Webinar Recap: How to Get Ahead of CA SB 253 GHG Verification

Missed our recent Sustainability & Climate webinar, “How to Get Ahead of CA SB 253 GHG Verification?” You can now watch the...

Missed our recent Sustainability & Climate webinar, “How to Get Ahead of CA SB 253 GHG Verification?” You can now watch the full recording on GSI’s YouTube channel.

In this session, Albert Chung, PhD, PE, and Brady Koetting, CPA, discuss what companies should know as SB 253 moves from reporting preparation toward verification, assurance, and audit-ready emissions data.

The webinar covers the current state of SB 253, what to expect from the verification process, common assurance questions, supporting documentation, materiality, internal controls, site visits, and steps organizations can take now to identify gaps before assurance begins.

Please note that regulatory guidance has continued to evolve since this webinar was recorded. Since the webinar, the California Air Resources Board (CARB) announced a proposed update that would defer the initial Scope 1 and Scope 2 greenhouse gas reporting deadline from August 10, 2026, to November 10, 2026. This proposed three-month extension is intended to provide additional clarity following final approval of the regulation. The general guidance shared in this webinar on how companies can prepare remains applicable, including the importance of organizing data, confirming reporting boundaries, engaging internal stakeholders, and preparing for verification.

Watch the recording here: https://youtu.be/Wz8AVNrWd_8

Keep an eye out for more upcoming webinars from GSI as we continue sharing insights on sustainability, climate disclosure, regulatory changes, and environmental strategy.

From Net Zero Commitments to Climate Accountability: How SBTi, ISO 14060, IFRS S2 and ESRS Fit Together

As climate reporting shifts from voluntary pledges to mandatory disclosure, companies are increasingly combining science-based targets, net zero management systems, and regulatory...

As climate reporting shifts from voluntary pledges to mandatory disclosure, companies are increasingly combining science-based targets, net zero management systems, and regulatory reporting frameworks to demonstrate both ambition and execution. Rather than operating as standalone initiatives, frameworks such as ISO 14060, SBTi, IFRS S2, and ESRS can be viewed as complementary components of an emerging three-layer Climate Accountability Stack, connecting implementation, credibility, and disclosure to help organizations move from climate commitments to measurable progress.

The net zero standards landscape is entering a new phase. For years, companies have struggled with a crowded mix of voluntary frameworks, investor expectations, carbon accounting rules, and climate disclosure requirements. Two of the most significant recent developments are the draft ISO Net Zero Aligned Organizations Standard (ISO 14060) and the Science Based Targets initiative’s Corporate Net-Zero Standard Version 2.0. [1][2]

Both aim to improve the credibility of corporate net zero claims. But they are not interchangeable. ISO 14060 is emerging as a broad, internationally harmonized standard for net zero transition planning and alignment, while SBTi remains a more prescriptive target-setting and validation framework focused on emissions reductions aligned with climate science. [3][4]

A Brief History of the ISO Net Zero Standard

ISO’s work on net zero began with the ISO Net Zero Guidelines, IWA 42:2022, launched at COP27. The guidelines were developed to create a common global reference point for what “good” net-zero action should look like across organizations, cities, regions, and countries. ISO describes IWA 42 as a framework intended to align territorial approaches, such as national or city net zero plans, with organizational and value chain approaches. [2]

The draft ISO 14060 standard builds on those 2022 guidelines. ISO released the draft for public consultation June 2026, describing it as the world’s first international standard for net zero alignment and a tool to support credible, comprehensive net-zero transition plans. [1] Public consultation ends in August 2026 and the final publication is expected in 2027.

The significance of ISO 14060 is that it moves net zero from guidance toward a more formal, potentially certifiable and independently verifiable management-system-based standard. That matters because ISO standards are already widely used by companies for environmental management, quality, safety, and risk systems. For companies that already use ISO 14001 or other ISO management systems, ISO 14060 may be easier to integrate into existing governance, controls, documentation, and assurance processes.

