CDP: The Incredible Shapeshifting NGO
Ten Reasons Why the Carbon Disclosure Project is an Empty Black Box of Fuzzy Accounting
The CDP (The Carbon Disclosure Project) is indeed a project that seemingly changes its identity and objectives on the daily. The NGO’s chief objective is to do whatever it has to in order to dominate the climate reporting market and become the global standard for carbon emission disclosures. But it has a very loose reporting standard that can be adapted and altered to fit these political ambitions.
As the field of carbon emission disclosures has been very fuzzy, where the most valuable input in the reporting process consists in simply paying the exhorbitant disclosure fees, the CDP has been able to shapeshift its flagship app through more than two decades of undefined climate campaign marketing. That the CDP’s house of cards is only now collapsing is both a nod to its incredible PR and bully tactics and a shameful admission to how gullible so many in the corporate world have been to have fallen for this emissions reporting scam.
This is part four of an ongoing series on how the CDP NGO has manipulated other parties. Part One looked at how it manipulated the investment community, offering trading houses insider information on corporate information while threatening companies into sharing their information with a “disclose or divest” extortionary tactic. The second part examined how the CDP has developed a concept of “transition risk” where companies who do not bow to the activist transition narrative face the risk of being forced out of business as societies shift to “more sustainable alternatives”. Part Three looked at how the CDP has been lobbying government procurement agencies into making their disclosure app mandatory for all funding grants. The next part will look at the motivations of the founders and their networks. The final part of this series takes account of the lucrative funds the CDP earns and questions what it does with them.
Ten Shapeshifting Alterations of the CDP
In the 24 years that the CDP directors have been talking about themselves, there have been at least ten shapeshifting alterations from these decades of opportunism. Some of its actions were wholly unethical, many based on crass opportunism, but all of them showed a lack of respect for the integrity of the project or the values that had driven them.
The ten shapeshifting alterations include how the NGO:
Adapted the CDP reporting tool to be an insider-trading investment product
The CDP started in 2000 as a non-profit tool to register carbon emissions to try to establish a baseline to manage CO2 levels at a time when the concept of carbon emission trading was being bandied about. After the failure of the Copenhagen COP15 in 2009, and a rethink on how the corporate world should be involved in climate policy, the CDP tool morphed into an opportunity for the investment community to offer sustainability funds to ethical and later, ESG investment funds.Lobbied aggressively to have the CDP standard adopted at government levels
It is a good question how many lobbyists the CDP employs in Washington. In the same year that the U.S. Securities and Exchange Commission (SEC) climate disclosure rules were announced, the CDP informed their clients that they were fully aligned with the regulatory rules. Two years earlier, in 2022, the NGO celebrated having all US government procurement contracts be dependent on the recipients filing a carbon disclosure report with the CDP.Using large investment funds as an extortion tool, the CDP developed a concept of transition risk to bully companies to “disclose or divest”
As the CDP grew, its ambition to become the global standard for carbon emissions reporting for the global investment community, allowing it to throw its weight around and threaten companies who did not participate (ie, pay their disclosure fees). With the risk of being excluded from large ETFs, it made sense for companies to relent to the NGO’s demands.Developed supply chain reporting as ESG started to gain momentum
The corporate world PR marketing approach during the CDP’s reign had evolved from a CSR approach, to a sustainability strategy to an ESG model. In order to not lose its dominance, in 2007, the CDP introduced a supply chain reporting initiative.Coordinate with NGOs to provide CDP private data for activist campaigns
Members of the CDP, for example, worked with the anti-industry NGO, Climate Accountability Institute, to provide CDP disclosure data in the preparation of a joint report called The Climate Majors. The goal was to use this internal data to attack the largest carbon emitters. Thank you for your data, thank you for paying the expensive disclosure fees ... and now, ignoring any respect for your company’s privacy, you can read a report where we are sharing your data with another NGO to publicly attack you.Changed its name to try to move into other environmental fields (water and forests)
As other environmental reporting standards started to develop, the CDP introduced water and forestry disclosure standards. To appear credible in this new market, in 2013 the NGO changed its name from the Climate Disclosure Project to, simply, CDP.Engaged in regulatory capture within the US government
