ARE COMPANIES DEVELOPING
CREDIBLE CLIMATE
TRANSITION PLANS?
Disclosure to key climate transition-focused indicators
in CDP’s 2022 Climate Change Questionnaire

February 2023

Contents

03

Key findings

04

Introduction

06

Disclosure to key transition-focused indicators

09

Industry trends

11

Geography trends

13

Element-level trends

20

Conclusion

21

Appendix

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Key findings

12
3

4,100 of them disclosed that they had already developed a 1.5°C-aligned climate transition plan.
Of these 4,100 organizations, 81 of them reported sufficient detail to all 21 key indicators in
the climate change questionnaire that align with a credible climate transition plan. These 81
organizations represent 0.4% of the entire disclosure sample in 2022 (18,600+).
In our 2021 assessment of climate transition plan disclosure, 135 organizations met
the disclosure criteria to all key indicators. The reduction seen this year is based on CDP
strengthening the disclosure criteria for what constitutes a credible climate transition plan byupholding them to 1.5°C alignment.

4

6,520 organizations reported that they plan on developing a climate transition plan within

5Over 60% of all disclosing organizations fall within the ‘few’ threshold of credible climate

6

More than a third of the disclosing organizations met the disclosure criteria for the risks &7

In contrast, financial planning, targets, and strategy to achieve net-zero were the poorest

8

Across the 13 industries assessed, power generation and infrastructure were the front runners

910
3

In 2022, 18,600+ organizations disclosed through CDP’s climate change questionnaire, of which

two years.

transition plan disclosure, i.e., these organizations disclosed to less than seven of the key
indicators of a credible climate transition plan.

opportunities element of a credible climate transition plan – this was followed closely by thegovernance element (24%) and the policy element (19%).

performing elements of a credible climate transition plan with 3%, 4% and 7% of organizations
meeting the disclosure criteria in these respective elements.

with 2.2% and 1.7% of all organizations in each of these industries disclosing against all 21 key
indicators of a credible climate transition plan.
The apparel, fossil fuels, and hospitality industries had the poorest levels of disclosure with only
one organization in each of these industries disclosing against all the 21 key indicators of acredible climate transition plan. Of the key industries identified, the best and worst performing
elements were consistent with the trends identified in key findings 5 & 6.
Whilst no geography had an outstanding record, Japan leads the regional assessment with 16
Japanese organizations disclosing to all 21 key indicators of a credible climate transition plan.

Introduction

This report provides an overview of the current state of climatetransition plan information disclosed through CDP's 2022 climatechange questionnaire. The data analyzed in this report spans over
18,600 organizations in 13 industries and across 135 countries.
While this report is not an assessment of an organization’s climate transition towards a
1.5°C-aligned world – it is an evaluation of whether an organization’s disclosure is sufficientand credible. By strengthening the criteria for what makes a credible climate transition plani.e. enforcing that a plan must be aligned to 1.5°C and have a rigorous target, CDP continued
to raise the bar in this year's assessment of what is considered a credible climate transition
plan. This report focuses on climate transition plans, but CDP recognizes that climate is
only a facet of a wider, environmental challenge and the critical need for organizations toinclude nature in their thinking and broader transition planning. As such, we will include wider
environmental indicators when defining a credible transition plan in the future.
Across the globe in 2022 we saw an increase in value placed on organizations disclosing
and developing transition plans. In the US, the Securities and Exchange Commission(SEC) proposed climate disclosure regulation, including disclosure of climate targets
and transition plans. Regulation set to be implemented in the European Union (EU) will
also require disclosure of climate transition plans, as outlined in the draft European
Sustainability Reporting Standards (ESRS). Similarly, the publication of the International
Sustainability Standards Board’s (ISSB) Exposure Drafts on climate and generalsustainability-related financial disclosures proposes a range of disclosures around anorganization’s transition plans. Other industry-led coalitions including the Taskforce on
Climate-Related Financial Disclosures (TCFD) and the Glasgow Financial Alliance for Net
Zero (GFANZ) are also applying pressure on organizations and financial institutions todevelop and disclose transition plans. Most recently at COP27 in November 2022, the
UK Transition Plan Taskforce (UK TPT - convened by the UK government post COP26)
released the first draft of its Disclosure Framework, outlining requirements from publicly
listed organizations and financial institutions in the UK to publish their climate transition
plans. In January 2022, the FCA introduced rules for listed companies and large regulated
asset owners and asset managers to disclose transition plans as part of their TCFD aligned
disclosures, initially on a comply or explain basis. The first disclosures under these rules
will be made in 2023. The UK TPT’s outputs will support UK firms and companies to publish
high quality plans under existing rules. Please see CDP's Technical Note for the alignment
between the identified elements of a credible climate transition plan and the various
incoming mandatory disclosure recommendations.
This evolution towards policy regulation demonstrates the increasing pressure onorganizations and financial institutions to improve and outline their transition plans.
Considering incoming regulation (as of December 2021) around transition disclosure, thisreport also reflects global readiness amongst existing disclosers.

4

In November 2021, CDP pioneered a discussion paper on climate transition plans, in which we identified thefollowing key elements that constitute a credible climate transition plan:

Governance

Scenario analysis

Financial planning

Value chain engagement &low carbon initiatives

Policy engagement

Risks & opportunities

Targets

Scope 1, 2 & 3 accounting
with verification

These elements can be evidenced through the disclosure to 21 key indicators dispersed throughout the 2022
climate change questionnaire1 (see Appendix). The questionnaire collects data disclosed through these indicators,
and this is the basis on which CDP has established credible climate transition plan disclosure – please refer to
CDP’s Technical Note on climate transition plans for more detail.
A climate transition plan is a time-bound action plan that clearly outlines how an organization will achieve its
strategy to pivot its existing assets, operations and entire business model towards a trajectory that aligns withthe latest and most ambitious climate science 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. Environmental
disclosure alone is not enough – it needs to lead to accountability and transformation; hence the relevance ofclimate transition plans as part of a business’s strategy.

