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CDP Worldwide (Europe) gemeinnützige GmbH

CDP Europe

CDP is a global non-profit running an environmental disclosure system for companies and governments.

Lobbying Activity

CDP urges EU to set binding climate adaptation targets

4 Sept 2025
Topic — This initiative seeks to create an integrated framework for managing European climate risks.
Message — CDP requests the inclusion of quantified adaptation scenarios and legally binding targets at the EU level. These targets should be built bottom-up from the goals and financing needs of local governments. The framework must also encourage collaboration between companies and cities on shared regional adaptation targets.123
Why — Binding rules and harmonized tracking would increase the value and demand for CDP’s disclosure data.45
Impact — National governments could lose control over budgets that must support subnational finance needs.67
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Response to Policy agenda for cities

16 May 2025

Data from subnational governments collected via CDP and CDP-ICLEI Track surface four gaps that must be addressed to close the implementation and finance gap among EU cities and regions: The multilevel integration gap The place-based action gap The urban climate finance gap The enabling conditions gap The data evidence that streamlined and effective EU support for cities and other urban areas should address these four main gaps. Notably in areas such as finance and enabling regulatory conditions EU action must complement support provided by Member States. Please see key findings from the data disclosed by EU cities and regions in the attachment.
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CDP urges mandatory ocean metrics in environmental disclosure

17 Feb 2025
Topic — A proposal for unified EU ocean policies and sustainable maritime management.
Message — CDP recommends incorporating specific ocean metrics like noise pollution into environmental disclosures. They advocate for reporting standards aligned with international frameworks to ensure transparency.12
Why — This positions CDP as a key implementation partner for EU marine monitoring.3
Impact — Industries using unsustainable practices would face much higher public scrutiny and accountability.4
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

28 Feb 2024 · ESAP

Response to Postponement of deadlines within the Accounting Directive for the adoption of certain ESRS

19 Dec 2023

CDP evidence shows the importance of sector-specific information for investors. Since 2018 CDP has been requesting companies to fulfil sector-specific questions based on their primary activities. The move towards sector-specific questions was called for by investors to enable easier and more meaningful comparison on company progress. By delaying sector-specific standards the Commission deprives investors of this ability. Please see the attached document for more details.
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CDP Urges Ambitious Soil Monitoring and Public Data Disclosure

26 Sept 2023
Topic — The European Commission is proposing new legislation to monitor and restore healthy soils.
Message — CDP urges the EC to mandate further soil health measures for regeneration. They recommend making data publicly accessible to promote transparency among non-state actors. Monitoring should encompass non-state actor information to accelerate implementation of soil health actions.123
Why — This would increase the use and relevance of CDP's existing environmental disclosure platform.4
Impact — Companies with significant environmental impacts lose the ability to keep soil risks confidential.5
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Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

8 Sept 2023 · Sustainability reporting

CDP urges more transparency in EU ESG rating methodologies

1 Sept 2023
Topic — EU proposal to regulate the reliability and integrity of ESG rating providers.
Message — CDP supports regulation focusing on improved transparency of methodologies around ESG ratings and scores. They strongly recommend a voluntary code of conduct for ESG data products to complement the rules. Additionally, they call for clearer definitions of third-party and consulting services to manage conflicts.123
Why — Scientific alignment of ratings would better support global environmental decision-making goals.4
Impact — Rating agencies with commercial ties to credit clients face stricter conflict-of-interest oversight.5
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Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and

18 Jul 2023 · European Reporting Sustainability Standards

CDP Europe Urges Mandatory Climate and Biodiversity Reporting Standards

5 Jul 2023
Topic — New EU standards for companies to report environmental and social sustainability data.
Message — CDP requests mandatory reporting for key environmental metrics like greenhouse gas emissions. They also demand removing thresholds that delay biodiversity and value chain reporting.12
Why — Mandatory standards would improve the data quality for CDP’s environmental disclosure platform.3
Impact — Financial investors lose access to essential information required for their own regulatory compliance.4
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CDP Europe Urges Inclusion of Corporate Reporting in Nature Law

18 Aug 2022
Topic — The EU is establishing legally binding targets to restore ecosystems and recover biodiversity.
Message — CDP recommends including requirements for non-state actors and referencing European Sustainability Reporting Standards. They suggest that corporate data should inform and contribute to national restoration plans.123
Why — These rules would establish CDP as the primary platform for monitoring corporate environmental commitments.4
Impact — Businesses would face new obligations to integrate biodiversity impacts into all financial decisions.5
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CDP Europe Urges Mandatory Nature-Positive Targets for Corporate Directors

