CDP Technical Note: Reporting on Climate Transition
Plans
CDP Corporate QuestionnaireContents
Contents..................................................................................................................................... 2
Version ....................................................................................................................................... 3
About this document.................................................................................................................. 4
1. Introduction ............................................................................................................................ 5
1.1 What is transition and why are climate transition plans important? ....................................... 5
2. Credible climate transition plans ........................................................................................... 6
2.1 CDP’s definition of a credible climate transition plan ............................................................ 6
2.2 Principles for a credible climate transition plan..................................................................... 7
2.3 Elements of a credible climate transition plan ...................................................................... 7
2.4 Coverage of CDP’s climate transition plan elements across other frameworks/standards ..... 9
3. Reporting on your climate transition plan ........................................................................... 11
3.1 Map of credible climate transition plan elements against the 2024 CDP Corporate
questionnaire.......................................................................................................................... 11
4. Further resources................................................................................................................. 15
5. Appendix - List of frameworks and initiatives related to climate transition plans ............. 15

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Version
Version

Revision date

Revision summary

1.0
2.0
3.0

February, 2022
February, 2023
June 28, 2024

3.1

August 9, 2024

First published version.
Second published version.
Question numbers updated to align with the CDP Corporate
questionnaire 2024
Question numbers corrected and mapping updated

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About this document
This technical note provides guidance on how organizations disclosing through CDP candemonstrate that they have a credible climate transition plan in place - as described in CDP’s climatetransition plan discussion paper. This understanding will support disclosure requests for 202 4 andbeyond.
CDP has also published its Financial Services Transition Plans and Net Zero Commitments technicalnote for financial institutions that would like to disclose financial sector -specific details on theirclimate transition plans.
For further information on CDP's work in this area see CDP’s Transition plan webpage.
 Part 1 broadly introduces the concept of transition, and then outlines the importance ofclimate transition plans specifically.
 Part 2 provides a technical definition of climate transition plans, the principles which govern
their credibility and the elements of a credible transition plan.
 Part 3 lists the questions in the 2024 CDP Corporate questionnaire that relate to credible
climate transition plans.
 Part 4 provides additional resources which supplement information detailed in this technicalnote.
 Part 5 lists the frameworks and initiatives which relate to climate transition plans.

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1. Introduction
1.1 What is transition and why are climate transition plans
important?
What do we mean by transition and what is a climate transition plan?
Transitioning refers to taking actions that: align a business model with a world in which two key outcomes are pursued:• global average temperature is allowed to rise by no more than 1.5°C above pre-industrial
levels.
• natural ecosystem health is restored.
 enable a thriving economy that works for people and planet in the long term.
A credible transition plan sets out how an organization will achieve the above.
Why are climate transition plans and disclosure about them important?
Organizations typically set emissions reduction targets, commit to monitoring their progress on
climate action, and reduce their exposure to climate-related risks. A climate transition plan is anencompassing instrument that helps organizations to align with the latest and most ambitious climate
science recommendations. This alignment is achieved by establishing specific strategies and clear
accountability mechanisms to track progress. While strategic planning for the future is not a new
instrument, the extent of climate transition and the hard limits set on such a transition throughscientific discoveries mean that climate transition plans are often a critical element in ensuring afuture for the organization. During 2023 there were several developments that increased the urgency
for organizations to develop and disclose credible climate transition plans.
 Following on from COP27, several updates have come out of COP28:• The Global Stocktake text called on parties to contribute to the transition away from fossil
fuels in energy systems. This headline conclusion is an explicit sign that organizations needcredible transition plans to ensure decarbonization in line with a 1.5 °C-aligned world.
• The International Sustainability Standards Board released a COP28 Declaration of Support(ISSB), gaining signatories from almost 400 organizations, to commit to advancing the
adoption and/or use of the ISSB’s climate-related reporting, including transition plan-related
requirements.
• The Taskforce on Net Zero Policy was announced. The focus of the Taskforce will be toensure the credibility and accountability of 1.5°C-aligned net zero emissions commitments
by non-state actors. The Taskforce aims to build upon the work of the UN Secretary General’sHigh Level Expert Group’s (HLEG), 2022 “Integrity Matters” report.
 The need for a climate transition plan has also been accelerated by the evolving regulatory
landscape.
• The United Kingdom’s (UK) Transition Plan Taskforce (TPT) published its final version of
its foundational document, with the UK Financial Conduct Authority (FCA) now exploring
how this guidance can support organizations disclosing transition plans under IFRS S2.
• The European Union’s (EU) Corporate Sustainability Reporting Directive (CSRD), first
introduced in 2021 and formally adopted in January 2023 establishes reporting guidelines
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•on how companies should communicate information on their sustainability effort andpractices. The CSRD requires large companies (more than 500 employees) in the EU todisclose on their transition plans for climate change mitigation and their plans to ensurethat their business model and strategy are compatible with the respect of planetary
boundaries of the biosphere integrity and land-system change.
In 2022, the EU Commission submitted a proposal for a new directive on Corporate
Sustainability Due Diligence (CSDDD) to the European Parliament and Council, which
was adopted in December of that year. The aim of the CSDDD is to enhance theprotection of the environment and human rights in the EU and globally, by imposing
mandatory due diligence procedures across their operations and value chains. A key
facet of the CSDD is not only the requirement for organizations to develop a transition
plan, but also the requirement to implement it.

