Taxonomy Foundations
Please feel free to answer only the questions that are of the most interest and relevance to you.
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
- Protection of biodiversity and healthy ecosystems
- Circular economy
It is proposed that the design and implementation of the Canadian taxonomy be informed by the following six principles: Credible; usable; interoperable; dynamic; regionally specific; and prioritized.
2a. Do you agree or disagree with these proposed principles as the foundation for the taxonomy?
Select
Do No Significant Harm and Minimum Social Safeguards
Please feel free to answer only the questions that are of the most interest and relevance to you.
The proposed taxonomy framework for Canada includes a set of Do No Significant Harm (DNSH) criteria and Minimum Social Safeguards (MSS), which will be designed to ensure that climate mitigation objectives do not adversely impact other environmental and social values, or legal rights. It is proposed that issuers must disclose the extent to which they meet specific criteria for both DNSH and MSS in order to claim taxonomy alignment.
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?
Select
4b. Please explain your answer in the space below
Partial alignment should not weaken the substantive safeguards themselves or allow activities with material environmental, social, human rights or health harms to be presented as equivalent to activities meeting all applicable safeguards.
The approach should distinguish between full and partial alignment and require disclosure of any material criteria that are not met, together with information on mitigation and remediation measures where appropriate. Partial alignment should be a mechanism for transparency and improvement, rather than lowering the level of protection expected of taxonomy-aligned activities.
Thresholds should be further defined with reference to potential harm to health and safety and where possible disclosures should specify a timeline and pathway toward full alignment rather than allowing indefinite partial status.
5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?
Disagree
5b. Please explain your answer in the space below
We strongly support the inclusion of DNSH and MSS frameworks that ensure that climate mitigation objectives do not come at the expense of Indigenous rights, human rights, health, or other environmental, social and governance values.
From a health sector perspective, we recommend that the DNSH framework explicitly recognize community and patient health outcomes as a safeguard category in its own right, alongside environmental and social safeguards. Climate-aligned investments and transition activities should be assessed for their potential impacts, positive or negative, on access to care, health equity, and population health. A planetary health approach recognizes the interdependence of human health, healthy ecosystems, and a stable climate, and when paired with a planetary boundaries framework, is a useful lens for assessing these interconnected impacts.
The framework should therefore consider health impacts not only where they are direct and immediate, but also where environmental or climate-related impacts can create material consequences for community health, health equity, or the resilience of health systems.
We would welcome the opportunity to contribute health-sector expertise as this section of the framework is further developed.
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?
Agree
6b. Please explain your answer in the space below
DNSH and MSS frameworks should be grounded in Canadian legislation and regulation. However, legislation should not be treated as the ceiling for taxonomy safeguards. Where Canadian legislation or regulatory requirements do not fully uphold applicable Indigenous rights, human rights or internationally recognized standards, the taxonomy should establish a higher level of ambition.
This is particularly relevant to health, where there is no comprehensive federal legal requirement to assess or disclose the health equity impacts of infrastructure or investment decisions in contrast to more established environmental impact assessment.
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
Projects and entities with greater scale, profit, or potential impact should have more comprehensive disclosure requirements, while smaller projects and entities could have more streamlined reporting requirements.
The approach should remain proportionate while maintaining appropriate safeguards.
There are useful examples internationally of tiered reporting requirements. The recently updated Charities Statement of Recommended Practice (SORP) in the UK introduces different reporting requirements based on the size of charities, including new ESG disclosure requirements for larger charities.
9. Are there any gaps in the proposed DNSH/MSS framework that could result in unintended environmental or social harms?
Health is an important gap in the proposed framework. The DNSH/MSS framework should explicitly consider potential impacts on community and patient health, access to care, health equity and population health. This is particularly important for underserved and rural communities.
Our newest Health Standards Organization Climate & Health: Specialty Reflection Matrix illustrates what this looks like in practice: hospital departments identifying backup staffing plans, diversified medication and food supply chains, and surge capacity protocols as their top climate risks. Where health facility retrofits or decarbonization investments are taxonomy-eligible (under the buildings sector), the DNSH criteria for those investments should require evidence that continuity-of-care planning has been considered, not just physical asset resilience (e.g., flood-proofing a building). More broadly, DNSH assessment for taxonomy-aligned investments in any sector should consider whether a project's construction, operation, or decommissioning could disrupt access to nearby health infrastructure or services.
Specific gaps may include: pharmaceutical and clinical waste management in the DNSH pollution-prevention criteria; labour conditions in the manufacture of medical devices and PPE, where supply chains carry documented human rights and labour risks; or health impacts on communities affected by climate-related facility closures, relocations, or service disruptions. While taxonomy alignment is voluntary, given the scale of capital it is designed to direct, we would flag the risk of care deserts emerging where decarbonization incentives favour consolidation of services into fewer, larger, more efficient facilities without an accompanying health-equity safeguard.