1. In the 2021 version of this report, the assessment outlined 24 key climate transition indicators in the 2021 questionnaire – however, due to the ongoing evolution of the climate change
questionnaire, these indicators have been streamlined to 21. Please note, despite these questionnaire revisions, the same (and in some cases, more) information can still be reported
on, in these 21 indicators, when compared to the 24 indicators in the 2021 assessment. These 21 indicators are only a core subset of a wider set of transition relevant indicators in the
climate change questionnaire5Disclosure to key transition-focused indicators

4,100

organizations disclosed
through CDP that they
have a 1.5°C-aligned
climate transition plan.
Over

28%

of all disclosing
organizations in the
power generationindustry reported
developing a public
climate transition planwith a shareholder
feedback mechanism
in place.

Disclosure of climate transition plans and strategy
In 2022, 4,100 organizations disclosed through CDP that they have a
1.5°C-aligned climate transition plan2. Of the organizations who reported
to have developed a 1.5°C-aligned climate transition plan, only 1,751 ofthem reported that it was publicly available, and that there was a welldefined mechanism in place to collect feedback from shareholders. Evenamong leading organizations more transparency is needed to be responsive
to stakeholder feedback. Alarmingly, 3,341 organizations indicated that
their strategy has been influenced by climate, but they do not intend
to develop a 1.5°C climate transition plan. However, it is encouraging to
see that 6,520 organizations reported that they are developing a climatetransition plan within two years. We expect to see significant improvementin the quantity and quality of transition plans over the coming years.
Over 28% of all disclosing organizations in the power generation industry
reported developing a public climate transition plan with a shareholder
feedback mechanism in place, the highest of any industry. This represents
a promising trend from one of the most important industries to lead theclimate transition. Similarly, 26% of all disclosing financial institutions
reported developing a public climate transition plan with shareholder
feedback mechanisms in place, signaling strong ambition from an industry
with great influence over the whole economy’s transition. Conversely,
manufacturing, services, food & beverage, hospitality, and biotechnology
are lagging with less than 9% of disclosing organizations in these industries
reporting a public climate transition plan with shareholder feedback
mechanisms in place.
In 2022, 5,552 organizations disclosed that climate issues have influenced(or that evaluation was in progress) their supply chain and/or value
chain, products and services, operations, and investment in research &development (R&D). Of these, less than half also reported developing a
climate transition plan aligned to a 1.5°C world, and only 1,307 of theseare publicly available with shareholder feedback mechanisms in place.
This suggests that many organizations have not yet developed a climatetransition plan that will demonstrate to capital markets, customers, andother stakeholders how they plan to mitigate climate risks and realize
opportunities of aligning with a 1.5°C world. This represents a gap of 444
organizations that do not support their climate transition plan with robust
disclosure on how it will impact each aspect of their business strategy.

2. This statistic references data which was extracted from the CDP platform, as of 18 October 2022.
6

Summary of disclosure to all key indicators
Along its sustainability journey, an organization will typically set emissions reduction targets, commit to monitoring
its progress on climate, and reduce its exposure to climate-related risks. Over the past 20 years, CDP has played
a transformational role in driving disclosure and action from businesses, capital markets, cities, and governments
around the world – through its disclosure platform and scoring methodology. Further to these actions, a climatetransition plan serves as a strategic planning instrument that helps organizations align their various climate
actions. An organization should disclose sufficient details to all 21 key climate transition-focused indicators todemonstrate the robustness and credibility of its climate transition plan and track the progress of its transition to a
1.5°C world.
Although this level of disclosure is critical, many organizations are failing to disclose to all the key indicators. 12.6%of the organizations reporting through CDP have many elements of a credible climate transition plan, however
only 81 (0.4%) of them disclosed sufficient detail to all key indicators. Whilst over 4,100 organizations disclosedthat they had developed a 1.5°C-aligned climate transition plan, only a small minority of these are demonstrating
through their disclosure, that they have a credible plan in place. With a 40% increase in overall disclosure whencompared to the 2021 disclosure cycle, it is rational to expect the new organizations to be at the start of theirtransition journey and therefore not yet have a credible climate transition plan. Going forward, as these disclosuresand their implementation mature, we expect their quality to also improve. CDP regularly raise the bar for what
qualifies as environmental leadership in line with emerging science, feedback from stakeholders, and market needs
for greater environmental transparency. This is evidenced by the reduction seen in the number of organizations who
disclosed against all the key indicators in the climate change questionnaire (135 in 2021). This reduction is due tomore stringent criteria on 1.5°C alignment from companies.

7

Distribution of disclosure to all 21 key indicators
Figure 1. 2022 disclosure to climate transition plan indicators – by disclosure tier

3,541

12,7372,244

81
Few (0-33%)

Some (33-66%)

Many (67-99%)

All (100%)# Total number of organizations
Organizations have been categorized into four tiers, based on their level of credible disclosure against the 21
key indicators – please see Appendix for a detailed breakdown of these relevant tiers. The ‘few’ tier represents
organizations that have disclosed against up to 33% of the key indicators, the ‘some' tier represents organizationsin the 34%-66% range, the ‘many’ tier represents organizations in the 67%-99% range and the ‘all’ tier represents
organizations who disclosed to 100% of the key indicators of a credible climate transition plan.
The largest proportion of all disclosing organizations fall within the ‘few’ tier, representing 68% of allorganizations that disclosed through the climate change questionnaire in 2022. The ‘few' tier is followed by the‘some’ tier with 19% of disclosing organizations falling within this tier. Combined, these bottom two tiers represent
87% of all disclosing organizations, demonstrating that a large group of disclosers are failing to disclose to manyor all of the transition-relevant indicators. This leaves 13% of organizations that disclose to many of the climatetransition plan indicators and 0.44% disclosing to all indicators. Most organizations have a long way to go to
improve transition-relevant disclosures in their CDP climate change response.
Organizations that disclosed that they have developed a public 1.5°C-aligned climate transition plan with defined
shareholder feedback mechanisms predominantly disclosed to many indicators of a credible climate transition
plan, with 949 organizations disclosing within this tier.