2. Credible climate transition plans
A credible climate transition plan is one that sets out how a business will position itself to thrive in a
1.5°C world.

2.1 CDP’s definition of a credible climate transition planA credible climate transition plan is a time-bound action plan that outlines how an organization willachieve its strategy to pivot its existing assets, operations, and entire business model towards
a trajectory aligned with the latest and most ambitious climate science 1 recommendations,
i.e., halving greenhouse gas (GHG) emissions by 2030 and reaching net-zero by 2050 at the latest,
thereby limiting global warming to 1.5°C.
Based on CDP data and research into established frameworks, CDP considers a credible climatetransition plan to be defined by the five following characteristics:
 It supports a strategy for the climate transition i.e., actions that need to occur for an organization
to pivot towards a 1.5°C world, with five- to ten-year near-term science-based targets (SBTs),i.e., emissions reduction targets in line with 1.5°C pathways. Along with long-term SBTs, which
aim to achieve net-zero by 2050 at the latest.
 It contains verifiable and quantifiable key performance indicators (KPIs) which:• measure the success of an organization’s climate transition; and• are tracked regularly.
 It is succinctly integrated into an organization’s existing mainstream filings (in annual financial
reporting/sustainability reporting/overall business strategy) 2, and provides an accountability
mechanism.
 It is guided by the principles outlined in section 2.2.
 It contains the key elements outlined in section 2.3.
These criteria demonstrate to investors and other stakeholders that an organization is aligning with
ambitious long-term climate goals, and that its business model will transition, in order to be relevant(i.e., profitable) in a 1.5°C world. To avoid potential regulatory shocks, organizations should aim toalign, as a minimum, with relevant Paris-aligned policy goals for where the organization operates
1

As communicated by scientifically reliable and reputable institutions such as the Intergovernmental Panel on Climate Change (IPCC)
and the Science Based Targets initiative (SBTi).
2
The exact reporting system utilized may vary by organization. For better accountability, (1) ease of integration and (2) reporting frequency
should be the key factors used to assess where to integrate the transition plan.

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(this includes direct and value chain operations). Given the number of countries that have committed
to net-zero emissions, it is critical that investors and other stakeholders are able to assess anorganization’s plans to align with such a future (refer to NetZero tracker).

