Quick Comparison
| CDP | TCFD | |
|---|---|---|
| Scope | Environmental — climate, water, forests | Climate-related financial risks and opportunities |
| Applicability | Companies requested by investors/customers | Any organization |
| Required/Voluntary | Voluntary (investor/customer-driven) | Voluntary recommendations (mandated in some jurisdictions, now succeeded by ISSB) |
| Geography | Global | Global |
| Key Focus | Environmental scoring via annual questionnaires | Structured climate risk disclosure across four pillars |
| Assurance | Verification encouraged; rewards in scoring | Not specified |
What is CDP?
CDP operates the world's largest environmental disclosure platform, collecting data from over 23,000 companies through annual questionnaires on climate change, water security, and forests. The system is demand-driven: institutional investors and supply chain purchasers request disclosure, and companies receive letter-grade scores (A through D-, or F for non-response) that benchmark performance against peers.
CDP has progressively aligned its climate change questionnaire with the TCFD framework. Since 2018, CDP's questions explicitly map to the TCFD's four pillars — Governance, Strategy, Risk Management, and Metrics & Targets. In practice, completing a CDP climate questionnaire generates most of the information needed for TCFD-aligned disclosure, and CDP has positioned itself as the primary implementation mechanism for TCFD reporting.
In 2024, CDP began integrating ISSB-aligned questions, evolving its role from a TCFD implementation platform to a multi-framework disclosure hub. The organization has stated its intention to serve as a single reporting channel through which companies can satisfy CDP, ISSB, and eventually ESRS requirements.
What is the TCFD?
The Task Force on Climate-related Financial Disclosures published its recommendations in 2017, creating a globally adopted framework for climate risk disclosure organized around four pillars: Governance, Strategy, Risk Management, and Metrics & Targets. The framework produced eleven recommended disclosures covering board oversight, organizational strategy around climate risks and opportunities, risk identification processes, and quantitative metrics including greenhouse gas emissions.
The TCFD was disbanded in October 2023 after the ISSB assumed its monitoring responsibilities. IFRS S2 fully incorporates the TCFD's framework and recommended disclosures. While TCFD as an independent body no longer exists, its four-pillar architecture remains the structural foundation for global climate disclosure through ISSB, ESRS, and CDP.
Key Differences
1. Platform vs Framework
CDP is a disclosure platform — it collects, scores, and publishes environmental data. The TCFD was a framework — it defined what to disclose and how to structure it. CDP provides the mechanism; TCFD provided the architecture. Think of TCFD as the blueprint and CDP as one of the buildings constructed from that blueprint.
2. Scoring and Accountability
CDP scores companies publicly, creating market-based incentives for better disclosure and performance. TCFD had no scoring mechanism — companies self-reported their alignment with recommendations, and the quality and completeness of TCFD disclosures varied enormously. CDP's scoring brings accountability that TCFD's recommendations lacked.
3. Topical Scope
CDP covers three environmental themes: climate change, water security, and forests. TCFD addressed only climate-related financial risks and opportunities. While the climate overlap is significant, CDP's water and forests questionnaires extend into environmental territory that TCFD never covered.
4. Data Collection Approach
CDP uses structured questionnaires with specific questions, dropdown selections, and required data fields. Responses are standardized, enabling automated analysis and comparison. TCFD recommended disclosures that companies produced in their own format — annual reports, sustainability reports, or standalone TCFD reports. The data standardization difference is substantial.
5. Target Audience
CDP primarily serves investors and supply chain purchasers who request disclosure. TCFD's recommendations were directed at companies for the benefit of lenders, insurers, and investors more broadly. In practice, significant overlap exists, but CDP's demand mechanism means companies respond to specific requestors, while TCFD reporting was generally directed at the public market.
6. Current Status
CDP continues to operate and is expanding its scope to align with ISSB and ESRS. TCFD has been formally disbanded, with its legacy fully absorbed into IFRS S2. For companies planning their climate disclosure approach, CDP remains an active platform while TCFD is a historical framework whose content lives on in ISSB standards.
Which One Do You Need?
CDP is relevant if investors or supply chain customers request your disclosure. Given that over 740 investors and 330+ supply chain members use CDP, most large companies will receive a request. CDP is also useful for companies wanting a scored benchmark of their climate and environmental performance.
TCFD's content is now in ISSB. If your jurisdiction is adopting ISSB standards, you need IFRS S2 rather than TCFD. If you're in a jurisdiction that still references TCFD (like current UK listing rules), compliance with ISSB or a comprehensive CDP response will satisfy TCFD requirements.
Most companies use CDP as their primary mechanism for producing TCFD/ISSB-aligned climate disclosures, particularly given CDP's questionnaire already maps to the four-pillar structure.
Can You Use Both?
CDP was designed to implement the TCFD framework, so using both is the norm, not the exception. CDP's climate change questionnaire is structured around TCFD's four pillars, and CDP publishes a mapping showing how each question corresponds to TCFD recommended disclosures. A company that achieves a high CDP score has, by definition, produced disclosure that is substantially TCFD-aligned.
The most common approach is to complete the CDP climate questionnaire annually and then reference those disclosures (or produce a summary document) as the company's TCFD-aligned reporting. Many companies include a TCFD index in their annual or sustainability report that points to both the CDP response and relevant report sections.
Going forward, CDP's alignment with ISSB means this integration will extend — a CDP response will increasingly serve as the data collection mechanism for ISSB-compliant climate disclosure.
Council Fire's Perspective
CDP has been the most effective implementation mechanism for TCFD in practice. The framework gave companies the "what" and "how" of climate disclosure; CDP gave them the "when" and "why" — annual deadlines, investor pressure, and public scores. Organizations that treated CDP seriously produced better TCFD disclosures than those that attempted TCFD reporting independently.
As CDP evolves to incorporate ISSB alignment, we advise clients to treat CDP as their primary climate disclosure workflow. The data collection, governance review, and target-setting that CDP demands annually builds the muscle for ISSB compliance. For organizations still early in their climate disclosure journey, a strong CDP response is the most efficient path to comprehensive climate reporting that satisfies multiple stakeholder and regulatory needs.
Frequently Asked Questions
Does a CDP response satisfy TCFD requirements?
Substantially, yes. CDP has aligned its climate change questionnaire with TCFD's eleven recommended disclosures since 2018. An organization that provides a comprehensive CDP climate response will cover the majority of TCFD requirements. However, some jurisdictions with specific TCFD mandates may require disclosures in particular locations (e.g., annual reports) rather than solely through CDP.
Now that TCFD is disbanded, should I stop referencing it?
The TCFD brand is being phased out in favor of ISSB. In the transition period, referencing "TCFD-aligned" reporting remains understood by stakeholders, but new reporting should reference IFRS S2. Most regulators mandating TCFD are transitioning to ISSB-based requirements. CDP's alignment with ISSB means the transition will happen naturally through the CDP platform.
How does CDP use my data?
CDP publishes company scores and makes disclosed data available to requesting investors and, in some cases, publicly. Detailed questionnaire responses are shared with the investors and supply chain members who requested disclosure. CDP also aggregates data for research, benchmarking, and its annual reports on corporate environmental performance. Companies can designate certain responses as non-public.
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