8Industry Trends

Summary of industry trends
The top industries that made up the 81 organizations who reported against all key indicators include: services,manufacturing, materials, and infrastructure. Influential organizations in high-emitting industries are not changing
their business models fast enough. This risks making global targets unachievable unless they accelerate their rateof change.
To better understand climate transition plan disclosure performance across various industries, CDP analyzed
overall industry disclosures.
Figure 2. Industry breakdown across disclosure tier - climate transition plan indicators
Percentage
10%0%Apparel

457

Biotech, health care & pharma

479

Financial services

20%

30%

40%

50%

60%

70%

80%

100%

662

Food, beverage & agriculture

1038

Fossil Fuels

271

Hospitality

111

Infrastructure

719

International bodies

8

Manufacturing

7443

Materials

1670

Power generation

228

Retail870

Services

3717

Transportation services

930

0

6000

4000

2000

Number of organizations
Few

9

90%

Some

Many

All

Total organizations

8000

Power generation and infrastructure had the highest disclosure rate3 with 2.2% and 1.7% of all organizations
in each of these industries disclosing to all 21 key indicators of a credible climate transition plan. This
demonstrates a significant gap within all industries. Apparel, fossil fuels and hospitality had the poorest rate ofdisclosure with only one organization in each of these industries disclosing to all key indicators.
However, there are some promising trends. The industries with the strongest disclosure rates to many or all of the
key indicators were power generation with 38% and financial services with 35%. It is critical that power generation
organizations and financial institutions continue to develop more robust and credible climate transition plan
disclosures in order to facilitate and finance a transparent climate transition.
To negate the risk of not meeting our global climate ambitions, more pressure needs to be applied to organizationsin the fossil fuels industry. In 2021, fossil fuels were among financial services and power generation as the leadingindustries in climate transition plan disclosure with 5% of organizations in their industry disclosing to all key indicators.
However, the decrease in transparency from fossil fuel organizations (now with only one organization disclosing
to all key indicators) in this year’s analysis is concerning, as they are falling behind key value chain partners (power
generation and financial services). With global energy demand expected to rise by population and economic growthparticularly in developing economies, it is vital that there is an increase in disclosure to help mitigate the transition
being derailed in an attempt to meet increased energy demand.

3. Disclosure rate = Total number of disclosures in the threshold as a proportion of total disclosure (across all thresholds), per industry.
10

Geography Trends

We recognize the complexity of assessing regional disclosures, hence this section of the report does not present
any analysis on the underlying factors/broader implications of the trends identified from this regional assessment.

Summary of geography trends
Organizations headquartered in over 135 countries disclosed through CDP in 2022. When evaluated for disclosure
to all key indicators of a credible climate transition plan, Japan was the leader with 16 organizations. Japan was
also the leading country in the 2021 assessment of the disclosure of credible climate transition plans.
Please see Figure 3, below, for a regional breakdown of disclosure performance to the key climate transition plan
indicators.
Figure 3. Disclosure performance, by country/region (Top 20)
4000

100%
90%

3718

80%

Percentage

60%
50%

2000

2037

40%

1695
1448

30%

1310

1000
975

20%

578

10%

547

500

481

425

390

244

Some

Many

224

193

186

183

172

166

Sp
ai
n
Ca
na
da
Sw
ed
en
Sw
itz
er
la
N
nd
et
he
Ho
rla
ng
nd
Ko
s
ng
,C
hi
na
Au
st
ra
lia
Tu
rk
ey
Fi
nl
an
d

a
di

322

Ko
re
a
M
ex
ic
o

of

In

Re

pu
bl
ic

ce

hi
na

w

an

,C

ly

Fr
an

Ta
i

Ita

Br it
Ch
ita ed
in
a
in Ki
an ng
d do Ja
N m por o an
th f
er Gr
n ea
Ire t
la
n
Br d
az
il
Ge
rm
an
y

Few

11

378

Un

Un

ite

d

St

at

es

of

Am

er

ic
a

0%

All

Total organizations

0

Number of organizations

3000

70%

G20 narrative
According to The Climate Transparency 2022 Report, the G20 is responsible for approximately 75% of GHG
emissions. In 2022, research found that energy emissions rebounded 5.9% to above pre-pandemic levels. To
prevent the global temperature rising above 1.5°C and halve emissions by 2030, the G20 has an important role toplay. Worryingly, no organizations from countries in the G20 other than Portugal, had a disclosure rate higher than
2% when assessed for disclosure to all 21 key indicators. Several organizations from countries such as Canada andChina had no disclosures meet the criteria on all key indicators. However there are more encouraging signs whenlooking at disclosure to many (14 - 20) of the key indicators. Please see the Appendix for total regional disclosure(and tier breakdown).

UK
Given that the UK government will be making disclosure of transition plans for publicly listed organizations andfinancial institutions mandatory in 20234, a marked increase in UK climate transition plan disclosure is expected.
Out of the 1,448 UK organization that disclosed through CDP in 2022, 28% (404) reported having developed a
1.5°C-aligned climate transition plan. Of these 404 organizations, six disclosed to all 21 key indicators. 15% (212)of all UK organizations disclosed to many of the key indicators. Concerningly, most UK organizations (960) were in
the few threshold, having disclosed to less than a third of the key indicators.
CDP has worked and continues to collaborate with the UK TPT in its mandate to establish best practice for firmlevel transition plans. CDP’s research, data and disclosure guidance aims to support the UK TPT’s ambition to help
UK organizations and financial institutions to improve the quality of transition plan disclosure.

4. From 2023 – 2024, the Financial Conduct Authority (FCA) plans to consult on changes to its Listing Rules to reference ISSB standards, expected to be adopted in the UK once finalized.
The FCA intends on considering UK TPT outputs as a basis to strengthen its transition plan disclosure expectations of listed companies, asset managers and FCA-regulated asset
owners.
12

Element-level trends

Figure 4 shows the percentage of all disclosing organizations that disclosed sufficient detail for each individual
element of a credible climate transition plan. The chart compares disclosure trends using two groups:{ Group 1 – Entire disclosure group: The 18,600 + organizations who disclosed through the climate change
questionnaire in 2022
{ Group 2 – Climate transition plan disclosure group: The 4,100 organizations who reported to have developed a
1.5°C-aligned climate transition plan
Figure 4 – Disclosure to the climate transition plan elements
Risks & Opportunities
Governance
Policy engagement

Element

Scenario Analysis
S123 accounting withverification
Value chain engagement

Strategy to achieve net zero
Targets
Financial planning
0%

10%

20%

Entire disclosure sample (Group 1)