A Brief History of SBTi’s Corporate Net-Zero Standard

The Science-Based Targets initiative was launched before the Paris Agreement and has become one of the most influential voluntary frameworks for corporate emissions target setting. Its Corporate Net-Zero Standard gave companies a science-based pathway for setting near-term and long-term emissions reduction targets, with an emphasis on deep value chain decarbonization before neutralizing residual emissions.

SBTi’s Corporate Net-Zero Standard Version 2.0 was developed through a multi-year revision process. According to SBTi, the Version 2.0 revision process included two public consultations and extensive pilot testing involving 1,800 stakeholders, with more than 320 companies participating in the first phase of pilot testing and more than 50 in the second. [4] Version 2.0 was released this month (June 2026) and is described by SBTi as its most comprehensive framework for corporate climate action to date. [3] Validation against the new standard is expected to open in early 2027.

Where ISO 14060 and SBTi’s Corporate Net-Zero Standard 2.0 are Similar

ISO 14060 and SBTi’s Corporate Net-Zero Standard 2.0 share several important principles. Both are designed to increase credibility in corporate net-zero claims by:

  • Emphasizing the need for near-term action rather than distant 2050 commitments.
  • Recognizing that organizations need accountability, implementation standardization, actionable emissions measurement, transparency, and progress reporting.

Both also respond to the same underlying problem:

  • Corporate net zero claims have often been inconsistent, poorly defined, overly reliant on offsets, or disconnected from real operational decisions.

In that sense, both standards are part of a broader movement away from aspirational climate commitments and toward evidence-based transition planning.

Where ISO 14060 and SBTi’s Corporate Net-Zero Standard 2.0 Differ

The biggest difference is purpose. SBTi is primarily a target-setting and validation framework. It is best known for defining whether a company’s greenhouse gas reduction targets are aligned with climate science. It is especially relevant for companies that want externally validated emissions reduction targets that investors, customers, and disclosure users recognize.

ISO 14060 is broader. It is focused on net zero alignment and transition planning, not only target validation. It may be better understood as a management-system-oriented standard that helps organizations structure their net zero strategy, governance, implementation, and assurance approach.

Another major difference is audience. SBTi is designed primarily for companies. ISO’s net zero work is intended to be useful across organizations, policymakers, cities, regions, and other institutions. ISO’s 2022 guidelines explicitly aimed to align territorial and value chain approaches. [2]

There is also a difference in how each establishes credibility. SBTi validates targets. ISO standards, depending on the final structure and assurance ecosystem, may be used more like other ISO standards: as a basis for internal controls, third-party assessment, and integration with management systems.

When SBTi May Be the Better Fit

SBTi may be the better choice for a company seeking recognition by investors, customers, employees, and rating organizations. It is particularly useful for companies facing pressure from large customers, lenders, or sustainability ratings platforms to demonstrate that their Scope 1, 2, and 3 targets are aligned with climate science.

SBTi is also likely to remain the stronger option when the primary need is emissions target credibility. For companies with mature greenhouse gas inventories, strong Scope 3 data, and a desire to make public climate commitments, SBTi provides a structured pathway for setting and validating targets.

When ISO 14060 May Be the Better Fit

ISO 14060 may be more suitable for organizations that need a practical net-zero management framework rather than only a validated target. This may include companies that are earlier in their climate journey, organizations with complex operations, public agencies, infrastructure companies, private companies, or companies already using ISO 14001 or other ISO management systems.

ISO 14060 may also be useful where the challenge is not only “what should our target be?” but “how do we build the governance, controls, transition plan, documentation, and accountability needed to deliver it?”

For companies preparing climate transition plans under regulatory or investor pressure, ISO 14060 could become a practical bridge between climate strategy, enterprise risk management, environmental management systems, and disclosure readiness.

Why Companies May Need Both ISO 14060 and SBTi

For many years, net zero commitments were largely voluntary. Companies adopted science-based targets, published sustainability reports, and announced ambitious climate goals in response to investor expectations, customer pressure, and corporate values. Today, however, climate commitments are increasingly intersecting with mandatory disclosure requirements.