2.2 Principles for a credible climate transition plan
CDP has developed six fundamental principles that will guide the preparation of a credible climatetransition plan:
1. Accountability: The plan has clearly defined roles and responsibilities. This includes effective
governance mechanisms, where the board and C-suite executives are accountable for
implementation of the plan.
2. Internally coherent: The plan is integrated into the business strategy and financial planning of
the organization.
3. Forward looking: The plan should reflect considerations of the short- and long-term, trending
towards 2050. However, an emphasis on the short-term (the next 5-year timeframe) is critical toachieve long-term climate ambitions, which should be supported by governance mechanisms(new or existing).
4. Time bound and quantitative: The plan’s KPIs are quantifiable and are outlined for defined
timeframes.
5. Flexible and responsive: The plan is reviewed and updated regularly 3, with a defined
stakeholder feedback mechanism in place (e.g., shareholders, at AGMs).
6. Complete: The plan covers the whole organization and its value chain, i.e., any exclusions fromthe plan must not be material to the organization and/or its impact on the natural environment(ensuring the double materiality principle applies to disclosure of exclu sions).

2.3 Elements of a credible climate transition plan
The key elements of a climate transition plan are described below, and they are the outcome of an
extensive technical review.
The table below indicates how each element relates to the TCFD’s 2021 update to its report on“Implementing the Recommendations of the Task Force on Climate-related Financial Disclosures(2017 annex)” to provide additional guidance on disclosing metrics, targets, and climate transition
plan information in line with the TCFD recommendations.

3

In alignment with the 2021 update to the TCFD’s recommendations, with its integration of transition plans, transition plans s hould at aminimum be reviewed every five years for continuous relevancy and efficacy and updated if required. The TCFD also notes that progressagainst the plans should be reported annually, alongside any material, substantive changes to the plan be reported
annually (if required)

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Transition Plan
Element

GOVERNANCE

Description

TCFD Pillar

This demonstrates that an organization has board-level
oversight of the climate transition plan and that there aredefined governance mechanisms in place, to ensure
implementation of the plan.

Governance

SCENARIOANALYSIS

A climate transition plan should be underpinned by robust
scenario analysis4 used to identify potential substantive
climate-related risks and opportunities.

FINANCIALPLANNING

As part of its strategy to achieve net zero, an organization
should outline time-bound financial planning details of its
transition. For example, Capital Expenditure (CAPEX),
Operating Expenditure (OPEX), Revenue, etc.

VALUE CHAINENGAGEMENT &LOW-CARBONINITIATIVESStrategy

A climate transition plan should include time-bound actions
to decarbonize business processes (and those of its value
chain), with time-bound KPIs. This includes three distinct
elements5:(1) value chain engagement;(2) increasing the share of revenue from low-carbon
products and services; and(3) implementing emissions reduction initiatives for both its
direct and indirect operations.

POLICYENGAGEMENT

A climate transition plan should demonstrate thatan organization's public policy engagement 6 aligns with its
climate commitments and strategy.

RISKS &OPPORTUNITIESA climate transition plan should outline an organization’s
process for addressing identified climate-related risks andRiskmaximizing substantive climate-related opportunities.
Management

TARGETSA climate transition plan should contain time-bound,verified science-based targets which are in line with thelatest climate science. Organizations should set near-term
SBTs to halve emissions by 2030 and should also set a
net zero long-term target – by 2050 at the latest.

A climate transition plan should be accompanied by anannual Scope 1, 2 & 3 emissions inventory that is
SCOPE 1, 2 & 3
ACCOUNTING WITH complete, accurate, transparent, consistent, relevant, andverified by a third-party.
VERIFICATION7

Metrics &Targets

4

While the scenario analysis is not the plan, it helps to set the temperature target and the implications will inform the risk s & opportunities
which the strategy seeks to address.
5
The focus should be on the most relevant parts of the value chain – not necessarily all three distinct elements will be relevant for every
sector/organization.
6
Public policy engagement includes direct policy and lobby group engagement .
7
The inventory accounting includes emissions and energy sources accounting .