30%
Percentage (%)

40%

50%

60%

Climate transition plan disclosure sample (Group 2)

Although there may be unique cases, the trend of disclosure and implementation of a credible climate transition
plan follows a journey which is initiated by identification of risks & opportunities, establishment of governancestructures to guide progress of the transition, strategizing through robust scenario analysis, implementation of aplan by setting science-based targets (SBTs) and establishment of resources (financial and otherwise) to achieve
set targets. This should be continually validated by an ongoing audit of the plan’s performance.
This journey is consistent with the data assessed in this report as more than a third of the disclosing
organizations met the disclosure criteria for the risks & opportunities element of a credible climate transition
plan – this was followed closely by the governance element (24%) and the policy engagement element (19%).
In contrast, financial planning, targets, and strategy to achieve net-zero were the poorest performing elementsof a credible climate transition plan with 3%, 4% and 7% of organizations meeting the disclosure criteria in theserespective elements. It is essential that disclosure to each element increases at pace.

13

The following sub-section demonstrates the progression along this journey and further analyzes thedisclosures within each individual element:

Risks & opportunities
A climate transition plan should outline an organization’s
process for minimizing identified climate-related risks andmaximizing climate-related opportunities. Organizations
should disclose any identified climate-related risks and/or opportunities with the potential to have financial or
strategic impact on their business and their plans tomanage them. Where these risks or opportunities havenot been identified organizations should disclose why they
consider their business to not be exposed to these climaterelated risks and/or opportunities.
Disclosure of potential climate-related risks or, whereappropriate, disclosure of a reason for why risks havenot been identified was strong with 40% of organizations
disclosing sufficient detail. Disclosure of potential climaterelated opportunities, or where appropriate, disclosure ofa reason for why opportunities have not been identified
was slightly stronger with 42% of organizations disclosing
sufficient detail.
For organizations to disclose sufficiently to this element,
they should disclose on both their risk and opportunities
management processes. It is encouraging that 32% of
disclosing organizations disclosed sufficient detailof their process for managing risks and realizing
opportunities. In contrast, only 6% of organizations that
disclosed that they have a 1.5°C climate transition planwith a defined shareholder feedback mechanism also
disclosed sufficient detail of their risk and opportunities
management processes.
It is essential that organizations disclose their risk
and opportunities management process, and that any
climate transition plan manages risks and plans to realize
opportunities if they have been identified. A climatetransition plan demonstrates how an organization plans tocontinue to be relevant (i.e., profitable) in a 1.5°C-aligned
world. The risk and opportunities element of a credible
climate transition plan is where an organization candemonstrate this business-related planning element.

14

GovernanceGood governance means an organization has board-level
oversight on the climate transition plan and that there
are defined governance mechanisms in place to ensure
implementation of the plan. Over one-third of all disclosing
organizations reported having board-level oversightof climate transition plans. Additionally, more than
one-quarter of disclosing organizations reported having
incentives in place for the management of climate related
issues. Less than a quarter of disclosing organizations haveboth board-level oversight and incentives in place.
When examining these governance indicators amongorganizations that reported having a public 1.5°C-aligned
climate transition plan with shareholder feedback
mechanisms in place, more than 68% also have board-level
oversight and offer incentives. While most organizations
with strong climate transition plans report having
these governance practices in place, there are manyorganizations that need to improve their governance.
Similarly, organizations without climate transition plans areless likely to have robust governance practices in place. The
data suggests that organizations with climate transition
plans tend to have better governance practices thanorganizations without climate transition plans.

Scenario analysis
A climate transition plan should be underpinned by robust
scenario analysis — to identify potential substantive
climate-related risks and opportunities, enhance criticalstrategic thinking, and help an organization understandhow it might perform in different future states. Of the
18,600+ organizations that disclosed in 2022, just 3,315
organizations disclosed a robust scenario analysis
process. Of the 1,751 organizations that reported apublic 1.5°C-aligned climate transition plan with a defined
shareholder feedback mechanism in place, about 63%(1,111 organizations) also disclosed details which
demonstrate robust scenario analysis. It is critical thatorganizations engaged in climate transition planning
implement scenario analysis as an important strategicplanning tool. To learn more about scenario analysis andbest practices for disclosure, see CDP's Technical Note on
Scenario Analysis.

Targets
SBTs are a vital part of a credible climate transition plan. A climate transition plan should contain time-bound, andwhere possible, verified SBTs which are in line with the latest 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. CDP
assessed disclosed targets and investigated three key indicators: (1) absolute targets, (2) intensity targets, and (3)net-zero targets. For analysis of this element, there were 2,597 organizations that could not be assessed this year –please see Appendix for more detail.
For analysis of this element, two assessment routes were considered:{ SBTi route: This assessment route aligns with the underlying methodology of the Science Based Targets
initiative (SBTi) for setting credible science-based targets.
{ CDP route: For organizations who do not have SBTi validation, CDP offers an alternative way to assess
leadership within disclosure of targets. For more information, please see here.
Of the three target indicators assessed within this element, reported net-zero targets met the disclosure criteria
most, followed by absolute targets, and then intensity targets – see Figure 5, below.
Figure 5 – Distribution of disclosed targets data

Number of organizations

16000

16,99015,90814,786

12000

800

400

2,597

2,597

1,613

1,220
98

0
Absolute targets

Intensity targets

Disclosure did not meet criteria

Not assessed

Net-zero targets
Disclosure met criteria

672 organizations met the disclosure requirement for targets i.e., these organizations credibly disclosed either
an absolute or intensity target and a net-zero target, amounting to 4% of the total sample. Over half of theseorganizations (384) also disclosed that they have a 1.5°C transition plan with a defined shareholder feedback
mechanism. Although organizations may disclose that they have ambitious emissions reduction targets via other means,
CDP views the SBTi as the gold standard for setting credible SBTs. This is because the SBTi follows an independent,
rigorous, verified and science-aligned process aimed at driving ambitious climate action in the private industry.