Frameworks such as the International Sustainability Standards Board’s (ISSB) IFRS S2 Climate-related Disclosures and the European Union’s Corporate Sustainability Reporting Directive (CSRD), implemented through the European Sustainability Reporting Standards (ESRS), require companies to disclose not only their greenhouse gas emissions and targets, but also the governance, strategy, risks, transition plans, and resources supporting those commitments. [5]

This shift raises an important question: How can companies demonstrate that their net zero ambitions are credible, actionable, and embedded within business operations?

The answer may lie in combining the strengths of SBTi and ISO 14060. SBTi provides external credibility for emissions reduction targets. It establishes whether a company’s near-term and long-term greenhouse gas reduction goals are aligned with climate science and SBTi’s applicable target-setting methodologies. Investors, customers, and rating organizations increasingly recognize SBTi validation as a benchmark for ambition and target credibility. [3]

ISO 14060 addresses a different challenge. It provides a framework for developing and maintaining the systems required to achieve those targets. This includes governance structures, organizational accountability, transition planning, implementation processes, monitoring, and continual improvement. In essence, ISO 14060 may provide the operational architecture behind a company’s net zero strategy.

While SBTi and ISO 14060 were developed as voluntary frameworks, their importance is growing as climate disclosure requirements become increasingly mandatory. As a result, many organizations are beginning to view these standards not simply as sustainability tools, but as building blocks for regulatory compliance and disclosure readiness.

IFRS S2: Connecting Net Zero Commitments to Investor Disclosures

IFRS S2 requires companies to disclose climate-related information across four pillars:

  • Governance
  • Strategy
  • Risk Management
  • Metrics and Targets

ISO 14060 could provide the supporting management system for these disclosures, while SBTi provides the validated targets disclosed under the Metrics and Targets pillar. [5]

A company may therefore disclose:
“Our net zero transition plan is developed in accordance with ISO 14060 principles for Net Zero Aligned Organizations, and our greenhouse gas reduction targets have been independently validated by the Science Based Targets initiative.”

ESRS E1: From Climate Commitments to Transition Plans

The European Sustainability Reporting Standards go even further. ESRS E1 requires organizations to disclose [6]:

  • A climate transition plan
  • Decarbonization levers and actions
  • Climate governance
  • Policies and targets
  • Capital expenditures aligned with the transition
  • Progress toward climate goals

ISO 14060 is particularly well aligned with these requirements because its primary focus is establishing the systems, governance, and implementation pathways needed to deliver net zero commitments. Meanwhile, SBTi can provide confidence that the emissions reduction pathway embedded in the transition plan is grounded in climate science.

The Emerging Climate Accountability Stack

As mandatory reporting expands globally, many organizations may adopt a three-layer approach that helps organizations move from climate ambition to implementation, verification, and transparent disclosure:

Viewed together, these frameworks illustrate how climate management is evolving from a focus on target-setting toward a more integrated model of implementation, validation, and disclosure. SBTi establishes where a company needs to go, and ISO 14060 helps define how it gets there. IFRS S2 and ESRS provide the framework for transparently communicating that journey to investors, regulators, and stakeholders.

As climate reporting evolves from voluntary commitments to mandatory accountability, companies that can integrate all three elements, credible targets, robust implementation systems, and transparent disclosure, may be best positioned to demonstrate both ambition and execution.

IFRS S2 | CSRD/ESRS EI | CSDDD

Criticisms of SBTi

SBTi’s influence has also made it a target of criticism. Some critics argue that Version 2.0 introduces too much flexibility and weakens the rigor that made SBTi valuable. Recent reporting has highlighted concerns that the revised standard allows companies to miss targets if they demonstrate “best efforts,” disclose barriers, and provide evidence of action. Critics have also raised concerns about greater flexibility around energy certificates and value chain approaches. [8]

SBTi has also faced scrutiny over governance, corporate influence, and sector-specific standards. Its oil and gas standard was reportedly paused after several major energy companies withdrew from the process, raising questions about how voluntary standards should handle hard-to-abate and fossil-fuel-intensive sectors. [9]

The central criticism is that if SBTi becomes too flexible, it risks losing scientific credibility. If it remains too strict, some companies may disengage. Version 2.0 is an attempt to navigate that tension.