23 May 2022
Topic — New EU rules on corporate accountability for human rights and environmental impacts.
Message — CDP recommends that directors be legally required to set measurable, science-based targets for climate and nature. They also call for an accountability mechanism to ensure companies align with net-zero and full nature recovery by 2050.12
Why — Adopting a uniform methodology would standardize environmental data and validate CDP's assessment tools.34
Impact — Corporate boards will face significantly higher legal accountability for their companies' environmental impacts.5
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Response to Land use, land use change and forestry – review of EU rules

3 Nov 2021

CDP Europe supports the adoption by the European Commission of the new LULUCF Regulation to guide the land use sector to contribute to the EU´s Emission reduction target. As the IPCC highlighted, 24 to 30% of the mitigation potential to keep global warming well below 2 degrees depends on the ability to stop deforestation and ecosystem degradation, whilst stimulating the restoration of degraded forest and land. Forests play a crucial role, but other ecosystems are also vital and can greatly contribute to the achievement of our climate ambitions, notably peats and wetlands. Hence, CDP Europe considers positively the broadening of the scope of the LULUCF Regulation to cover other ecosystems in addition to forests. CDP Europe values the Commission’s ambition to include non-CO2 agricultural emissions in the LULUCF in 2031 moving the EU towards reporting of Agriculture, Forestry and Other Land Use (AFOLU) emissions, but urges the Commission to establish rigorous forward-looking mechanisms mandating companies linked to the land use sector to adopt verified science-based targets, along with forests – and water-related targets, conducting scenario analysis and setting internal carbon and water prices. Companies linked to the land-use sector should adopt Science Based Targets following the Forest, Land and Agriculture (FLAG) methodology to fully incorporate deforestation and land-related emissions. Meanwhile, investors and companies should be encouraged to use existing resources to guide the decarbonisation of companies with supply chains linked to land-use as per the recommendations published in Climate Action 100’s report: https://www.climateaction100.org/approach/global-sector-strategies/food-and-beverage/ While CDP Europe welcomes the Commission’s proposed change to ensure Member States record and account for the emissions of biomass used in energy towards their 2030 climate commitments, we stress the importance of introducing accounting rules which cover the scope of bioenergy. The delegated act adopted by the Commission in October 2020 amending the LULUCF regulation established a new Forest Reference Level, but the current rules allow for increases in harvests for bioenergy. Effective regulation around the use of biofuel and biomasses for energy production is required to avoid unintended negative consequences due to the rise in demand of these resources foreseen as the EU realises its climate targets. Sustainable sourcing of materials for biofuel and biomass must take priority as anticipated pressure on land increases. The Commission must implement policy which is coherent and does not contradict wider environmental goals such as the Sustainable Development Goals and the Paris agreement. Transparency is essential to help understand the impacts this industry can have and help to discover policy intervention areas. CDP Europe is committed to supporting economic actors in their transition towards a sustainable use of land and are promoting innovative approaches such as jurisdictional and landscape approaches, in which the involvement of multiple stakeholders can ensure the scaling of actions to deliver multiple environmental, social and economic benefits. These approaches can holistically tackle various environmental issues, notably climate-change, deforestation and ecosystem degradation, biodiversity loss, water scarcity. CDP would like to promote these approaches to policy and economic actors to enhance the ability of the land-sectors to contribute to climate mitigation.
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Response to Revision of Non-Financial Reporting Directive

14 Jul 2021

CDP Europe welcomes the European Commission’s (EC) renewed NFRD and proposal for Corporate Sustainable Reporting Directive (CSRD). It is encouraging that the CSRD is TCFD aligned and seen as a platform upon which to build wide-reaching reporting standards compatible with potentially forthcoming international standards. While the CSRD requires companies to report in line with 1.5°C scenario, CDP Europe would like scenario analysis to include science-based GHG reduction targets reporting requirements included for reporting. Science-based targets ensure that companies commit to take short-term action to reduce emissions at a pace that is consistent with keeping warming below 1.5°C and make decisions in line with the latest science from the IPCC. We are pleased to see the EC expand the scope of companies covered under this initiative. Requiring more companies to report will provide the much-needed non-financial information investors require to make their portfolios sustainable. Under the chapter on ‘consolidated sustainability reporting’ CDP Europe would like to see the inclusion of reasonable assurances as well as external verifications on reported data for GHG emission. CDP Europe accepts both reasonable and high assurances in its corporate reporting requirements as it is thought this will always provide a higher level of assurance than limited and moderate assurances. We are happy to see a comprehensive set of EU sustainability reporting standards covering ESG+ and including reporting requirements on corporate strategy, implementation of targets and scenarios are to be devised by the EFRAG taskforce. Notwithstanding, we believe that deforestation should be unequivocally defined in the CSRD. While we welcome the inclusion of biodiversity and ecosystems as a standalone reporting requirement, specifying the inclusion of commodity-driven deforestation, ecosystems degradation and land use at level 1 would future-proof the reporting standards against watering them down in the delegated act. Furthermore, a more specific standard would ensure that supply chain impact on biodiversity and ecosystems is accounted for while providing consistent and reliable information required by investors and companies to adequately assess the risks and opportunities.
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Response to Supervisory data strategy

