Why ocean enters the questionnaire now
Ocean ecosystems sit at the intersection of climate change, biodiversity loss, water security and food systems. Until 2026, CDP did not have a dedicated channel for ocean related disclosure. The 2026 cycle introduces the first set of ocean questions integrated into the existing corporate questionnaire, opening a window for companies with material marine dependencies to start reporting in a structured way.
The implementation is deliberately gentle. Ocean is integrated rather than a stand alone module. Disclosure is opt in. Scoring is not yet active. The intent: build the data baseline this year, refine the questions next year, activate scoring from 2027 onwards.
What ocean disclosure covers
The 2026 ocean questions cover the same DIRO logic as the rest of the questionnaire: dependencies, impacts, risks and opportunities, but applied specifically to marine and coastal ecosystems. Topics include:
- Direct operational impacts on marine ecosystems (shipping emissions, port operations, offshore infrastructure, coastal facilities).
- Dependencies on marine ecosystem services (fisheries inputs, marine biodiversity, coastal protection).
- Pollutants entering marine environments (plastics, chemicals, sewage, agricultural runoff via rivers).
- Climate change linkages (ocean acidification, sea level rise, marine heatwaves).
- Governance and risk management specifically scoped to ocean issues.
These map closely to the TNFD ocean realm and the SBTN ocean module that is being developed. Companies aligning with TNFD or SBTN already have most of the data foundation.
Who should opt in
The expectation is highest for sectors with direct marine exposure:
- Shipping and logistics: marine emissions, fuel transitions, ballast water, port operations.
- Fisheries and aquaculture: stock management, ecosystem impacts, supply chain traceability.
- Offshore energy: oil and gas, offshore wind, marine biodiversity around installations.
- Coastal infrastructure: ports, real estate, tourism, telecommunications cables.
- Food and beverage with seafood inputs: seafood traceability, certified sourcing.
- Consumer goods with plastic packaging: marine plastic pollution as material risk.
Companies in these sectors should opt in even though scoring is inactive. The benefits:
- Establish a credible baseline before scoring goes live in 2027.
- Signal to investors and customers that you are ahead of the regulatory curve.
- Identify data gaps and start closing them now while there is no scoring penalty.
- Align disclosure with TNFD and emerging SBTN ocean methodologies.
What it does not require yet
The 2026 ocean questions are deliberately scoped to be achievable. They do not require:
- Full quantitative inventories of marine impacts the way C7 requires for emissions.
- Validated science based ocean targets (SBTN ocean methodology is still in development).
- Ocean specific verification statements.
The expectation is qualitative process disclosure plus quantitative data where it already exists. This pattern will tighten in subsequent cycles, the same way climate disclosure tightened from 2018 to 2024.
How to prepare your 2026 response
If you are opting in, follow this sequence:
1. Materiality screening. Confirm that ocean issues are material for your operations or value chain. Use the TNFD LEAP approach (Locate, Evaluate, Assess, Prepare) as a starting point, or work backwards from your supply chain and operational footprint.
2. Reuse the C2 DIRO process. The ocean questions live within C2 and the relevant theme modules. The DIRO process you describe for climate, water and forests can be extended to cover ocean. Avoid creating a parallel process; integrate ocean into the existing one.
3. Document existing data. Most companies already collect some ocean relevant data: shipping fuel consumption, plastic packaging weights, water discharge to coastal areas, seafood sourcing volumes. Map what you have before commissioning new data collection.
4. Identify partners. Marine ecosystem data often requires external partners: research institutes, NGOs, satellite providers (for shipping AIS data), certification bodies (MSC, ASC for seafood). Build the partnership network in 2026 so the data flows in 2027.
5. Align with TNFD and SBTN. Companies disclosing under TNFD already address marine realms. Companies preparing for SBTN ocean methodology will produce data that maps directly into CDP. Align disclosures across frameworks to avoid duplicated work.
For broader context on how CDP integrates with other frameworks see CDP vs CSRD: differences, overlap, and how to disclose once.
What ocean means for non marine sectors
Even companies without direct marine operations should consider opt in if:
- Their plastic packaging contributes to marine pollution.
- Their agricultural supply chain runs off into watersheds that reach the ocean.
- Their shipping emissions are material to their Scope 3 category 4 (upstream transportation).
- Their financed activities (banks, asset managers) have material ocean exposure.
For these sectors the disclosure is lighter, focused on indirect impacts and value chain exposure rather than direct operations. Even at this level, opting in signals proactive risk management.
What changes in 2027
Based on the trajectory of plastics (introduced 2024, expanded 2026, scoring expected 2027 or 2028), ocean is likely to follow a similar arc:
- 2026: opt in, unscored, baseline data collection.
- 2027: questionnaire refinement based on 2026 disclosures, possibly first scoring for high impact sectors.
- 2028 onwards: full scoring integration and broader sector applicability.
Companies that establish ocean disclosure in 2026 enter the scoring phase with two years of trend data and refined methodology. Companies that wait start from zero in 2027 or 2028.
Where Dcycle fits
Dcycle’s environmental data architecture is designed to extend from climate to water to forests to ocean using the same canonical inventory. The same vessel level fuel data that feeds Scope 3 category 4 emissions also feeds ocean shipping disclosures. The same plastic packaging data that feeds C10 also informs marine pollution disclosures. Building the architecture once, then extending it as new themes activate, is the architecture this 2026 cycle rewards.
To see how Dcycle structures this for ocean and adjacent themes, request a demo.
Final thought
Ocean disclosure in 2026 is a low pressure, high signal opportunity. There is no scoring penalty for opting out and minimal scoring upside for opting in. But the strategic value is in the data you collect during the unscored window. Two years of structured ocean data positions you for the 2028 scoring cycle in a way no end of year scramble can replicate.