Criticisms of ISO 14060

Because the standard is new and still in consultation [1], it remains to be seen how rigorous, auditable, and widely adopted it will be. ISO standards can be powerful because they are globally recognized, but they can also be broad. If ISO 14060 becomes too process-oriented, it may help companies document net zero plans without necessarily ensuring the level of emissions reductions needed for climate alignment.

Another concern is that companies may use ISO alignment as a credibility signal without pursuing SBTi-level emissions reduction ambition. The effectiveness of ISO 14060 will depend heavily on the final requirements, assurance practices, and how clearly it addresses offsets, residual emissions, Scope 3 emissions, and transition plan accountability. [7]

Final Thoughts: The Future of Net Zero Is Integration

For more than a decade, corporate climate action has focused on setting commitments. The next decade will be defined by an organization’s ability to demonstrate implementation, accountability, and measurable progress.

As regulators, investors, customers, and lenders increasingly seek evidence of credible transition planning, organizations will need more than ambitious targets alone. They will need governance structures, management systems, implementation roadmaps, performance monitoring, and transparent disclosure mechanisms capable of supporting long-term climate commitments.

Viewed through that lens, SBTi, ISO 14060, IFRS S2, and ESRS are not competing frameworks. They address different dimensions of the same challenge.

  • SBTi helps establish whether targets are scientifically credible.
  • ISO 14060 helps organizations build the systems needed to achieve them.
  • IFRS S2 and ESRS provide the disclosure framework for communicating progress and accountability to investors and stakeholders.

Organizations that successfully integrate all three approaches may be better positioned to demonstrate not only climate ambition, but climate execution. As climate reporting continues to mature, organizations will increasingly be judged not only on the ambition of their commitments, but on the credibility of their pathways and the transparency of their progress. The question is no longer simply “What is your target?” The more important question is becoming “How will you deliver it and how will stakeholders verify your progress?”

REFERENCES

1. International Organization for Standardization (ISO). IWA 42:2022 Net Zero Guidelines. Available at: ISO IWA 42 Net Zero Guidelines

2. International Organization for Standardization (ISO). ISO launches international standard for net zero alignment. June 2026. Available at: ISO Net Zero Alignment News

3. IFRS S2 Climate-related Disclosure. Available at: IFRS S2 Climate-related Disclosures

4. Science Based Targets initiative (SBTi). Corporate Net-Zero Standard Version 2.0. Available at: SBTi Corporate Net-Zero Standard V2

5. Science Based Targets initiative (SBTi). Developing the Net-Zero Standard. Available at: SBTi Net Zero Development Process

6. United Nations Race to Zero Campaign. Starting Line and Minimum Criteria. Available at: UN Race to Zero Criteria

7. International Energy Agency (IEA). Net Zero by 2050: A Roadmap for the Global Energy Sector. Available at: IEA Net Zero Roadmap

8. Financial Times. “Science Based Targets initiative softens climate rules amid criticism.” June 2026. Available at: Financial Times coverage of SBTi revisions

9. Financial Times. “Corporate climate target setter faces criticism over governance and standards.” Available at: Financial Times SBTi governance article

10. European Union. Corporate Sustainability Due Diligence Directive (CSDDD). Directive (EU) 2024/1760. Available at: https://eur-lex.europa.eu/eli/dir/2024/1760/oj

Webinar Recap: First Time CDP Disclosers

Missed last month’s Sustainability & Climate webinar, “First-Time CDP Disclosers: What You Should Know Before You Start?” You can now watch the...

Missed last month’s Sustainability & Climate webinar, “First-Time CDP Disclosers: What You Should Know Before You Start?” You can now watch the full recording on GSI’s YouTube channel.