15 Jun 2021

CDP Europe welcomes the EU Commission’s initiative to improve the collection of supervisory data, especially where environmental disclosures in capital markets are concerned. As data is collected from portfolio stress testing exercises, such as the Bank of England Climate Biennial Exploratory Scenario, the systemic risks of climate change will be understood more clearly and financial supervisors will be better informed to factor them into institutions’ capital requirements, which keep the financial system stable and sustainable. Once that happens, financial institutions will have a direct and informed way of accurately accounting for and pricing in climate risk. An accurate assessment of the risk climate change poses to capital markets is reliant on consistent and harmonised data with suitable technology to handle the data. The EU Commission should align its data strategy with data consistency measures outlined in the TCFD. The figures disclosed by financial institutions are not always comparable to one another. Financial institutions are not all defining and expressing the metrics in the same way. In 2020 CDP’s report on greening finance found that 49% of financial institutions indicate they do not conduct any analysis of how their portfolio impacts the climate at all. Awareness and reporting of water issues within the financial sector is low: while 70% of responding financial institutions regard climate change as an important issue for their institution, this drops to just 22% for water security. This indicates that much of the sector’s environmental impact remains out of sight of supervisory authorities. Of the financial insitutions which do carry out analysis and report, it is clear from the disclosures that financial institutions are not using the terminology consistently; some define the metrics differently and express them in different units making comparisons difficult for data users, while other portfolio impact metrics are less well understood. An additional data consistency and harmonisation challenge is the issue of financial institutions measuring different parts of their portfolios. For data users to have comparable data, the market must coalesce and adopt more consistently the terminology used by the TCFD for these metrics. Financial institutions should also work towards reporting on more of their portfolio, while giving breakdowns by fund, asset class or sector where these are useful. CDP has provided guidance in a Technical Note on Portfolio Impact Metrics. Facilitating data consistency and harmonisation requires suitable technology to expediate comparable digital data formats. The supervisory data should be structured around agreed taxonomies and reporting requirements and standards. The format used for the data should streamline and facilitate the management of data, encouraging more data analysis and comparison against external data.
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Meeting with Frans Timmermans (Executive Vice-President) and European Environmental Bureau and

27 Oct 2020 · Business and investor support for higher ambition and the just transition

Response to Sustainable corporate governance

8 Oct 2020

CDP Europe is part of the global CDP non-profit network, that drives companies and governments to reduce their greenhouse gas emissions, safeguard water resources and protect forests. Voted number one climate research provider by investors and working with institutional investors with assets of US$96 trillion, we leverage investor and buyer power to motivate companies to disclose and manage their environmental impacts. Globally, over 8.400 companies with over 50% of global market capitalization disclosed environmental data through CDP in 2019, including more than 2.100 European companies representing approximately 76% of the European market capitalization. This is in addition to the over 950 cities, states and regions globally who disclosed – including more than 215 in Europe – making CDP’s platform one of the richest sources of information globally on how companies and governments are driving environmental change. CDP, formerly Carbon Disclosure Project, is a founding member of the We Mean Business Coalition.
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Response to Revision of the Urban Wastewater Treatment Directive

8 Sept 2020

CDP Europe is part of the global CDP non-profit network, that drives companies and governments to reduce their greenhouse gas emissions, safeguard water resources and protect forests. Voted number one climate research provider by investors and working with institutional investors with assets of US$96 trillion, we leverage investor and buyer power to motivate companies to disclose and manage their environmental impacts. Globally, over 8.400 companies with over 50% of global market capitalization disclosed environmental data through CDP in 2019, including more than 2.100 European companies representing approximately 76% of the European market capitalization. This is in addition to the over 950 cities, states and regions globally who disclosed – including more than 215 in Europe – making CDP’s platform one of the richest sources of information globally on how companies and governments are driving environmental change. CDP, formerly Carbon Disclosure Project, is a founding member of the We Mean Business Coalition.
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Elina Melngaile (Cabinet of Executive Vice-President Valdis Dombrovskis)