15

Of the 672 organizations that met the disclosure criteria for the targets element, three-quarters of them have somelevel of SBTi status - see Figure 6 for distribution of these SBTi targets.
Figure 6 – Breakdown of SBTi status amongst 672 organizations who met the disclosure criteria for credibletargets element level disclosure
Net-zero target distribution

Near-term target distribution

216
406

94

69

313

50

29

Net-zero committed

Near-term target committed

Net-zero target approved

Near-term target approved 1.5oC

No net-zero status

Near-term target approved well below 2oC
Near-term target approved 2oC

Out of the 672 organizations, 313 of them have a 1.5°C SBTi approved near-term target, with 50 of these also
having an SBTi net-zero approved target. The data highlights a discrepancy between the number of disclosed
targets and transition plans in general. Even though organizations demonstrate that they have science-basedtargets, the data suggests that this is not always supported by a credible climate transition plan demonstrating how
they will achieve them.

16Financial planning
As part of its strategy to pivot to a 1.5°C-aligned world, an organization should outline time-bound financial planningdetails required to achieve its climate transition. 35% of organizations disclosed broad details on how climate
issues have impacted their financial planning. Stakeholder demand is rapidly increasing for transparent andgranular reporting on Capital Expenditure (CAPEX) and other financial planning details. All emerging transition
plan frameworks recommend organizations to disclose financial planning information to report on the impacts ofclimate-related risks and opportunities on their business and strategy.
In 2022, CDP introduced a new question to collect granular, forward-looking information on Revenue, CAPEX,
Operating Expenditure (OPEX), or other financial metrics in alignment with the transition to 1.5°C for the reporting
year and planned for 2025 and 20305. Only 581 organizations (just over 3%) provided financial figures AND amethodology explaining the estimation used to calculate any reported financial metric. Approximately 407
of these organizations with strong financial planning disclosure also reported a public 1.5°C-aligned climatetransition plan with feedback shareholder mechanisms in place. This demonstrates that many (approximatley174) organizations that reported having developed a 1.5°C-aligned climate transition plan are in fact missing thisessential aspect of credible climate transition plan disclosure.
Disclosure to the financial planning element was the weakest with on average 3% of organizations disclosing
sufficiently to these indicators across the entire disclosure sample. Yet nearly 15% of organizations in the power
generation industry provided robust disclosures on the current and future planned financial planning in alignment
with their 1.5°C climate transition plan, the most of any industry. This is a promising trend from an important
industry. From all other industries, less than 8% of organizations disclosed these details, and manufacturing andservices industry disclosure rate was 2%.
5. In 2021, only organizations in certain high-emitting sectors were requested to report on industry-specific questions regarding CAPEX plans or investment in R&D.

17

Value chain engagement & low carbon initiatives
A climate transition plan should include time-bound actions to decarbonize business processes (and those ofits value chain), with time-bound KPIs. This includes three distinct elements: (1) value chain engagement; (2)increasing share of revenue from low-carbon products and services; and (3) implementing emissions reduction
initiatives for its direct and indirect operations. The key indicators assessed within this element include thedisclosure of supply chain engagement strategy and the disclosure of details and revenue from low-carbon
products and/or services.
Value chain engagement enables an organization to effectively transition across its wider operations and drive
down emissions that are located within its value chain. Whilst such actions are essential to any credible transitionand central to a credible climate transition plan, organizations disproportionately failed to disclose details of
their supply chain engagement strategy. Only 16% of organizations disclosed details on their supply chain
engagement strategy, which requires organizations to disclose the type of engagement, description of the impact,
percentage of coverage over supplies and procurement spend, and a rationale for engagement.
Driving down emissions within an organization’s direct operations through increasing the portfolio of low-carbon
products and/or services is another feature of this element. Organizations should disclose the percentage of revenue
they receive from their low-carbon products and/or services and elaborate with a comment. Only 11% of disclosing
organizations disclosed sufficient details on their low-carbon products and/or services. Discouragingly, fewerorganizations disclosed details on their products and/or services than supply chain engagement strategies.
Disclosure of this element was particularly poor. Organizations that disclosed details on both their supply chain
engagement and low-carbon products and/or services only represent 8% of the entire disclosures to the climatechange questionnaire in 2022. Similarly, only 3% of those organizations that disclosed that they have a public
1.5°C-aligned climate transition plan with a defined shareholder feedback mechanism in place, disclosed details on
both their supply chain engagement and low-carbon products and/or services, more work is needed.

Policy engagement
A climate transition plan should demonstrate that an organization's public policy engagement aligns with its climate
ambition and strategy. Any existing or planned engagement should contribute toward creating an accommodative
policy environment with climate-positive policies that support an organizational and an economy-wide transition.
Organizations should disclose whether their engagement activities are in line with the Paris Agreement and details
on their processes in place to ensure engagement activities are consistent with their overall climate change
strategy. 19% of organizations disclosed such details on their policy engagement including an explanation of why
such direct or indirect engagements were not taking place. Concurrently, 81% of organizations disclosing via
the 2022 climate change questionnaire failed to disclose sufficient details of their policy engagement. Most
organizations that disclosed that they have a 1.5°C climate transition plan with a defined shareholder feedback
mechanism were not transparent with their policy disclosure, with only 6% disclosing sufficient detail of this crucial
element of credible climate transition plans.

18

Scope 1, 2 and 3 accounting with verification
A climate transition plan should be accompanied by an annual Scope 1, 2 and 3 emissions inventory that iscomplete, accurate, transparent, consistent, relevant, and verified by a third-party. In this year’s analysis, we
assessed the disclosure of indicators within this element and identified that of all three scopes of emissions
reported, Scope 2 disclosures most met the disclosure criteria (99%), followed by Scope 1 (71%) and Scope 3 (22%)- see Figure 7, below:
Figure 7 – Scope 1, 2 and 3 accounting with verification
180

20,000

Number of organizations

16,0005,240

14,383

12,000800

13,363

15,92818,423

400

4,220

2,675

0
Scope 1

Scope 2

Scope 3

Third party verification

Sub-element
Disclosure met criteria

Disclosure did not meet criteria

As you cannot manage what you do not measure, a robust emissions inventory with third party verification is the
bedrock of the transition journey and the foundation of setting science-based targets which underpin a credible
climate transition plan. Of the entire group assessed, 1,750 organizations met the disclosure criteria for thiselement i.e., these organizations disclosed robustly to all three scopes of emissions and reported the existenceof a credible third-party verification system. Interestingly, the data shows that of the 4,101 organizations whoreported to have developed a climate transition plan, less than half (approximately 43%) of them had a credible
and third party verified emissions inventory, which accompanied their plan. Although this element is not a directindicator of climate transition plans, credible climate transition plans must be accompanied by robust and complete
disclosure of GHG emissions to track progress.