In this session, Becky Twohey, PhD, Albert Chung, PhD, PE, and Carmen Twitchell discuss how companies can prepare for California SB 253 GHG verification and build a stronger, more defensible greenhouse gas reporting process.

The webinar covers what to expect from the verification process, common assurance questions, supporting documentation, materiality, site visits, and practical steps organizations can take now to improve readiness.

Watch the recording here: https://youtu.be/rDbhv4VN2ro

Keep an eye out for more upcoming webinars from GSI as we continue sharing insights on sustainability, climate disclosure, regulatory changes, and environmental strategy.

The Purpose of Conducting an LCA for EPR Compliance

As pressure grows to improve packaging circularity and reduce waste, governments are increasingly adopting policies that place greater responsibility for end-of-life packaging...

As pressure grows to improve packaging circularity and reduce waste, governments are increasingly adopting policies that place greater responsibility for end-of-life packaging management on producers. Extended Producer Responsibility (EPR) laws are one of the primary policy tools used to shift the financial and operational burden of packaging waste management onto producers while creating incentives for more recyclable and resource-efficient packaging designs. For companies with in-scope packaging, these laws can create significant new compliance obligations and costs. As packaging EPR requirements continue to develop, life cycle assessments (LCAs) can help producers evaluate packaging trade-offs, support redesign decisions, and, in some EPR programs such as Oregon’s, reduce EPR fees by demonstrating improved environmental performance.

Why EPR is changing packaging decisions

Although extended producer responsibility is not a new concept, the growing number of packaging-specific EPR laws being introduced has brought the issue to the forefront for many companies bringing packaged products to market. Packaging EPR laws require producers to help fund and support systems that manage packaging at the end of its useful life through producer responsibility organizations and fee structures tied to the types, weights, and amounts of packaging introduced to the market. Adding complexity to the matter is that it is up to each state to develop EPR legislation applicable to producers within its scope. The legislation is still being developed and finalized in many states that have enacted EPR laws. Tracking the different compliance requirements and staggered deadlines can add an additional layer of stress for organizations operating across multiple EPR states.

The first producer fee invoices have begun being issued in Oregon and Colorado, and the public fee schedules show that costs can vary significantly depending on the types of packaging a company has supplied in each state. While specific fee schedules and circularity incentives vary by state, in general, states reward packaging choices that support recyclability, recycled content, and reuse systems.

Additionally, packaging may be subject to eco-modulation factors that affect the fees that in-scope organizations are responsible for. Eco-modulation works by increasing or decreasing producer fees based on packaging characteristics the state wants to discourage or reward. This can mean lower fees for packaging that better supports recyclability, recycled content, or reuse systems, and higher fees for materials that are harder to recover or recycle.

Specific to Oregon, producers may also request eco-modulated fee discounts by conducting voluntary life-cycle assessments (LCAs). Oregon awards larger eco-modulation bonuses for analyses that show that a packaging change has achieved a substantial reduction in environmental impacts. Outside Oregon, LCAs can still provide strategic value by helping producers test redesign options, document environmental trade-offs, and generate evidence that may support alignment with eco-modulation frameworks in other states, although there is not the same direct financial benefit seen in Oregon’s program.

Why an LCA is a useful business tool under EPR

While Oregon’s EPR legislation directly links eco-modulation adjustments to the life-cycle impacts of in-scope packaging, LCAs offer strategic value in other EPR states by helping producers compare packaging alternatives and prioritize redesigns that align with eco-modulation criteria. Many EPR programs reward packaging choices, such as using more recycled content, improving recyclability or compostability, and encouraging reuse.

An LCA helps producers avoid packaging changes that improve one performance characteristic while creating unintended consequences in another. Comparative LCAs can help organizations determine which materials or packaging formats best meet their needs, rather than focusing on a single factor. For example, conducting an LCA may reveal that switching packaging to a certain mono-material format improves recyclability but also increases GHG emissions because the replacement material is more energy-intensive to produce. Similarly, an analysis could find that reducing packaging weight may lower material usage but could also reduce product protection, leading to higher rates of damage, spoilage, or loss. By showing how a packaging system performs across multiple life-cycle stages and impact categories, LCAs provide organizations with a better understanding of redesign and purchasing decisions.