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2.4 Coverage of CDP’s climate transition plan elements across other frameworks/standards
The table below shows the extent to which the CDP Corporate questionnaire covers the elements of a credible climate transition plan, as set out in otherframeworks/standards. Please note: At the time of this publication, some of the mapped standards/frameworks exis ts only as draft recommendations.

Table 1: Mapping climate transition plan elements to existing frameworks.

Standards/Frameworks/Initiatives
CDP credible climate transition plan elements

IFRS(ISSB)

SEC

Board level oversight
Board expertise on climate-related issues
Governance

Executive management accountability & feedback mechanisms
Executive incentives linked to climate
performance indicators

Strategy to achieve
Net
Zero
Scenario Analysis

Existence of a "1.5°C world" aligned transition plan within businessstrategy & shareholder feedback
Link between identified (and potential) climate-related risks,
opportunities & company strategy
Details of scenario analysis
Financial planning details associated with a 1.5°C world

Financial Planning

Low carbon products or services

Value chain
engagement & Lowcarbon initiatives

Low carbon initiatives - direct operations

Policy engagement

Alignment of public policy engagement with climate ambition &strategy
Process for identifying climate-related risks & opportunities

Risks & Opportunities

Value chain engagement

Climate-related risks - risks, potential financial impact and response
strategy
Climate-related opportunities - opportunities, potential financial
impact and response strategy
Emissions reduction targets - absolute & intensity

Targets

Other climate-related targets
Net-zero targets

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EFRAG (ESRS)

TPT

GRI

GFANZ

Scope 1, 2 &3
accounting
with verification

Comprehensive and third-party verified emissions accounting

Full coverage
There is at least full coverage between CDP’s Corporate questionnaire and the disclosure requirement set by this framework/standard i.e., CDP’s questionnaire meets (and in some cases,
exceeds) the disclosure requirement set by this framework/standard.

Partial coverage
There is partial coverage between CDP’s Corporate questionnaire and the disclosure requirement recommended by this framework/standard.

Not applicable
The mapped standard/framework does not require the disclosure of this information – whereas CDP’s Corporate questionnaire does.

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3. Reporting on your climate transition plan
CDP’s Corporate questionnaire collects data on the climate transition plan elements. Questions
which align directly to the climate transition plan elements (as currently defined above) are set out
below.

3.1 Map of credible climate transition plan elements against the2024 CDP Corporate questionnaire
To demonstrate a credible climate transition plan and existing efforts to transition to a 1.5°C world,
an organization should report on the direct and supporting questions with in the CDP Corporate
questionnaire, such as those outlined below:
 DIRECT INDICATORS (*): These questions allow organizations to indicate that their climatetransition plan includes forward-looking and quantitative information, such as associatedfinancial planning details and climate-related targets. This also refers to questions that
explicitly mention “climate transition plans” in the questionnaire.
 SUPPORTING INDICATORS: Beyond the direct indicators, other CDP questions allow
organizations to report actions and data that evidence the robustness and credibility of theirclimate transition plan, such as the foundational elements of governance for example. These
supporting indicators are not necessarily forward looking but allow organizations to report
information that complements their climate transition plan, e.g., activities and data such as
emissions accounting and verification, or how climate has impacted their strategy or
engagement in the reporting year.
The table below maps the 2024 CDP Corporate questionnaire question numbers (direct andsupporting indicators) to the key elements of a credible climate transition plan (in section 2.3) . For
further information on the following questions please see CDP’s Guidance for Companies
Climate Transition
plan element
GOVERNANCE

Aligned 2024 CDP
question number
4.1.1, 4.1.2(Board level oversight)

4.2(Board expertise on
climate-related issues)

4.3, 4.3.1(Executive
management
accountability &feedback mechanism)

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Relevance
To ensure accountability for developing an
ambitious plan as well as implementation of
the plan’s ambitions, board level oversight ofthe climate transition plan is crucial insteering business strategy towards a 1.5°Caligned trajectory.
Addressing climate change requires specificexpertise related to climate change and its
impacts, and the potential direct and indirect
effects on the business. Ensuring thiscapability exists within governance structuresindicates an organization’s competence indelivering on its climate transition plan andincreases the chance of success.
Executive management have responsibilityfor (1) developing a climate transition plan,and (2) frequently reporting to the board on
progress towards realizing the plan’s
ambitions.

