CDP Disclosure for SMEs in 2026: Submission, Scoring and Verification Explained

CDP runs the world's most widely used independent environmental disclosure system. Companies, cities and regions report data through it each year, and that data is used by investors, banks and large corporate buyers to assess environmental performance and risk. In 2025, more than 23,100 organisations disclosed through CDP, including around 11,000 small and medium-sized enterprises using the dedicated SME questionnaire.

Disclosure is voluntary, but it is rarely optional in practice. Most smaller businesses end up disclosing because a customer, investor or lender has requested it. For 2026, CDP has kept its focus on making the process simpler, while adding two new optional nature modules and, for the first time, a top-level score that SMEs can achieve. This guide covers what the SME questionnaire asks for, how it is scored, where third-party verification fits in, and the practical steps and deadlines for submitting.

Who can use the CDP SME questionnaire in 2026?

CDP offers two corporate questionnaires: the full corporate questionnaire and a shorter SME questionnaire. The SME version contains fewer and simplified datapoints, and has no sector-specific questions.

Eligibility is based on size. A business can use the SME questionnaire if it has 1,000 or fewer employees and annual revenue of US$250 million or less. Above either of those thresholds (more than 1,000 employees or more than US$250 million in revenue), only the full corporate questionnaire is available. Businesses below the threshold can still opt in to the full questionnaire if they prefer. 

This matters for mid-market businesses, because CDP's SME threshold is far broader than the standard EU definition of an SME (usually fewer than 250 employees). A business with several hundred staff will often still qualify for the simpler SME route.

One exception applies: organisations requested to disclose by the RE100 initiative cannot use the SME questionnaire.RE100 is a global initiative led by The Climate Group in partnership with CDP, where companies commit to sourcing 100% renewable electricity across their operations by a set target year. Companies that join are required to disclose through the full CDP corporate questionnaire because the initiative demands detailed, standardised reporting to verify progress against their renewable electricity commitments and ensure transparency and credibility. 

What does the CDP SME questionnaire ask businesses to disclose in 2026?

The SME questionnaire centres on climate change, and that is the only environmental issue scored for SMEs in 2026. Every discloser answers the climate datapoints.

The climate section asks for:

• Emissions methodology and any exclusions from the inventory
• A Scope 1, 2 and 3 emissions inventory
• A breakdown of emissions by business activity
• Energy-related activities
• Emissions reduction targets
• Emissions reduction initiatives

As a quick reminder of the scopes: Scope 1 covers direct emissions from sources a business owns or controls, Scope 2 covers the emissions from bought-in energy such as electricity, and Scope 3 covers everything else across the value chain, from purchased goods and services to business travel. Scope 3 is usually the largest share and the hardest to measure.

New for 2026, CDP has added two optional nature modules to the SME questionnaire: one on forests and one on water security. The forests module applies to businesses that produce or source seven key commodities (timber, cattle, palm oil, soy, coffee, cocoa and rubber). The water module applies where water security is relevant to operations or the supply chain. These modules are only shown to businesses asked to report on them or that choose to opt in during questionnaire setup. Both forests and water are unscored for SMEs in 2026.

One practical note on data privacy: CDP asks businesses not to include the names of individuals anywhere in a response. Where a question asks about a role, only the position is needed.

How is the CDP SME questionnaire scored in 2026?

CDP scores SMEs across four consecutive levels, each representing a step towards stronger environmental management:

The levels are cumulative. A business has to meet a minimum standard at one level before it can earn credit at the next, which rewards consistent reporting rather than isolated strong answers.

The headline change for 2026 is that SME Leadership is now scored, so an SME A score is available for the first time. It recognises leading climate action within the SME questionnaire. CDP is clear that an SME A is not equivalent to an A on the full corporate questionnaire, and recommends the full questionnaire for businesses engaging closely with capital markets or working towards leadership recognition.

Two points are worth understanding about how scoring works:

• CDP does not verify the information in a response when it scores it. Scores are based on what is disclosed, so completeness and internal consistency are what count. Weblinks and attachments are generally not considered for scoring unless a question specifically asks for them.
• Only responses submitted in one of five languages are scored: English, Latin American Spanish, Brazilian Portuguese, Japanese and Chinese.

Score visibility depends on who requested the disclosure. If a business was requested by CDP's Capital Markets Signatories, its score is made public. If it was requested by other requesters, such as a supply chain customer, the score stays private unless it reaches SME A.

Do SMEs need third-party verification for CDP?

This is one of the most misunderstood parts of CDP disclosure, so it is worth being precise.

For SMEs in 2026, third-party verification (also called assurance) is not mandatory. There is no blanket requirement to have a set percentage of emissions verified in order to disclose, or to be scored, on the SME questionnaire. Independent verification can strengthen the credibility of reported data, but it is not a barrier to disclosing.

The strict verification thresholds people often hear about belong to the full corporate questionnaire, where CDP applies a set of "essential criteria" at higher scoring levels. CDP states explicitly that these essential criteria do not apply to the SME questionnaire. For context, on the full corporate questionnaire in 2026:

So, in short: an SME does not need third-party assurance to disclose to CDP in 2026. A business heading towards the full corporate questionnaire and aiming for Leadership or the A List does. If verification is on the horizon for other reasons, our guide to ISO 14064 verification covers how third-party assurance of a GHG inventory works.

How do businesses submit to CDP in 2026?