LCAs can also support EPR-related analysis and documentation by providing consistent, comparable data on a package’s environmental impacts across raw material extraction, manufacturing, transportation, and end-of-life management. This can help organizations identify impact hotspots in the supply chain, understand where meaningful improvements are possible, and focus efforts on changes that align with EPR compliance priorities.

In some states, these incentives are already taking shape. In Colorado, producers can submit voluntary data to qualify for certain incentives. LCAs can help pinpoint which packaging changes may be most valuable to track or invest in. Minnesota’s law strongly encourages packaging formats that are reusable, recyclable, compostable, or refillable.  California requires in-scope producers to reduce plastic-covered material by 25% by 2032, adding another reason to compare packaging redesign options. LCAs can be a useful tool for producers to evaluate trade-offs and identify which redesigns are best aligned with EPR program priorities.

What an LCA evaluates and how it is performed

Organizations using LCA for EPR compliance generally conduct the assessment in accordance with ISO 14040 and ISO 14044 standards. These widely recognized standards provide a consistent framework for conducting and comparing life cycle assessments. Under these standards, an LCA is defined as a structured method for evaluating the potential environmental impacts of a product system across its life cycle.

 

 

 

 

 

Source: ISO Online Browsing Platform

For packaging, this typically means assessing impacts across key life-cycle stages, including raw material extraction, material pre-processing, product manufacturing, transportation and storage, and end-of-life management. The analysis may also consider performance-related factors such as product protection, spoilage, or product loss, as these outcomes can significantly affect the total life-cycle impact.

Under ISO 14040 and 14044, an LCA is generally conducted in four phases: goal and scope definition, life cycle inventory analysis, life cycle impact assessment, and interpretation. In practice, this defines which packaging systems are being compared and what functions they are meant to serve, gathers data on material and energy inputs, evaluates environmental impacts across selected categories, and interprets the results to understand trade-offs, hotspots, and opportunities for improvement.

Key Limitations and Cautions

While LCAs can be powerful tools for evaluating packaging alternatives, their results are heavily dependent on how the LCA is conducted. Choices such as end-of-life assumptions and data sources can materially affect the assessment outcomes, making results only as meaningful as the methodology behind them.

Packaging LCA results are most reliable when informed by the company or by other experts with product- and packaging-specific knowledge. Identifying realistic alternatives requires input on technical constraints that may not be reflected in publicly available LCA datasets. In practice, the company or its packaging provider helps identify realistic alternatives and provides the technical information needed to compare them. The LCA process then evaluates the environmental trade-offs among those packaging options. An LCA should be treated as a collaborative evaluation process, rather than a stand-alone exercise done without input from those responsible for packaging design and performance.

LCAs also do not automatically translate into lower EPR fees. A package may perform well in a life-cycle study but still fall short of an EPR program’s specific fee criteria related to recyclability, reuse, or recycled content. Additionally, conducting an LCA can require significant time, data collection, and technical review. LCAs are most useful when they are treated as structured decision-support tools that complement state-specific EPR compliance analysis.

Conclusion

As packaging EPR programs continue to take shape, producers are under increasing pressure to understand how packaging choices affect environmental performance and fee exposure. LCAs can provide a structured way to compare alternatives, identify tradeoffs, and support packaging decisions aligned with emerging EPR requirements. Although an LCA is not a substitute for state-specific compliance analysis, it can serve as a valuable decision-support tool for organizations seeking to better understand the potential environmental implications of packaging redesign options.

GSI can support comparative LCA analyses that evaluate packaging alternatives across their life cycles. This can help organizations compare options, identify unintended trade-offs, and make more informed decisions about source reduction, packaging changes, and potential EPR fee implications.

