1a. The first phase of taxonomy development will focus on climate mitigation. In subsequent phases of the Canadian taxonomy, which objectives should be prioritized? Please select your top choices.

• Climate change adaptation / resilience
• Circular economy

2a. Do you agree or disagree with these proposed principles as the foundation for the taxonomy?

Strongly agree

2b. Please share the reason for your answer in the space provided

Affine Climate Solutions supports the proposed principles as a strong foundation for a credible and usable Canadian sustainable finance taxonomy. Collectively, they strike the right balance between environmental integrity, practical application and alignment with international approaches.
We particularly support the emphasis on science-based and measurable criteria, clear transition pathways, interoperability, regional and sectoral relevance, and periodic review as technologies, markets and policy evolve. These principles recognize that the taxonomy must be sufficiently rigorous to maintain investor confidence while also being practical for financial institutions and businesses to apply.
The principles also provide an appropriate basis for developing criteria that reflect the realities of different sectors. For long-lived assets such as buildings, this will be important to ensure that transition criteria recognize measurable progress, capital-replacement cycles and credible pathways to near-zero emissions, while maintaining clear safeguards against carbon lock-in.
Applied consistently, the principles should support a taxonomy that is ambitious, trusted and capable of mobilizing capital at scale across the Canadian economy.

3. Please rate each of the principles below on a scale from “very important” to “not at all important.”

Credible

Very important

Usable

Very important

Interoperable

Important

Dynamic

Very important

Regionally Specific

Important

Prioritized

Very important

4a. Do you agree or disagree with the proposed partial alignment approach, which would require entities to disclose the extent to which DNSH/MSS criteria are or are not met rather than requiring full alignment with all DNSH/MSS criteria?

Strongly agree

4b. Please explain your answer in the space below

Affine Climate Solutions supports the proposed partial alignment approach. Requiring full alignment with every DNSH and minimum social safeguards criterion from the outset could significantly limit the taxonomy’s practical use, particularly where data, verification methods or consistent sector-specific criteria are not yet widely available.
A disclosure-based approach can preserve transparency while allowing the taxonomy to support market development and improvement over time. Entities should clearly identify which DNSH and MSS criteria have been assessed, which have been met, where information is unavailable, and where gaps remain.

5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?

Strongly agree

5b. Please explain your answer in the space below

Affine Climate Solutions supports the proposed scope of objectives under the Do No Significant Harm and Minimum Social Safeguards frameworks.
The application of these objectives should be proportionate, risk-based and tailored to each sector. Criteria should focus on the most material potential harms and avoid duplicative or immaterial reporting requirements. For buildings, for example, the most relevant considerations may include physical climate risk, refrigerants, water use, construction waste, site impacts, occupant health and safety, and responsible labour practices.
Clear guidance, standardized evidence requirements and appropriate reliance on recognized certifications or professional attestations will be important to make the framework credible and practical to implement. The key is to align to existing standards and practices and their evidence thresholds versus creating net new ones.

6a. Do you agree or disagree with the proposed approach to grounding the DNSH/MSS frameworks in Canadian legislation and going beyond existing laws and standards where necessary?

Neutral

6b. Please explain your answer in the space below

Affine Climate Solutions strongly supports grounding the DNSH and MSS frameworks in applicable Canadian legislation and regulatory standards. However, we do not support routinely extending these requirements beyond existing law, particularly for the real estate sector.
The taxonomy’s primary role for buildings should be to identify and mobilize capital toward improved energy and carbon performance. Adding multiple environmental and social requirements that exceed established legal standards would create significant complexity, uncertainty and compliance cost, while potentially reducing industry participation and slowing investment in building decarbonization.
Canadian real estate owners already operate within extensive federal, provincial and municipal requirements covering environmental protection, building safety, accessibility, labour practices, human rights and Indigenous consultation. Compliance with these requirements should generally provide the baseline for DNSH and MSS assessment.
International experience, most notably in the EU, shows that DNSH and MSS requirements tend to be much harder to implement once they go beyond what domestic law already requires. The result has been heavier administrative burden, gaps in available data, and weaker uptake.