Everything runs through the online CDP Portal. The process looks broadly like this:

1. Access the Portal. Businesses requested by a customer or by capital markets receive a direct link. Those disclosing voluntarily (CDP calls them Self-Selected Companies) and new users without a link register to disclose first.
2. Complete onboarding. This means reviewing any requests to disclose, confirming a Submission Lead (the person who will submit the final response), paying the admin fee where it applies, and setting up the questionnaire so the right modules appear.
3. Answer the questionnaire. Responses are entered through structured questions, narrative fields and numerical tables. Colleagues and external advisers can be added as contributors to work in the same workspace.
4. Submit before the deadline.

Two features make repeat disclosure quicker. Businesses that have disclosed before can "copy forward" their previous answers, which pre-populates the questionnaire, though CDP advises checking and updating every carried-over answer before resubmitting. New for 2026, CDP is rolling out an AI-assisted feature that lets organisations upload data from documents such as annual reports and then suggests draft answers to review, edit or ignore. It is being introduced in phases from June 2026.

What are the key dates and fees for CDP disclosure in 2026?

The 2026 cycle runs from June to October. The dates that matter most:

Responses submitted after the scoring deadline can still be filed, but they are not scored. A limited number of paid on-demand extensions to 30 September are available at CDP's discretion.

On fees, only companies pay CDP's admin fee, and whether an SME pays depends on who asked it to disclose. A business is exempt from the fee if it has only been requested by a supply chain member, a banks programme member, a private markets member, or the RE100 initiative. Since most smaller businesses disclose because a customer has asked them, many will not pay a fee at all. The fee does apply to businesses requested by CDP's Capital Markets Signatories, and to those choosing to disclose voluntarily. Where a fee is payable, the amount is the same whether a business completes the SME or the full corporate questionnaire. CDP publishes its current fee tiers by region.

How does CDP align with other reporting frameworks?

One reason CDP disclosure is useful beyond the score itself is that it pulls a lot of environmental reporting into a single dataset. CDP's questionnaire is aligned with the ISSB's IFRS S2 climate standard, and CDP has been deepening alignment with the TNFD, the Global Reporting Initiative (GRI), the Science Based Targets Network, the Greenhouse Gas Protocol, and the Ellen MacArthur Foundation's Global Commitment on plastics.

For businesses with EU exposure, CDP's climate questions also map closely to the climate disclosures under the European Sustainability Reporting Standards (ESRS E1). In practice, the work done to build a CDP response, especially a full-scope GHG inventory and a credible reduction target, feeds directly into other frameworks a business may face, from SBTi target validation to SECR and B Corp.

What has changed for SMEs in 2026?

The overall direction for 2026 is stability and simplification, with a few additions worth knowing:

• SME A is now available, with Leadership scored for the first time, giving SMEs a clear top rung to aim for.
• Two optional nature modules (forests and water security) have been added, though neither is scored for SMEs this year.
• AI-assisted data upload is being introduced in phases to speed up the process.
• Copy-forward and clearer guidance make repeat disclosure more straightforward.

The SME questionnaire itself was introduced in 2024, replacing the older minimum version of the corporate questionnaire. More than 12,500 SMEs used it in its first year. The structure has held steady since, so businesses that disclosed last year will recognise the process.

FAQs

Is CDP disclosure mandatory for SMEs?

No. CDP disclosure is voluntary for SMEs. However, many smaller businesses choose to disclose because they have been requested to do so by a customer, investor, or financial institution through the CDP disclosure system. 

What is the difference between the SME and full corporate questionnaire?‍

The SME questionnaire is shorter, simplified, and has no sector-specific questions. It is open to businesses with 1,000 or fewer employees and US$250 million or less in revenue. Larger organisations use the full corporate questionnaire, which includes sector-specific datapoints and stricter essential criteria at higher scoring levels.

Does an SME have to pay to disclose to CDP?

‍Not always. A business is exempt from CDP's admin fee if it has only been requested by a supply chain member, a banks programme member, a private markets member or RE100. The fee applies to businesses requested by capital markets signatories, and to voluntary (self-selected) disclosers.

Do SMEs need their emissions verified to disclose to CDP?‍

No. Third-party verification is not mandatory for SMEs in 2026. It can add credibility, but the strict verification thresholds apply only to the full corporate questionnaire at Leadership and A List level.

What is the deadline for CDP disclosure in 2026?‍

The scoring deadline is 16 September 2026. Responses can be submitted until the final deadline in the week of 26 October 2026, but anything filed after the scoring deadline is not scored.

What emissions data does CDP need?‍

At minimum, an SME reports its Scope 1, 2 and relevant Scope 3 emissions, along with the methodology used, any exclusions, energy data, reduction targets and reduction initiatives.

Can a business disclose to CDP voluntarily?‍

Yes. CDP calls these Self-Selected Companies. Voluntary disclosers pay the admin fee, and their responses are made available to capital markets signatories.

How Seedling can help

A strong CDP response rests on one thing above all: an accurate, full-scope carbon footprint you can stand behind. That is where we focus. Seedling pairs intuitive carbon accounting software with one-to-one support from a dedicated carbon expert, so you can measure a complete Scope 1, 2 and 3 footprint in line with the GHG Protocol, set a science-based reduction target, and produce data that is checked by our team before it goes anywhere.

Because that same footprint feeds CDP, SECR, B Corp, SBTi and client requests, the work is done once and reused across frameworks. If a customer or investor has asked your business to disclose through CDP, we can help you get the underlying numbers right.

To talk it through, book a demo or get in touch. For a wider walkthrough of the platform and process, see our Ultimate Guide to CDP Reporting in 2026.

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