First-Time CDP Disclosers: What You Should Know Before You Start

For many companies, the first CDP disclosure starts with a simple question: Do we actually need to do this? In most cases,...

For many companies, the first CDP disclosure starts with a simple question: Do we actually need to do this? In most cases, the answer is yes. CDP began as an investor-driven climate transparency initiative and evolved into a widely used component of the sustainability reporting landscape, closely aligned with frameworks such as TCFD, IFRS S2, and GRI. Since 2020, the number of disclosers has increased by roughly 30% annually with more than 22,000 companies, representing more than half of the global market capitalization, disclosing to CDP in 2025. Whether the request to disclose originates from a customer, investor, lender, or internal leadership, CDP has increasingly become the standard mechanism through which companies are

That pressure can make a first disclosure feel high stakes. The questionnaire is detailed, the scoring can seem opaque, and the process often highlights how many internal teams, data systems and processes must collaborate to produce a credible response. The good news is that first-time disclosure does not require perfection. What matters most is understanding what CDP is actually asking for, how the scoring works, and where companies tend to lose points that could otherwise be avoided.

The biggest misconception: scoring is not just about how much you disclose

First-time disclosers often assume CDP rewards volume of information disclosed – it does not. The goal of a first response is rarely to “say everything,” but rather to “clearly demonstrate where the business currently stands.” CDP awards points according to a published set of criteria to measure the maturity of a company’s response to each question.Companies at the C level may identify climate risks, report emissions, and set goals to establish targets and seek verification in the next two years. Companies at the B level demonstrates more formal governance, documented procedures, target tracking, and integration of climate considerations into business processes. At the A level, climate

considerations are strategically embedded across the organization, supported by credible targets, and demonstrate an influence that extends beyond the company’s own operations.

Progressing through these levels is not about writing longer responses. It is about providing qualitative evidence of how climate considerations are managed and integrated into the business.

Consistency matters more than many companies expect

One of the most common ways companies lose points is through inconsistency in question responses. Qualitative questions benefit from clear, structured responses following a logic such as Situation, Task, Action, Result/Review. Even well-written narratives can still miss scoring criteria if they do not directly address specific elements of the prompt.

Quantitative questions present a different challenge – data must reconcile across the entire questionnaire. Total emissions, energy use, and related figures should align wherever they appear. Discrepancies between responses can raise questions about data quality or internal controls, and the company will lose points.

For first-time reporters, this is one of the most practical lessons. Before submission, responses should be reviewed less like a narrative report and more like an audited package. Metrics should be defined consistently and tell the same story in every response.

Timing is tighter than it looks

With the question bank set to release mid-April, the time to begin preparing is now. First-time reporters often underestimate how long it takes to coordinate internal contributors, gather supporting evidence, confirm data, review narrative responses, and resolve inconsistencies. By the time the disclosure window opens in June, companies should already know who owns governance modules, who owns emissions data, who can speak to strategy and risk, and who is responsible for reviewing and approving the final submission.

This is especially true when the disclosure depends on external assurance, target validation, enterprise risk processes, legal review, or executive signoff. While the disclosure is submitted through a single portal, the evidence needed to support it usually lives across multiple functions, including finance, sustainability, legal, operations, procurement, facilities, and executive leadership.

What first-time disclosers should prioritize

If this is your first year, the primary objective should be credibility and internal coordination rather than score maximization.

In many cases, the most valuable outcome of a first disclosure is not the grade itself. Instead, the process reveals where governance is still informal, where data collection is weak, and where strategy and environmental reporting remain disconnected. That visibility is often what enables meaningful improvement in the second year.

For first-time disclosers, CDP can be a complex and demanding process. GSI can help ease that burden by offering disclosure support, by mock-scoring questionnaire drafts to bring greater transparency to the scoring process, and by providing strategic assistance in communicating reasonable expectations to internal and external stakeholders. For companies with prior CDP disclosure experience, GSI also brings a strong track record in supporting grade improvement efforts and has even helped clients raise their score by a full letter grade.