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Climate Transition
plan element

STRATEGY8SCENARIOANALYSISFINANCIALPLANNING

Aligned 2024 CDP
question number
4.5, 4.5.1(Executive
management incentives
linked to climate
performance indicators)
5.2*(Existence of “1.5°C
world” aligned transition
plan within businessstrategy & shareholder
feedback)

Relevance

7.74, 7.74.1(Low-carbon products
or services)

Organizations can develop their low-carbon
products or services portfolio over time tosignal how they intend on transitioning their

To incentivize conscious action andcommitment in implementing the plan, it isrecommended that executive management
incentives are linked to climate performanceindicators.
An organization’s climate transition planshould: be aligned with a 1.5°C world: tosignal climate ambition.
 be publicly available: to demonstratetransparency.
 integrated into the businessstrategy: to fulfil the principle ofinternal coherence.
 haveadefinedshareholder
feedback mechanism: to incentivize
regular feedback collection.
Here, organizations can explain how climate5.3.1
related risks and opportunities influenced(Link between identified their strategy and climate transition plan,(and potential) climate- specifically in areas of products/services,
related risks,
value chain, investment in R&D andopportunities &operations.
company strategy)
5.1, 5.1.1, 5.1.2
Scenario analysis is used as a strategic tool
(Details of scenario
to inform the development of the climate
analysis)transition plan, based on several potential
future climatic states.
5.3.2, 5.4*, 5.4.1*
Financial planning is crucial when
(Financial planningdemonstrating that an organization is aligning
details associated with with climate goals (as elaborated in its
a credible climate
climate transition plan), and that it will betransition)
relevant (i.e., profitable) in a 1.5°C world.
Organizations can use these CDP questions
to demonstrate how they have aligned theirfinancial planning with their climate transition
plan in the reporting year and at milestone
years ‘2025’ and ‘2030’. Financial details
may describe revenue, CAPEX, and/or OPEX
projections which are crucial for realizing theplan’s ambition.

8

Strategy is not an individual element of a climate transition plan – instead, the transition plan is how an organization achieves its
strategy to pivot towards a 1.5C aligned trajectory. The inclusion of strategy in this table is due to the fact that it appea rs as a module in
CDP’s questionnaire and contains a number of key indicators which provide information on an organization’s climate transition plan.

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Climate Transition
plan element

VALUE CHAINENGAGEMENT &LOW-CARBONINITIATIVES

Aligned 2024 CDP
question number

7.55.2(Low-carbon initiatives– direct operations)5.11, 5.11.1, 5.11.2,
5.11.5, 5.11.6, 5.11.7,
5.11.9(Value chain
engagement)

POLICYENGAGEMENTRISKS &OPPORTUNITIES

4.11, 4.11.1, 4.11.2(Alignment of public
policy engagement withclimate ambition &strategy)

2.2.1, 2.2.2(Process for identifying
climate-related risks &opportunities)

