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Disclosure Frameworks

Preparing Your Emissions Data for the CDP Climate Questionnaire

6 min read Wei-Lin Chua
Abstract structured questionnaire data layers for climate disclosure preparation

CDP opens its annual questionnaire cycle in spring and closes submissions in the autumn. For most sustainability leads in manufacturing, the questionnaire itself is not the hard part. The hard part is having the right data structure in place before the questionnaire window opens. Companies that scramble to pull numbers together during the response window tend to end up with inconsistencies between sections, missing disaggregations, and methodology descriptions that do not hold together under scrutiny.

This article covers the specific data structure the CDP Climate Change questionnaire requires from your emissions accounting, and what you should have assembled before questionnaire season begins.

How the CDP Climate Change questionnaire is organized

The CDP Climate Change questionnaire is organized around several themes: governance, risks and opportunities, business strategy, targets and performance, emissions methodology, and the emissions data itself. The emissions data sections require disaggregated figures by scope, source type, and greenhouse gas.

The sections you need complete emissions data for include:

  • Scope 1 gross emissions, broken down by greenhouse gas (CO2, CH4, N2O, and others if applicable)
  • Scope 2 gross emissions under both location-based and market-based methods
  • Scope 3 emissions by category, with notes on calculation methodology per category
  • Emission intensity ratios tied to your business metric (revenue, production output, or similar)
  • Data quality notes including calculation methodology, emission factors used, and boundary definition

The questionnaire also asks about your emissions verification status, whether an external third-party reviewed your numbers, and at what level of assurance. This is not a new requirement, but it is one that is increasingly scrutinized as CDP scores are used by investors and supply chain partners to make purchasing decisions.

Scope 1 disaggregation: what CDP actually wants

CDP asks for Scope 1 to be broken down by source category and by greenhouse gas. For a manufacturer, the typical Scope 1 sources are stationary combustion (boilers, furnaces, process heaters), mobile combustion (company vehicles, forklifts), and fugitive emissions (refrigerants, if applicable).

Each source category needs its own activity data trail. Stationary combustion comes from utility bills and fuel delivery invoices. Mobile combustion comes from fuel receipts or fleet fuel cards. Fugitive emissions come from refrigerant purchase records and service logs.

The greenhouse gas disaggregation matters because combustion produces primarily CO2, with small quantities of CH4 and N2O depending on combustion conditions and fuel type. These are rolled up to a CO2e total using GWP values from the IPCC's assessment reports. CDP asks for the CO2e total but also wants to understand which gases are included and on what GWP basis.

If you have been calculating a single "Scope 1 total" without keeping the source-type disaggregation, you will need to restructure your calculation before CDP submission. The total number is not sufficient for the questionnaire.

Scope 2: the dual-reporting requirement in practice

CDP requires both location-based and market-based Scope 2 figures when both methods are applicable. This has been true for several years and it still trips up companies that have only ever tracked one method.

Location-based uses the average grid emission factor for the geographic region where electricity is consumed. For Singapore this is the EMA grid factor. For facilities in multiple countries, each facility uses the factor for its own grid.

Market-based uses energy attribute certificates or contractual instruments. If you have purchased I-RECs, GOs, or other renewable energy certificates, the market-based figure reflects that purchase. If you have no such instruments, the market-based figure defaults to the residual mix factor for your grid, which is typically available from the local grid operator or from organizations like RE100.

The practical preparation work here is ensuring you have the utility account data for every facility, the correct factor vintage for each billing period, and the documentation of any energy attribute certificate purchases. The last point is often the messiest: the certificates may be purchased through a different procurement process than the electricity itself, and matching them to the right period and account requires cross-referencing two separate document sets.

Scope 3: categories and methodology documentation

CDP asks respondents to report on all relevant Scope 3 categories and to indicate which categories are included, which are excluded, and why. For each included category, you provide the tCO2e figure and a description of the calculation methodology used.

The key word is "relevant." You are not expected to calculate all 15 categories if most are immaterial to your business. But you need to have done the materiality assessment, documented the reasoning, and be prepared to explain your category selection. CDP reviewers are alert to companies that omit large upstream categories without adequate justification.

For each included category, the methodology note needs to specify whether you used a spend-based, activity-based, or supplier-specific approach, which emission factor database you drew from, and what data year the factors represent. This is more specificity than most companies maintain in their internal calculations, which is why getting the data structure right before questionnaire season matters.

Emission intensity and targets

CDP asks for at least one emission intensity ratio: total gross Scope 1 plus Scope 2, divided by a business metric relevant to your operations. Common choices are revenue, production volume, or floor area. The metric needs to be consistent from year to year; changing the denominator without explanation breaks year-over-year comparability.

If you have set emissions reduction targets, CDP wants specifics: base year, target year, percentage reduction relative to what baseline, and whether the target covers Scope 1 and 2 only or includes Scope 3. The data infrastructure implication is that you need a defensible base year figure, which means the year you use as your baseline must be calculated with the same methodology as your current year, or you need to restate both on a consistent basis.

Verification status and what it means for your data

CDP asks whether your Scope 1 and 2 figures have been externally verified and at what level of assurance. Limited assurance and reasonable assurance are the two levels; limited assurance is more common for emissions data, reasonable assurance is the higher standard and is increasingly expected for disclosed figures.

This is not a binary question for CDP purposes. You can indicate that figures are verified, not verified, or in progress. What matters is consistency: if you claim third-party verification and an investor asks to see the assurance report, the report needs to exist and the figures in it need to match what you submitted.

The implication for data preparation is that anything you plan to submit as verified should have a complete audit trail before it goes to a third-party verifier. Verifiers are looking for source documents (invoices, meter reads), calculation methodology documentation, and evidence that the calculation was carried out as described. A spreadsheet with no links to source documents does not support assurance, regardless of how accurate the numbers are.

What this preparation means in practice

The data structure you need for CDP is not fundamentally different from what GHG Protocol good practice requires for any disclosure. The specifics are: source-type disaggregation for Scope 1, dual-method reporting for Scope 2, category-by-category Scope 3 with documented methodology per category, and retention of source documents that support the numbers.

What Zevero produces is a structured emissions ledger where every entry has a source document, a classified emission type, a factor, and a calculated CO2e. That ledger is the basis for any disclosure format, including CDP. The questionnaire-specific structuring, the methodology notes, the intensity calculations, these are an additional formatting layer on top of the underlying data.

We are not the submission tool. We are the data preparation layer, and getting that layer right before questionnaire season opens is what determines whether your CDP response holds together under reviewer scrutiny.