CDP Disclosure in India: How to Score an A When 68% of Indian Respondents Get C or Below

Published: 22 June 2026 | Category: ESG Disclosure & Ratings | Reading time: 13 min read

CDP — formerly the Carbon Disclosure Project — has become the world’s dominant platform for corporate environmental disclosure. With over 24,000 companies disclosing globally and $130 trillion of investor capital behind the platform, a CDP score is no longer optional for companies seeking international capital, multinational supply chain positions, or credible ESG credentials. In India, CDP participation has grown rapidly: over 400 companies now respond, up from fewer than 100 in 2019. Yet the quality of Indian responses lags significantly behind global peers, with 68% of respondents scoring C or below — indicating basic disclosure without meaningful climate action.

This article examines the CDP scoring methodology, analyses where Indian companies lose points, maps the overlap between BRSR and CDP data requirements, and provides a practical roadmap for moving from C-score disclosure to A-score leadership.

CDP Scoring: How It Actually Works

CDP’s scoring methodology operates on four progressive tiers, each requiring the company to demonstrate increasingly sophisticated environmental management. Critically, scoring is cumulative — you cannot score B without meeting all C-tier criteria first.

Score Tier	Label	What It Requires	Indian Companies (%)
D / D-	Disclosure	Provides basic emissions data, governance structure	28%
C / C-	Awareness	Demonstrates awareness of climate risks, basic policies	40%
B / B-	Management	Takes coordinated action, sets targets, measures progress	25%
A / A-	Leadership	Best practice across all criteria, verified targets, supply chain engagement	7%

Where Indian Companies Lose Points

Our analysis of 50 Indian CDP responses reveals five consistent failure patterns that separate C-score companies from B and A performers:

1. Incomplete Scope 3 emissions (impact: -15 to -20 points). CDP requires disclosure across all 15 Scope 3 categories, with explanation for any categories excluded. Most Indian respondents report only 3-5 categories, with purchased goods (Cat 1), fuel-and-energy (Cat 3), and employee commuting (Cat 7) being the most common. Critical categories like use of sold products (Cat 11) and investments (Cat 15 for BFSI) are frequently omitted without adequate justification.

2. No science-based targets (impact: -10 to -15 points). CDP awards maximum points for approved SBTi targets. As of 2026, only 85 Indian companies have committed to SBTi, and fewer than 50 have approved targets. Without SBTi alignment, companies cannot access B-tier scoring on the targets section.

3. Weak climate governance disclosure (impact: -8 to -12 points). CDP asks detailed questions about board competency on climate issues, executive incentives linked to climate targets, and climate risk integration into enterprise risk management. Indian companies frequently provide generic governance descriptions without specifics — “the board reviews ESG matters quarterly” scores significantly lower than “the CSO reports directly to the board, with 15% of CEO compensation linked to Scope 1+2 reduction targets.”

4. No TCFD-aligned scenario analysis (impact: -10 to -15 points). CDP’s climate risk section requires scenario analysis under at least two climate scenarios (including a 1.5°C pathway). Fewer than 20% of Indian respondents conduct quantitative scenario analysis. Most provide qualitative risk descriptions without scenario-specific financial impact estimation.

5. Minimal supplier engagement (impact: -5 to -10 points). A-score companies must demonstrate engagement with at least 70% of suppliers by spend on climate issues. Most Indian companies engage fewer than 20% of suppliers, with engagement often limited to requesting data rather than setting targets or providing capacity building.

The BRSR-to-CDP Data Bridge

Companies already filing BRSR have a significant head start on CDP responses. Our mapping analysis shows approximately 60-70% data overlap between BRSR and CDP Climate Change:

BRSR Principle 6 environmental data — Scope 1 and 2 emissions, energy consumption by source, water withdrawal, waste generation — feeds directly into CDP Sections C6 (Emissions), C8 (Energy), and W1 (Water). However, CDP requires additional granularity: emissions by business division, energy purchased from renewable sources with certificate evidence, and water withdrawal specifically from water-stressed basins using WRI Aqueduct data.

The areas where CDP goes beyond BRSR include: climate risk assessment and scenario analysis (CDP C2-C3), transition plans with financial implications (CDP C3.3-C3.4), internal carbon pricing mechanisms (CDP C11), and Scope 3 emissions across all 15 GHG Protocol categories (CDP C6.5). These sections require dedicated effort that BRSR data alone cannot satisfy.