3.1, 3.1.1(Climate-related risks –risks, potential financial
impact and response
strategy)
3.6, 3.6.1(Climate-related
opportunities –opportunities, potential
financial impact andresponse strategy)
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Relevance
existing revenues, operations, and entire
business model towards a 1.5°C trajectory.
One of the key elements of a climatetransition plan is that it contains time-boundactions to decarbonize business processes
and implement emissions reduction
initiatives.
Organizations are facing risks in the value
chain that have material environmental andfinancial implications; hence, value chain
engagement plays a significant role inrealizing a climate transition plan. For
example, organizations with significant
emissions in their supply chain can leverage
their buyer power and engage their suppliers
on developing their own transition plan whichaligns with 1.5°C world.
Ensuring that an organization’s climatetransition plan is supported by fully aligned
external policy engagement (policy, law,regulation, and trade associations)demonstrates an ambitious effort towards
achieving a 1.5°C world. For manyorganizations, a successful climate transition
will depend on an accommodative policy
landscape, thus companies should advocate
for climate-positive policies that impact theirrelevant sector(s) and are consistent with
their climate transition plan. Organizations
should also lobby against climate-negative
policies which could affect their ability totransition.
To demonstrate forward planning (which is
crucial for a climate transition plan), an
organization’s transition plan should include
or reflect a process for identifying, assessing,and responding to climate-related risks andopportunities.
Details of the risks posed to an organization
by climate-related issues, and the estimatedpotential financial impact of these risks at thecorporate level, as well as the response
strategy to manage these risks.
Details of the opportunities posed to anorganization by climate-related issues, andthe estimated potential scale of theseopportunities at the corporate level as well as
the response strategy required to takeadvantage of these opportunities.
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Climate Transition
plan element
TARGETS

Aligned 2024 CDP
question number
7.5.3*, 7.53.1*, 7.53.2*(Emissions reduction
targets – absolute &
intensity)

7.54.1*, 7.54.2*(Other climate-related
targets)
7.54.3*(Net-zero target)

7.5, 7.6, 7.7, 7.8, 7.9.1,
SCOPE 1, 2 & 3
7.9.2, 7.9.3
ACCOUNTING, WITH (Comprehensive and
VERIFICATION
third-party verified
emissions accounting)

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Relevance
The plan includes near- and long-term,
verified science-based targets which are inline with the latest climate science to reach a
1.5°C world, with time-bound KPIs. Where
this is not feasible, the targets should align to
CDP recommended best practice.
Ambitious climate transition plans will include
other climate-related targets, including, but
not limited to, increased low-carbon energy
consumption or production targets.
The plan includes a net zero target, in linewith the latest climate science, with timebound KPIs. Third-party verification isconsidered best practice.
A climate transition plan should beaccompanied by a complete, accurate,transparent, consistent, and relevant
inventory of all three scopes of emissions.
Any individual organization may find it
important to fully disclose to Sections
Emissions Methodology and Exclusions andScope 1, 2, and 3 Emissions Inventory• Third-party verification is necessary
for credibility and transparency on
progress against a climate transitionplan.
• Companies should calculate anddisclose all material categories ofscope 3 and provide an explanation
for categories that are not relevant.

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4. Further resources
 CDP’s discussion paper on climate transition plans (2021)
 Examples of corporate climate transition plans (note: inclusion in this list does not imply anassessment by CDP that these plans are ‘credible’).
• SSE Net zero transition plan
• Aviva’s Climate Transition Plan
• Unilever Climate Transition Action Plan
• Aena Climate Action Plan

5. Appendix - List of frameworks and initiatives related
to climate transition plans
The following frameworks and initiatives informed CDP’s approach to Climate Transition plans:
 Task Force on Climate-Related Financial Disclosures (TCFD)
 Climate Safe Lending Network (CSLN) Assessing low-Carbon Transition (ACT) Climate Action 100+
 Say on Climate initiative [CIFF] Oxford Martin Principles for Climate-Conscious Investment
 Alliance for Corporate Transparency Australasian Centre for Corporate Responsibility (ACCR)
 The International Capital Market Association (ICMA) Glasgow Financial Alliance for Net Zero (GFANZ)
 The Institutional Investors Group on Climate Change (IIGCC)
 Investor Climate Action Plans (ICAPs)
 Transition Pathway Initiative (TPI) Climate Bonds Initiative (CBI) UK Transition Plan Taskforce (UKTPT)

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