11. Is there any other feedback you would like to provide on the proposed MSS/DNSH framework?
The health sector has an important perspective to contribute to the development of the DNSH/MSS framework. There are international examples of sustainability and ESG reporting being incorporated into the reporting and operations of health and charitable organizations.
The recently updated UK Charities Statement of Recommended Practice (SORP), for example, introduces ESG disclosure requirements for larger charities. There may be useful similarities and lessons for how health-sector organizations could report on sustainability, investments and related environmental, social and health impacts.
We would welcome the opportunity to contribute further health-sector expertise and examples as the DNSH/MSS framework is developed.
Section 3: Activity Classification Framework
Please feel free to answer only the questions that are of the most interest and relevance to you.
The activity classification framework proposes that the green category should be limited to activities with zero or near-zero emissions that make a substantial contribution to climate change mitigation or to activities that directly enable zero to near-zero emissions climate solutions (e.g., electric vehicle manufacturing facilities)
12a. Do you agree or disagree with this approach?
Select
12b. Please explain your answer in the space below
We recommend adding quantitative thresholds and methodologies underpinning the terms "zero to near-zero" and "substantial contribution".
The framework proposes that the transition category should include activities that have materially high emissions today but have the potential to decarbonize sufficiently to align with the green definition (i.e., zero to near-zero emissions) by 2050. These activities are likely to experience stable or growing demand in Paris-aligned representative pathways due to a lack of technically feasible low-carbon substitutes (e.g., major decarbonization investments in steel, cement, and chemicals manufacturing).
13a. Do you agree or disagree with this approach?
Select
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?
Select
The report proposes that initial research on the abatement measures category should be conducted in 2027 and include select emissions-reduction measures for activities that have high Scope 1 emissions today and are unable to achieve the life cycle emissions reductions necessary to align with Paris-aligned pathways (e.g. major decarbonization investments in the upstream production, refining, and distribution of oil and gas). These are activities that are highly likely to experience declining demand as the world transitions to clean energy and alternative technologies.
The report proposes an illustrative list of guardrails for the abatement measures category that, if formally developed and finalized, would be designed to prevent carbon lock-in and ensure the abatement measures category remains credible within a Paris-aligned framework. When thinking about the taxonomy’s credibility and usability, please provide feedback on this illustrative list of guardrails.
17. Is there any other feedback you would like to provide on the proposed activity classification framework?
We recommend that the activity classification framework include clearer guidance and examples for health care-related activities, including:
1) Decarbonization and energy retrofits of health care facilities (hospitals, long-term care, and community health infrastructure);
2) Climate-resilient health care infrastructure investment, including facilities designed to withstand extreme heat, flooding, and other climate-related disruptions to care delivery;
3) Investment activities undertaken by charitable health foundations, which often differ structurally from corporate or institutional investors and may need tailored guidance on eligibility
4) Health system supply chain and Scope 3 activities, including low-carbon procurement of medical devices, pharmaceuticals, and single-use products, given that supply chain emissions represent a large proportion of most health systems' carbon footprint; and
5) Clinical decarbonization activities, such as anesthetic gas capture and substitution, and inhaler reformulation, which are unique to the health sector and unlikely to be captured under existing built-environment or industrial categories.
More explicit taxonomy language for these activities would give the health philanthropy sector with clearer terminology and guidance to identify and assess climate-aligned investments, and would help standardize how "green," "transition," and "abatement" investments are understood and reported across the sector.
Section 4: Technical Screening Criteria
Please feel free to answer only the questions that are of the most interest and relevance to you.
18a. Do you agree or disagree with the proposed approach for developing technical screening criteria?
Select
18b. Please explain your answer in the space below
We understand that sector-specific technical screening criteria will be developed in Fall 2026. We urge the Council to ensure that the health sector – including health care facility operations, health foundation investment activity, and health-related infrastructure – is included as a distinct area of focus in that process, rather than assumed to fall entirely within existing built-environment or public-sector categories.
19. Please rate each of the proposed elements for the screening criteria on a scale from “very important” to “not at all important.”
- Primarily use quantitative metrics
- Important
Final questions
22. Overall, how satisfied are you with the proposed sustainable finance taxonomy framework?
Select
23. Is there any other feedback you would like to provide on the methodology report as a whole that has not already been covered?
For future phases of the Taxonomy, we recommend climate change adaptation and resilience be prioritized. Through our Climate Action Maturity Assessment work with Accreditation Canada and our Specialty Reflection Matrix (to be used by departments across internal medicine, psychiatry, radiation oncology, addiction medicine, urology, and laboratory medicine) we have direct operational evidence of the resilience gaps climate change is creating in care delivery: backup staffing and power during extreme weather, medication and food supply chain diversification, and surge capacity planning. These are capital-intensive gaps (backup generators, digital pathology for remote coverage, resilient facility retrofits) that a future adaptation-focused taxonomy phase could help finance.
We commend the Council on this important work and look forward to continued engagement as the taxonomy is developed. Please do not hesitate to contact us for further information or collaboration.