7. In which areas, if any, is it necessary to go beyond existing laws and standards for the DNSH/MSS framework?

Areas that go beyond existing laws and standards should be limited to circumstances where additional disclosure is necessary for investors and other market participants to understand a material risk.
For real estate, physical climate risk is an appropriate area for additional disclosure. Taxonomy-aligned buildings should disclose whether material physical climate risks have been assessed and, where material risks are identified, whether mitigation or adaptation measures are planned. The focus should be on consistent assessment and transparency, with applicable building codes and regulatory requirements continuing to establish the minimum performance standard.
The taxonomy should avoid creating a broad parallel regulatory regime covering matters that are already governed through established environmental, building, labour and human-rights requirements.

8a. Do you agree or disagree that different DNSH/MSS standards should apply to projects or entities of different sizes? E.g. more comprehensive disclosures required for larger projects and/or entities, with more streamlined disclosures for smaller projects and/or entities?

Agree

8b. Please explain your answer in the space below

Affine Climate Solutions supports proportionate DNSH and MSS disclosure requirements based on building size and complexity.

A simple two-level approach would work well for real estate:

Streamlined: Buildings captured by a nationally consistent small-building definition namely Part 9 Buildings as per the National Building Code. Requirements would focus on available energy and carbon information, a basic physical climate risk screen, and confirmation of no known material non-compliance.

9. Are there any gaps in the proposed DNSH/MSS framework that could result in unintended environmental or social harms?

Affine Climate Solutions does not identify any material gaps that require additional DNSH or MSS objectives at this stage. The proposed framework already covers a broad range of environmental and social considerations.

The priority should now be clear sector-specific guidance, proportionate evidence requirements and practical implementation. Early application of the taxonomy will provide better evidence of where additional safeguards or clarification may be needed.

10. How should the taxonomy operationalize the principles of the UN Declaration on the Rights of Indigenous Peoples and, in particular, the principle of Free, Prior, and Informed Consent, in the MSS framework?

The taxonomy should operationalize UNDRIP and Free, Prior, and Informed Consent through alignment with applicable Canadian laws.

Requirements should be proportionate to the nature, location and potential impacts of the activity. For existing buildings and routine retrofit projects, a confirmation of compliance with applicable legal and regulatory requirements should generally be sufficient.

11. Is there any other feedback you would like to provide on the proposed MSS/DNSH framework?

The taxonomy should remain focused primarily on energy and carbon performance. For real estate, the MSS and DNSH framework should identify material environmental or social harms that are significantly beyond normal sector practice, supported by clear disclosure and confirmation of compliance with applicable laws and standards.

A focused first-cycle approach will support practical adoption while preserving the credibility of the taxonomy.

12a. Do you agree or disagree with this approach?

Agree

12b. Please explain your answer in the space below

Affine Climate Solutions supports limiting the green category to activities with zero or near-zero emissions, or activities that directly enable those outcomes.

For Canadian buildings, near-zero should be defined through a performance threshold that reflects Canada’s colder climate, existing building systems and electrical infrastructure. A practical starting point for Green would allow no more than 10% of annual building energy to come from on-site fossil fuels, combined with energy efficiency performance in approximately the top 15% of comparable buildings.

The fossil-energy threshold should tighten over successive taxonomy cycles, moving from 10% toward less than 1% as low carbon electrical capacity expands and low-carbon technologies become more widely deployable. This provides a clear path to near-zero emissions while recognizing that Canada’s transition will differ from warmer jurisdictions such as Australia.

13a. Do you agree or disagree with this approach?

Strongly agree

13b. Please explain your answer in the space below

Affine Climate Solutions strongly supports a transition category for activities that can align with the green definition over time.

For real estate, the category should include three complementary pathways:

Performance pathway: Buildings that are already ahead of the market and making measurable progress toward green alignment.

Plan pathway: Buildings with a credible, time-bound capital plan that aligns major upgrades and equipment replacement to catch up to a Paris-aligned trajectory. This pathway should be phased out by 2040.

Measure pathway: Major individual projects that materially reduce energy use or fossil-fuel consumption, specifically where whole-building data is not yet available. This pathway should be phased out by 2040.

This category will likely include the largest share of qualifying buildings. Owners need incentives both to maintain leading buildings and to invest in measurable improvements that help underperforming buildings catch up.