19

Conclusion

With only 0.4% of all disclosing organizations
reporting details of a credible climate transition
plan, it is clear that better quality disclosure isneeded, but pivoting towards a 1.5°C-aligned
trajectory is a journey. This report shows
encouraging signs and interest in the uptake ofclimate transition plans from various stakeholders
and organizations.
Over 30% of all disclosing organizations reported that they intend
on developing a 1.5°C-aligned climate transition plan in the next two
years. There are encouraging signs that signal a substantial numberof organizations are on the journey to improve their transition-relevant
disclosure. Further, with a rapidly evolving regulatory landscape seen
across the UK, the EU and the US, forthcoming legislation on transition
plans will be a key driver of increased (and improved) climate transition
plan disclosure.
It should be emphasized that although there were only 81 organizations
who met the criteria for all the indicators of a credible climate transition
plan in this year’s assessment, there was also a subset of over 2,000
organizations who reported to many (14–20) of the key climatetransition plan indicators. CDP recognizes that climate transition plans
are a vital mechanism for transition to a 1.5°C-aligned world. This is why
transition planning features in the CDP 2021–2025 strategy, placing
transparency and accountability at its heart. CDP's disclosure platform,
disclosure guidance and thematic research seeks to incentivize thedisclosure of credible climate transition plans as they catalyze ambition
from disclosure & oversight to action plan.

20

Appendix

Assessment methodology & key transition-focused indicators in the 2022 climate change questionnaire
Climatetransition planelement

CDP 2022 climate change questionand question code

Relevance to climate transition plans

Assessment methodology(C1.1b) Provide further details on theboard’s oversight of climate-related
issues.

An organization should have board-level
oversight of its climate transition planwith defined governance mechanisms
in place to ensure delivery of the plan.
Climate issues should be a scheduled
item at all or some board meetings.

Organization discloses the frequency
with which climate-related issues are ascheduled agenda item, the governancemechanisms into which climate issues
are integrated and elaborate with an
explanation.

(C1.3a) Provide further details on the
incentives provided for the managementof climate related issues.

To incentivize conscious action andcommitment in realizing the plan’sgoals, it is recommended that executive
management incentives are aligned withthe organization’s climate transition plangoals.

Organization discloses who is entitled tothe incentives, the type of incentive andthe activity incentivized, and elaborated
with a comment.

(C3.2a) Provide details of yourorganization’s use of climate-related
scenario analysis.

Robust scenario analysis is an
important strategic planning tool thatcan be used to inform the developmentof a climate transition plan.

Organization discloses on its use ofclimate-related scenario analysis,
scenario analysis coverage, temperaturealignment of scenario, parameters,
assumptions, and analytical choices.

Governance

Scenario
analysis(C3.4) Describe where and how climaterelated risks and opportunities haveinfluenced your financial planning.

Financialplanning(C3.5a) Quantify the percentage shareof your spending/revenue that is alignedwith your organization’s transition to a
1.5°C-aligned world.

Organization reports on at least one
area of its financial planning thathas been influenced by climate anddescribes its influences.
Organization must select at least
one financial metric and disclose
the percentage share of the selectedfinancial metric which is aligned with a
1.5°C world in the reporting year, 2025,
2030 and description of methodology
used to identify spending/revenue that isaligned with a 1.5°C world.

(C12.1a) Provide details of your climaterelated supplier engagement strategy.

Organizations are facing resiliency
risks in the value chain that havematerial environmental and financial
implications; hence, value chain
engagement plays a significant role
in realizing a climate transition plan.
Organizations with significant emissions
in their supply chain can leverage
their buyer power and engage their
suppliers towards a 1.5°C-aligned
transition. A climate transition planshould include time-bound actions todecarbonize business processes within
the value chain, including supply chain
engagement that covers at least 25% of
its suppliers by procurement spend or
Scope 3 emissions.

Organization discloses the type of
supplier engagement, details of theengagement, a description of the
impact of the engagement, including
measures of success, a figure in boththe % of suppliers by number and % ofprocurement spend, and a rationale forthe cover of its engagement.

(C4.5a) Provide details of your products
and/ or services that you classify as lowcarbon products or that enable a third
party to avoid GHG emissions.

A climate transition plan should include
time-bound actions to decarbonize
business processes, such as growing
the revenue earned from its products
and services portfolio.

Organization discloses details of its lowcarbon products and services, as well asa non-zero figure for the % revenue fromthat product in the reporting year andelaborate with a comment.

Value chain
engagement& low carbon
initiatives

21

Financial planning is crucial whendemonstrating that an organization isaligning with climate goals (as elaborated
in its climate transition plan), and that
it will be relevant (i.e., profitable) in a
1.5°C-aligned world. Climate transition
plans should include a demonstrationof how they have aligned/intend to aligntheir financial planning with their climatetransition plan in the reporting year andat milestone years ‘2025’ and ‘2030’.
Financial details may describe revenue,
CAPEX, and/or OPEX projections
which are crucial for realizing the plan’s
ambition.

Climatetransition planelement

Policyengagement

CDP 2022 climate change questionand question code

Relevance to climate transition plans

Assessment methodology(C12.3) Does your organization engage
in activities that could either directly
or indirectly influence policy, law, or
regulation that may impact the climate?

For many organizations, a successful
climate transition will depend on anaccommodative policy landscape, thusorganizations should advocate forclimate-positive policies that impact
their relevant industry(s). A climatetransition plan should demonstratethat an organization’s public policy
engagement aligns with its climate
ambitions and strategy.

Organization should disclose whether it
has a direct or indirect engagement that
could influence policy, law, or regulationthat may impact climate, whether it
has a public commitment or position
statement to conduct its engagement
activities in line with the goals of
the Paris Agreement, describe theprocess(es) it has in place to ensure thatits engagement activities are consistent
with its overall climate change strategy
and where relevant, a reason (andexplanation) for not engaging in
activities that could directly or indirectly
influence policy, law, or regulation that
may impact the climate.