Former CDP director, Betty Cremmins, working for the US government’s Council on Environmental Quality, informed her old colleagues she was looking forward to sending thousands of new clients to CDP when the government made disclosure to the NGO’s standards a requirement for all federal government procurement contracts. The CDP and its sister organization, the Science Based Targets Initiative, were awarded regulatory authority without any call for tenders or investigation to how these non-US NGOs were funded.Continuously changing its reporting process (after decades of “development”)
The Task Force on Climate-related Financial Disclosures (TCFD) was formed in 2016 by Michael Bloomberg. After the TCFD’s first report in 2017, the CDP decided to align its disclosure platform with the TCFD in 2018. So after 18 years of developing its “world-leading climate disclosure platform”, the CDP threw it all out to adopt the Bloomberg-led protocols … to not risk losing their clients. If that weren't enough, last year the CDP decided again to redefine its standards to align with the European Commission’s EFRAG reporting standards supporting the EU CSRD Directive. The CDP apparently has no loyalty to the quality or purpose of its product and is willing to shapeshift it in order to stay relevant. At the same time, other groups in the field were not courting this troubled NGO.Stacked CDP people onto a global standards body just to ensure its model became the basis for any future carbon accounting guidelines
CDP founder, Paul Dickinson, admitted in an interview that the International Sustainability Standards Board (ISSB) was infiltrated by CDP people to dictate its protocols to the IFRS Foundation that sets the accounting standards for most countries (in anticipation that the IFRS would soon demand carbon accounting standards). When the ISSB Board was established during the COP 26 in 2021, there was no mention of the CDP standards, yet, among the existing reporting initiatives.Announced an alignment strategy in 2024 where it plans to adapt its disclosure process to every other existing carbon disclosure standard.
If the CDP had a product it believed in, then it would let this standard lead the disclosure process. Instead, last year, it announced a strategy to try to align its carbon reporting process with a collection of at least eight other existing standards. Worried that the NGO would lose market dominance, the CDP has decided to shapeshift in order to fit itself to other products. (Editor’s note: two days after this article was published, the CDP took down the web page on how they are aligning with other disclosure standards. See the page via Wayback Machine.)
What is the value of an organization that adulterates its platforms, objectives and strategies with the sole purpose of controlling and dominating an issue? It can only be, first, about profit and second, to maintain an influential network. It is not at all about a commitment to improving the environment or having a product that truly provides service to clients.

An Empty Black Box to Generate Disclosure Income
The CDP has essentially created a well-networked black box that it will try to fill with whatever it can to compel companies to pay for a fuzzy report the NGO can sell on to its fee-paying clients in the global investment world. The fact that this black box keeps changing and remains ill-defined does not seem to affect the CDP’s strategy. As long as it keeps its network of “virtue shepherds” in governments, the financial community and the UN/NGO/foundation worlds, the corporate sheep, they assume, will continue to be herded into its box.
The chief strategy for the non-profit is to dominate the environmental reporting arena so it will shapeshift its principles and reporting tools, expand its networks, redefine its products and lobby for integration into government policy requirements. The CDP humbly declares its objectives:
“Founded in 2000, CDP was the first platform to leverage investor pressure to influence corporate disclosure on environmental impact. Now with the world’s largest, most comprehensive dataset on environmental action, the insights that CDP holds empowers investors, companies, cities, and national and regional governments to make the right choices today to build a thriving economy that works for people and planet in the long term.” Source
One of the logical steps for the CDP was to get the investment community to integrate this data into its ESG investment tools. It quickly became a free-for-all of reporting tricks, greenwashing and gaming the system. The fuzzy nature of the CDP black box created an ecosystem of consultants and bottom-feeders (example) offering clients a means to push them up the rankings in their disclosure process to reap larger ESG benefits.
Times were good.
No one in 2023 had foreseen how fast the entire ESG game was going to wither on the vine. The world has changed in the last year and the climate campaigners who have shoved their agenda too forcefully on regulators, consumers and markets are now witnessing an incredible blowback. Every day, it seems, another couple banks are abandoning UNEP’s signature Net Zero Banking Alliance. DEI is becoming DOA. Is the CDP next?
How will the shapeshifting CDP adapt to this new, rather hostile, environment? Fortunately the NGO is flush with cash so it should be able to once again redefine itself. These manipulative opportunists won’t just go away.