Performance thresholds should strengthen every five years so that qualifying buildings remain approximately within the top 10–15% of the market and a substantial portion of the building stock reaches Paris alignment ahead of 2050.

14a. Do you agree or disagree that the proposed guardrails for the transition category (both for the whole-of-activity and measures pathways) are sufficient to protect the science-based credibility of the category and reduce the risk of carbon lock-in, while supporting usability?

Strongly agree

14b. Please explain your answer in the space below

Affine Climate Solutions agrees that the proposed guardrails provide a sound basis for maintaining scientific credibility, limiting carbon lock-in and supporting practical use.
For real estate, the guardrails should be applied through clear performance trajectories, time-bound transition plans and restrictions on new long-lived fossil-fuel equipment that is inconsistent with alignment by 2050.
Dual-fuel systems should remain eligible as a transitional solution where they materially reduce annual fossil-fuel use and place the building on a declining fossil-energy trajectory. In colder Canadian climates, they can allow heat pumps to serve most annual heating demand while retaining limited fossil-fuel capacity for the coldest periods. This can achieve substantial near-term emissions reductions, avoid disproportionate electrical upgrades and support broader market adoption.
Dual-fuel systems should therefore be assessed against annual fossil-energy performance and a defined pathway to near-zero emissions, rather than treated as carbon lock-in solely because some fossil-fuel capacity remains.

15a. Do you agree or disagree that the taxonomy should include a third “abatement” category, as proposed, that covers demand-decline activities?

Prefer not to answer

17. Is there any other feedback you would like to provide on the proposed activity classification framework?

Great work on the classification!

18a. Do you agree or disagree with the proposed approach for developing technical screening criteria?

Strongly agree

18b. Please explain your answer in the space below

Affine Climate Solutions supports the proposed approach to developing technical screening criteria. Criteria should be science-based, measurable, sector-specific and practical to apply using data that market participants can reasonably access.

For real estate, the criteria should prioritize energy and carbon performance, recognize phased transition pathways, and strengthen at regular five-year intervals. They should also accommodate both whole-building performance and major equipment improvements where complete building data is not yet available.

19. Please rate each of the proposed elements for the screening criteria on a scale from “very important” to “not at all important.”

Forward-looking wherever possible

Very important

Include sunset and/or sunrise dates where relevant

Very important

Revise as necessary during regular review periods

Very important

Primarily use quantitative metrics

Very important

Primarily focus on Scope 1 emissions but address Scope 2 and 3 emissions where feasible and/or material

Important

Informed by a range of robust methods

Very important

20. When thinking about the taxonomy’s credibility and usability, how technologically specific or prescriptive should the technical screening criteria be?

Technical screening criteria should focus on measurable energy and carbon outcomes rather than prescribing specific technologies. This allows building owners to select the most appropriate pathway for their climate, building systems, electrical capacity and capital cycle.

Limited technology-specific guardrails are appropriate where needed to prevent long-term carbon lock-in. For example, dual-fuel systems should qualify as a transitional solution where they materially reduce fossil-fuel use and support a declining fossil-energy trajectory. Eligibility for new dual-fuel installations should tighten at least by 2040, to ensure tightening performance metrics are met.

21. Do you agree or disagree with the proposed approach of focusing primarily on Scope 1 emissions, and addressing Scope 2 and 3 emissions where feasible and/or material?

Affine Climate Solutions supports a primary focus on Scope 1 emissions, provided that building energy performance is assessed alongside it.

For real estate, the core metrics should be fossil energy share and weather-normalized energy use intensity. Together, these capture the three essential elements of building decarbonization: conservation, energy efficiency and electrification.

Scope 2 emissions should not be a primary eligibility metric for buildings because grid carbon intensity varies significantly by region and changes over time. Owners should be assessed on the energy they use and the extent to which they reduce onsite fossil-fuel consumption, rather than on factors largely outside their control.

Embodied carbon should be addressed as a material Scope 3 consideration for new construction and major renovations. Initially, the emphasis should be on consistent measurement and disclosure, with the taxonomy able to strengthen expectations over time as data, benchmarks and market practices mature.

22. Overall, how satisfied are you with the proposed sustainable finance taxonomy framework?

Very satisfied