(C3.1) Does your organization’s strategy
include a transition plan that aligns witha 1.5°C world?

Developing a climate transition plan
provides certainty to data users that acompany is aligning to the long-termclimate goals and that its businessmodel will continue to be relevant in a
net-zero carbon economy. Collecting
feedback on the transition plan allows
shareholders to review and raise
resolutions related to progress.

Organization discloses that it has
a publicly available 1.5°C climatetransition plan with a well-defined
feedback mechanism in place, to trackprogress.

(C3.3) Describe where and how climaterelated risks and opportunities haveinfluenced your strategy.

A climate transition plan should outline
how an organization will achieve
its strategy to pivot its products
and services, supply/value chain,
investment in R&D, and operations to a
1.5°C-aligned world.

Organization describes how climate
has influenced, has not influenced,
or how they are considering climate’s
influence to their products and services,
investment in R&D, operations, andsupply/value chain.

Strategy(C2.3a) Provide details of risks identified
with the potential to have a substantive
financial or strategic impact on yourbusiness.
(C2.3b) Why do you not consider yourorganization to be exposed to climaterelated risks with the potential to have asubstantive financial or strategic impact
on your business?

Disclosing details of material climate
risks posed to an organization, including
the potential financial impact and thecost to respond to these risks, indicatesa robust climate transition plan is inplace.

Risks &
opportunities(C2.4a) Provide details of opportunities
identified with the potential to have asubstantive financial or strategic impact
on your business.
(C2.4b) Why do you not consider yourorganization to have climate-related
opportunities?

22

Disclosing details of material climate
opportunities posed to an organization,
including the potential financial
impact and the cost to realize theseopportunities, indicates a robusttransition plan is in place.

Organization reports details of at least one
climate-related risk identified, including
the potential financial impact and cost to
respond to the risk.
However, if an organization has notdisclosed to C2.3a, it must have disclosed
to C2.3b, by providing an explanation why
it does not consider itself to be exposed
to climate related risks with the potential
to have a substantive financial or strategic
impact on its business.
Organization reports details of at least
one climate-related opportunity identified,including the potential financial impact andcost to realize the opportunity.
However, if an organization has notdisclosed to C2.4a, it must have disclosed
to C2.4b, by providing an explanation why
it does not consider itself to be exposed
to climate related risks with the potential
to have a substantive financial or strategic
impact on its business.

Climatetransition planelement

CDP 2022 climate change questionand question code

(C4.1a) Provide details of your absoluteemissions targets and progress madeagainst those targets.

Targets(C4.1b) Provide details of youremissions intensity target(s) andprogress made against those target(s).

(C4.2c) Provide details of your net-zerotarget(s).

(C6.1) What were your organization’s
gross global Scope 1 emissions inindicator tons CO2e?
(C6.3) What were your organization’s
gross global Scope 2 emissions inindicator tons CO2e?

Scope 1,2,3
Accounting
withverification(C6.5) Account for your organization’s
gross global Scope 3 emissions,disclosing and explaining any
exclusions.

(C10.1) Indicate the verification/
assurance status that applies to yourreported emissions.

23

Relevance to climate transition plans

Assessment methodology
The criteria for credible targets
disclosure within a credible climatetransition plan require an organization todisclose: (1) its target to have a sciencebased status, (2) details on intensity or
absolute emissions targets (3) that it
has a 1.5°C-aligned target.

A climate transition plan should beunderpinned by ambitious near-and
long-term science-based targets which
are in line with the latest climate scienceto achieve a 1.5°C-aligned world.

A climate transition plan should aim toachieve science-based net-zero targets
in line with the latest climate science toachieve a 1.5°C-aligned world by 2050 at
the latest.

For this year's assessment, weleveraged the CDP scoring methodology
and resultantly, 2,597 organizations
could not be assessed for several
operational reasons such as:
Late submissions, minimum tierresponses with Investor request only,
HQ in Russian Federation/Belarus,
Forests only - Coal OR Metals & mining
companies, Forests only - didn’t
respond to any commodity, Unpaid
administration fees.
Organization reports on whether it isreporting a net-zero target, whether it isscience based – and if so, it also reports
details on its net-zero target.
Organization discloses a figure for its
Scope 1 emissions.

A climate transition plan shouldbe accompanied by a complete,accurate, transparent, consistent, andrelevant inventory of all three scopesof emissions. Organizations should
calculate and disclose all material
categories of Scope 3 and provide an
explanation for categories that are not
relevant.

A climate transition plan should beaccompanied by a complete annual
inventory Scope 1, 2, & 3 emissions thatis verified by a third party.

Organization discloses a figure for its
Scope 2 location-based or market-based
emissions.
For each category of Scope 3 emissions,the organization discloses a figure
for any “relevant, calculated” or “notrelevant, calculated” categories,
or provides an explanation for any
categories “not relevant, explanation
provided”.
Organization reports verification is inplace for its Scope 1, 2, and 3 emissions.

Threshold breakdown
Name

Threshold

MeaningAll

100%

Organizations in this tier disclosed to all 21 key indicators of a credible climate transition plan.

Many

67 - 99%

Organizations in this tier disclosed between 14 and 20 of the key indicators which comprise acredible climate transition plan.

Some

34 – 66%

Organizations in this tier disclosed between 7 and 13 of the key indicators which comprise acredible climate transition plan.

Few

0 – 33%

Organizations in this tier disclosed less than 7 of the 21 key indicators which comprise a credible
climate transition plan.