22 Apr 2020 · Non-financial reporting directive and disclosure requirements and European Public Databases

Response to Minimising the risk of deforestation and forest degradation associated with products placed on the EU market

4 Mar 2020

CDP Europe is part of the global CDP non-profit network, that drives companies and governments to reduce their greenhouse gas emissions, safeguard water resources and protect forests. Voted number one climate research provider by investors and working with institutional investors with assets of US$96 trillion, we leverage investor and buyer power to motivate companies to disclose and manage their environmental impacts. Globally, over 8.400 companies with over 50% of global market capitalization disclosed environmental data through CDP in 2019, including more than 2.100 European companies representing approximately 76% of the European market capitalization. This is in addition to the over 950 cities, states and regions globally who disclosed – including more than 215 in Europe – making CDP’s platform one of the richest sources of information globally on how companies and governments are driving environmental change. CDP, formerly Carbon Disclosure Project, is a founding member of the We Mean Business Coalition. For the full CDP response please see the file attached.
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Response to Climate Law

6 Feb 2020

CDP welcomes the Commission's Roadmap for putting forward a European climate law to set the framework for Europe’s economy and society to become climate-neutral by 2050. Please see our comment attached.
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Response to Institutional investors' and asset managers' duties regarding sustainability

23 Aug 2018

Please see attached file with CDP Europe's feedback. CDP Europe is a subsidiary and part of CDP Worldwide, an international non-profit that drives companies and governments to reduce their greenhouse gas emissions, safeguard water resources and protect forests. Voted number one climate research provider by investors and working with institutional investors with assets of US$87 trillion, we leverage investor and buyer power to motivate companies to disclose and manage their environmental impacts. Over 6.300 worldwide companies with some 55% of global market capitalization – including more than 1.200 in Europe – disclosed environmental data through CDP in 2017. This is in addition to the over 500 cities and 100 states and regions globally who disclosed – including 118 cities and 49 states and regions in Europe – making CDP’s platform one of the richest sources of information globally on how companies and governments are driving environmental change.
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Response to Institutional investors' and asset managers' duties regarding sustainability

21 Jun 2018

Please see attached file for CDP Europe's feedback. CDP Europe is a subsidiary and part of CDP Worldwide, an international non-profit that drives companies and governments to reduce their greenhouse gas emissions, safeguard water resources and protect forests. Voted number one climate research provider by investors and working with institutional investors with assets of US$87 trillion, we leverage investor and buyer power to motivate companies to disclose and manage their environmental impacts. Over 6.300 worldwide companies with some 55% of global market capitalization – including more than 1.200 in Europe – disclosed environmental data through CDP in 2017. This is in addition to the over 500 cities and 100 states and regions globally who disclosed – including 118 cities and 49 states and regions in Europe – making CDP’s platform one of the richest sources of information globally on how companies and governments are driving environmental change.
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Response to Institutional investors' and asset managers' duties regarding sustainability

21 Jun 2018

Please see attached file for CDP Europe's feedback. CDP Europe is a subsidiary and part of CDP Worldwide, an international non-profit that drives companies and governments to reduce their greenhouse gas emissions, safeguard water resources and protect forests. Voted number one climate research provider by investors and working with institutional investors with assets of US$87 trillion, we leverage investor and buyer power to motivate companies to disclose and manage their environmental impacts. Over 6.300 worldwide companies with some 55% of global market capitalization – including more than 1.200 in Europe – disclosed environmental data through CDP in 2017. This is in addition to the over 500 cities and 100 states and regions globally who disclosed – including 118 cities and 49 states and regions in Europe – making CDP’s platform one of the richest sources of information globally on how companies and governments are driving environmental change.
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Response to Fitness check on public reporting by companies

