculture, real estate all carry sector-specific questionnaire layers with data not in BRSR Core
3. Forests scope expansion to cocoa / coffee / rubber from 2026 — many Indian agribusiness exporters now in Forests scope; supply-chain origin tracking and DCF attestation outside BRSR Core entirely

In each case, the marginal effort above BRSR data reuse is 30-60% of the BRSR-data preparation effort itself — significant but bounded.

How BatchWise positions on CDP work

BatchWise does not submit CDP responses on behalf of clients. CDP submission is a strategic communications function as much as a data function — and the right resourcing is typically (a) an internal sustainability lead owning the narrative, (b) a CDP-experienced consultant for the response architecture and scoring optimisation, plus (c) the underlying GHG / water / energy data prepared and assured. BatchWise contributes (c) — through coordinated BRSR Core Assurance (which produces the assured Scope 1, 2, 3 numbers + water and energy footprints) and ISAE 3410 GHG verification (for entities needing standalone GHG assurance for CDP credibility). For (a) and (b), specialist CDP consultancies (Sphera, ERM, Carbon Trust India, Climate Connect, and several India-based independents) are the right partners.

Indian listed entities preparing for the 2026 CDP cycle should begin sequencing in May 2026 — see BRSR Core methodology for the data foundation, climate transition plan for the strategy disclosure, and the materiality assessment guide for the upstream prioritisation that determines which themes (climate / water / forests) you prioritise.