Total industry disclosure (and threshold breakdown)
TIERS
Industry

Few

Some

Many

All

Total

Apparel

324

91

41

1

457

Biotech, health care & pharma

285

116

75

3

479

Financial services

143

284

233

2

662

Food, beverage & agriculture

678

211

143

6

1,038

Fossil fuels

147

64

59

1

271

Hospitality

47

35

28

1

111

Infrastructure

377

135

195

12

719

International bodies

4

4

Manufacturing

5,571

1,304

553

15

7,443

Materials

1,019

350

288

13

1,670

Power generation

84

57

82

5

228

Retail

519

214

133

4

870

Services

2,854

533

314

16

3,717

Transportation services

685

143

100

2

930

12,737

3541

2244

81

18,603

Grand total

24

8

Total country/region disclosure (and tier breakdown)Country/region

25

Few

Some

Many

All

Total

United States

2,678

705

330

5

3,718

China

1532

416

89

Few

Some

Many

United ArabEmirates

50

9

3

62

Japan

835

467

377

16

1,695

Chile

34

2

8

44

United Kingdom

960

276

206

6

1,448

Greece24

11

7Brazil

1,114

118

77

1

1,310

Romania39

4Germany

700

171

103

1

975

Hungary

37

4

Italy

447

78

49

4

578

Saudi Arabia

37

3France

335

91

116

5

547

New Zealand

14

12

Taiwan, China

266

143

87

4

500

Czechia

34

5

39

India

328

95

53

5

481

Viet Nam

33

2

35

Republic of Korea

278

44

101

2

425

Philippines

18

8

7

33

Mexico

324

50

15

1

390

Israel

19

7

3

29

Spain

279

38

56

5

378

Ecuador

26

1

1

28

Canada

166

115

41

Egypt

22

5

1

28

Sweden

143

59

41

1

244

Kuwait24

1

25

Switzerland

123

61

35

5

224

Pakistan

16

7

1

24

Netherlands

111

51

27

4

193

Luxembourg

6

7

9

22

Hong Kong, China

123

47

16

186

Slovenia

16

5

Australia

114

43

26

183

Russian Federation

5

8

Turkey

87

25

57

3

172

Bangladesh

15

4Finland

105

31

29

1

166

Slovakia

15

2

Denmark

109

30

21

160

Qatar

17

1

Poland

98

30

1

129

Costa Rica

15

Ireland

51

29

36

116

Peru

8

8

Singapore

77

20

13

110

Kazakhstan

13

1

Belgium

62

15

28

1

106

Nigeria

123

Norway

47

17

35

4

103

Lithuania

11

2

1

14

Austria

61

24

18

103

Bermuda

4

6

2

12

Indonesia

78

16

7

101

Oman

12

Malaysia

78

18

3

99

Uruguay

11

1

12

Thailand

65

13

17

Guatemala

9

2

11

South Africa

29

28

34

91

Trinidad andTobago11

Argentina

64

8

1

73

Macao, China

9

Portugal

47

7

11

69

Iraq

10

10

Colombia

53

7

7

67

Algeria

8

8

2,037

322

2

4

97

Country/region

All

1

Total

43
43

1

42
40

13

39

21
7

20
19

1

18
18

1

16
16

1

15
15

12

11
1

10

Country/region

26

Few

Some

Many

Estonia62

8

Nicaragua

22Panama7

1

8Paraguay

2

2

Cayman Islands

3

2

2

7

Guernsey

1

1Bulgaria

5

1

1

7

Marshall Islands

1

1

Sri Lanka

6

1

7

Afghanistan

1

1

Croatia77Åland Islands

1

1

Iceland1

3

6

Bahrain1

1

Guyana5

1

6

Serbia5

1

6British Virgin
Islands

1

1

Kenya

4

5

Brunei Darussalam

1

1

Ukraine55

Cameroon

11(blank)

5

5

Congo

1

1

Dominican Republic

2

4

Côte d’Ivoire

1

1

Ghana

4

4

Equatorial Guinea

1

1

Malta

1

2

3

Eritrea1

1

Cyprus2

1

3

Eswatini

11Angola

3

3

Fiji

1

1

Bolivia(Plurinational
State of)3

3

Greenland11Cambodia

2

1

3

Jamaica

1

1

El Salvador

2

1

3

Monaco11

Honduras3

3

Mongolia

1

1

Jersey1

3

Mozambique

Jordan33Myanmar

1

1

Madagascar

3

3Namibia1

1

Mauritius

1

3

Norfolk Island

1

1

Puerto Rico

3

3

San Marino

1

1

Tunisia2

1

3

Senegal1

1

Uganda2

13South Sudan

1

1

Morocco1

2

Turkmenistan

11Belarus2

2

Georgia22

United Republic of
Tanzania

1

1

Lebanon

2

2

Libya

2

2

United States
Minor Outlying
Islands

Mauritania

2

2

Yemen

2

1

2

2

2

1

All

Total

Country/region

Few

Isle of Man

Some

1

1

1
1

Many

All

Total

1

1

1
1

DISCLOSURE INSIGHT ACTION

Authors

Data teamAmir Sokolowski
Global Director, Climate Change
amir.sokolowski@cdp.net

Ben Simpson
Senior Data Analyst - Transitions
ben.simpson@cdp.net

Tatiana Boldyreva
Associate Director, Climate
tatiana.boldyreva@cdp.net

Communications Lead

Emma Jenkins-Long
Associate Director - Transition Plans
emma.jenkins@cdp.net

Maddy Bravery
Communications Manager
maddy.bravery@cdp.net

Sylvester Bamkole
Senior Climate Analyst, Climate Change
sylvester.bamkole@cdp.net
Scott Twigg
Campaign Project Officer
scott.twigg@cdp.net

CDP Worldwide
4th Floor,
60 Great Tower Street,
London EC3R 5AZ
United Kingdom
Tel: +44 (0)20 3818 3900
www.cdp.net
info@cdp.net

If you are looking for more information on Climate Transition Plans
please email respond@cdp.net.

ABOUT CDP
CDP is a global non-profit that runs the world’s environmental
disclosure system for companies, cities, states and regions.
Founded in 2000 and working with more than 680 financial
institutions with over $130 trillion in assets, CDP pioneered using
capital markets and corporate procurement to motivate companies
to disclose their environmental impacts, and to reduce greenhousegas emissions, safeguard water resources and protect forests.
Nearly 20,000 organizations around the world disclosed data
through CDP in 2022, including more than 18,700 companies worth
50% of global market capitalization, and over 1,100 cities, states andregions. Fully TCFD aligned, CDP holds the largest environmental
database in the world, and CDP scores are widely used to drive
investment and procurement decisions towards a zero carbon,
sustainable and resilient economy. CDP is a founding member of the
Science Based Targets initiative, We Mean Business Coalition, The
Investor Agenda and the Net Zero Asset Managers initiative.
Visit cdp.net or follow us @CDP to find out more.