8 Mar 2018

CDP Europe is a subsidiary and part of CDP Worldwide, an international non-profit that drives companies and governments to reduce their greenhouse gas emissions, safeguard water resources and protect forests. Voted number one climate research provider by investors and working with institutional investors with assets of US$87 trillion, we leverage investor and buyer power to motivate companies to disclose and manage their environmental impacts. Over 6.300 worldwide companies with some 55% of global market capitalization – including more than 1.600 in Europe – disclosed environmental data through CDP in 2017. This is in addition to the over 500 cities and 100 states and regions globally who disclosed – including 118 cities and 49 states and regions in Europe, making CDP’s platform one of the richest sources of information globally on how companies and governments are driving environmental change. CDP, formerly Carbon Disclosure Project, is a founding member of the We Mean Business Coalition. CDP Europe has been involved in the various sustainable finance agendas of the European Commission since their inception and the CDP reporting standard is referenced in the non-binding guidelines on non-financial reporting and the German Climate Action Plan 2050. We commend the Commission for conducting an over-arching review of the corporate reporting framework in Europe. Given recent developments in Europe, such as the Directive on the disclosure of Non-Financial Information (NFI), the recommendations of the High-Level Expert Group on Sustainable Finance, as well as international developments, such as the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD), the time is right for a strategic review of Europe’s approach to corporate reporting. As emphasized by the EU High Level Expert Group on sustainable finance, improving corporate reporting on sustainability issues is a key enabling condition for a sustainable financial system. We would strongly recommend the European Commission to ensure that the upcoming review of the NFRD serves as an opportunity improving corporate reporting on sustainability issues and to envision a 2020 deadline for the NFRD review to be completed. We would also like to bring the Commission’s attention to the initiative CDP has taken towards mainstreaming corporate climate risk disclosure by incorporating the TCFD recommendations in the 2018 CDP questionnaires. Please find our comments in respect to questions 1 and 2 below and do not hesitate to contact us if we can be of further assistance.
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Meeting with Valdis Dombrovskis (Vice-President) and

20 Nov 2017 · Conversation on the European vision for a Sustainable Finance at CDP Europe Awards

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis)

17 Jul 2017 · sustainable finance, non-financial reporting, information on CDP Europe awards

Response to Revision of the Drinking Water Directive

23 Mar 2017

CDP’s, formerly Carbon Disclosure Project, water program acts on behalf of 634 institutional investors, representing EUR 65 trillion in assets. They use the water data collected via CDP to engage with portfolio companies, inform investment decisions and catalyze change. The program seeks water-related disclosure from the largest publicly listed companies globally, focusing only on those companies that have the greatest ability to impact on or be impacted by freshwater resources. Based on our work with private business, cities, states and regions, we suggest to take into account the following measures to improve water quality and security in Europe: EFFECTIVENESS and RELEVANCE - Include a clear reference to private sector responsibility and work across EU water and environmental policies to set context-based water targets for companies: Given that the EU is already looking to integrate the SDGs into its policy framework and current priorities of the European Commission, regulatory requirements will present opportunities to companies who can advance progress on the goals, while initially posing regulatory risk to those that are under-prepared. The commitments and targets companies set are fundamental to determining the status of water resources. However, unlike for carbon emissions, no universally accepted standard exists for the setting of meaningful and measurable corporate water targets. Water security requires collective action and coordination on shared water challenges at a local level. Meaningful targets are therefore those that are closely linked to the context within which a company’s direct operations and supply chains are located. CDP is partnering with the UN CEO Water Mandate, The Nature Conservancy, World Resources Institute and WWF to develop a common methodology that will assist companies in setting context-based targets that: Are based in science; Align with public sector efforts, particularly the targets relating to the United Nations’ 2030 Sustainable Development Goals; and Reflect the principles of water stewardship. EFFICIENCY - Increase transparency regarding water risk elements: European companies perform well when it comes to water governance issues with 76% of European companies reporting board level management, however increased disclosure on water-related issues, conducting risk assessments beyond direct operations and engaging with stakeholders is necessary to ensure future water security. Without transparency on crucial environmental metrics, it is impossible for investors – and difficult for the companies themselves – to understand the risks and opportunities they face and the steps they need to take to ensure water security. COHERENCE – Capitalize on other environmental regulations: Mandatory reporting requirements for the private sector are crucial to ensure transparency and comparability of business sector action and targets regarding water management. The Directive 2014/95/EU (Non-Financial Reporting Directive) requires public-interest entities with more than 500 employees to disclose in their management report relevant and useful information on their policies, main risks and outcomes relating to environmental matters. The ultimate objective of corporate attention to water stewardship issues is to enhance shareholder value, whether by reducing risk or seizing opportunities. Indeed, almost three-quarters (68%) of respondents report that they have identified water-related opportunities for their business. However, companies could be doing more: only 42% of those reporting opportunities to CDP also report strategies to realize them. There is a huge potential of improving the reported information under the Non-Financial-Reporting Directive in its revision in 2018 and to increase corporate water stewardship; And thus, to better support the objectives of the Drinking Water Directive and other Water policies.
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Meeting with Ann Mettler (Director-General Inspire, Debate, Engage and Accelerate Action)

26 Apr 2016 · Sustainable Development

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

23 Oct 2015 · Non-financial reporting