A Roadmap from C to A

Based on our work with Indian companies that have improved their CDP scores by 2+ tiers, we recommend a phased approach:

Year 1 (C → B): Build the data foundation. Complete Scope 1, 2, and full Scope 3 calculation using RSustain’s ScopeTracer. Set reduction targets (even if not yet SBTi-approved). Conduct a basic climate risk assessment identifying physical and transition risks. Ensure board-level climate governance is documented.

Year 2 (B → B+/A-): Add strategy and targets. Submit SBTi commitment letter. Conduct quantitative scenario analysis under 1.5°C and 3°C pathways. Develop a transition plan with sector-specific milestones. Begin supplier engagement on climate — target 40% of suppliers by spend. RSustain’s SBTi Pathway tool can model target-setting scenarios.

Year 3 (A- → A): Demonstrate leadership. Achieve SBTi-approved targets. Show year-on-year emissions reductions (not just intensity reductions). Engage 70%+ of suppliers on climate. Implement internal carbon pricing. Integrate climate into financial planning with quantified financial impacts. Achieve third-party verification of emissions data.

CDP Water and Forests: The Overlooked Questionnaires

While CDP Climate Change receives the most attention, Indian companies in water-intensive and land-use-sensitive sectors should also consider the CDP Water Security and CDP Forests questionnaires. These are increasingly requested by investors and carry growing weight in ESG ratings.

For water-intensive sectors — BFSI, beverages, chemicals, mining, textiles, agriculture — the CDP Water Security questionnaire requires water withdrawal data by source and basin, water risk assessments using WRI Aqueduct or similar tools, water-related targets, and value chain water risk assessment. RSustain’s WaterDisclose tool provides structured data collection aligned to CDP Water requirements.

For sectors with deforestation exposure — palm oil, soy, cattle products, timber, rubber, coffee, cocoa — CDP Forests requires supply chain traceability, deforestation-free commitments, and monitoring systems. With EUDR enforcement beginning in 2025, Indian agricultural exporters face overlapping requirements.

The bottom line: CDP disclosure is no longer a voluntary exercise for brand-conscious companies — it is a gateway to capital, supply chains, and market credibility. Indian companies that invest in improving their CDP performance will find that the same systems, data, and governance structures strengthen their BRSR compliance, investor relations, and climate resilience.

Frequently Asked Questions

How many Indian companies disclose to CDP and what are typical scores?

Over 400 Indian companies respond to CDP, growing 25% annually. However, 68% score C or below. Only 12 Indian companies are on the A-List. The average Indian corporate CDP score is C, compared to B- for European companies. RSustain’s CDP Response Builder helps identify scoring gaps and optimise responses.

How does CDP scoring work?

CDP uses four progressive tiers: D (Disclosure), C (Awareness), B (Management), A (Leadership). Scoring is cumulative — B requires all C criteria plus action-oriented management. A requires approved SBTi targets, 70%+ supplier engagement, year-on-year reductions, and TCFD-aligned scenario analysis. Scoring is sector-adjusted.

What is the overlap between BRSR and CDP data?

Approximately 60-70% of CDP Climate Change data can be sourced from BRSR Principle 6 disclosures — primarily Scope 1/2 emissions, energy consumption, and water data. CDP additionally requires Scope 3 across all 15 categories, scenario analysis, transition plans, and supplier engagement metrics that go beyond BRSR.

What does it take to achieve a CDP A-score?

Key requirements: comprehensive verified Scope 1/2/3 emissions, SBTi-approved targets, board-level governance with executive incentives, TCFD-aligned quantitative scenario analysis, year-on-year absolute emissions reductions, 70%+ supplier engagement, internal carbon pricing, and a costed transition plan. Use RSustain’s SBTi Pathway to model credible targets.

When should companies start preparing for CDP?

The CDP questionnaire opens in April-May with July submission deadlines. Preparation should begin at least 3 months before — ideally starting in January for data collection and gap analysis. Companies disclosing for the first time should attend RSustain Academy’s Carbon Accounting & Scope 3 Strategy course to build foundational capability.