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.
- Protection of biodiversity and healthy ecosystems
- Water and marine resource conservation
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?
Neutral
2b. Please share the reason for your answer in the space provide
Please see our comments.
3. Please rate each of the principles below on a scale from “very important” to “not at all important.”
- Credible
- Important
- Usable
- Important
- Interoperable
- Important
- Dynamic
- Important
- Regionally Specific
- Important
- Prioritized
- Important
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?
Neutral
4b. Please explain your answer in the space below
Please see our comments.
5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?
Neutral
5b. Please explain your answer in the space below
Please see our comments.
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
Please see our comments.
7. In which areas, if any, is it necessary to go beyond existing laws and standards for the DNSH/MSS framework?
Please see our comments.
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?
Neutral
8b. Please explain your answer in the space below
Please see our comments.
9. Are there any gaps in the proposed DNSH/MSS framework that could result in unintended environmental or social harms?
Please see our comments.
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?
Please see our comments.
11. Is there any other feedback you would like to provide on the proposed MSS/DNSH framework?
please see our comments
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?
Neutral
12b. Please explain your answer in the space below
Please see our comments.
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?
Neutral
13b. Please explain your answer in the space below
Please see our comments.
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?
Neutral
14b. Please explain your answer in the space below
Please see our comments.
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.
15a. Do you agree or disagree that the taxonomy should include a third “abatement” category, as proposed, that covers demand-decline activities?
Neutral
15b. Please explain your answer in the space below
Please see our comments.
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.
16. Should any additional guardrails be considered?
please see our comments
17. Is there any other feedback you would like to provide on the proposed activity classification framework?
please see our comments
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?
Neutral
18b. Please explain your answer in the space below
please see our comments
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
- Important
- Include sunset and/or sunrise dates where relevant
- Important
- Revise as necessary during regular review periods
- Important
- Primarily use quantitative metrics
- Important
- Primarily focus on Scope 1 emissions but address Scope 2 and 3 emissions where feasible and/or material
- Very important
- Informed by a range of robust methods
- Important
20. When thinking about the taxonomy’s credibility and usability, how technologically specific or prescriptive should the technical screening criteria be?
please see our comments
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?
please see our comments
Final questions
22. Overall, how satisfied are you with the proposed sustainable finance taxonomy framework?
Neutral
23. Is there any other feedback you would like to provide on the methodology report as a whole that has not already been covered?
The Canadian Council for Indigenous Business (CCIB) welcomes the opportunity to comment on the draft Methodology Report. CCIB is a national, member-based organization dedicated to advancing Indigenous economic prosperity and removing barriers to Indigenous business participation in the Canadian economy.
CCIB review of the draft report identifies a few gaps that need to be addressed. In particular, how does the taxonomy interact with the rights and interests of Indigenous People’s of Canada. On this measure, there is room for improvement.
Exclusion of Indigenous Knowledge and Perspectives from Core Definitions
The draft report’s definitions of green and transition activities, and the proposed technical screening criteria, are developed within a narrow Western scientific and quantitative framework focused primarily on greenhouse gas emissions and interoperability with international taxonomies. Indigenous Knowledge systems — which offer distinct, place-based understandings of sustainability, land stewardship, and long-term resource management — are not incorporated into these foundational definitions.
This omission is significant. Many activities and practices led or informed by Indigenous Knowledge in forestry, agriculture, land management, and resource development may not align neatly with the proposed metrics yet deliver broader environmental and community benefits. By failing to create explicit space for Indigenous Knowledge in determining what constitutes a sustainable or green outcome, the taxonomy risks excluding or undervaluing legitimate Indigenous economic activities and reinforcing existing patterns of exclusion from capital flows.
CCIB recommends that the final methodology explicitly recognize Indigenous Knowledge as a valid and necessary input into the definition of sustainability criteria, particularly for sectors with strong Indigenous presence such as mining, forestry, and agriculture. Future sector-specific criteria development should include dedicated mechanisms for Indigenous Knowledge holders to contribute directly.
Economic Reconciliation as the Primary Objective
Any Canadian sustainable finance taxonomy must be evaluated first against its contribution to economic reconciliation — the meaningful participation of Indigenous businesses in the economy on fair terms. Other objectives, while relevant, must not be permitted to override or complicate Indigenous economic interests.
The draft report acknowledges historical exclusion of Indigenous peoples and the importance of respecting Indigenous rights. However, it does not sufficiently translate these acknowledgements into concrete economic opportunities for Indigenous businesses. CCIB urges the Council to reframe the taxonomy’s purpose statement to place economic reconciliation and Indigenous business participation as core objectives.
Indigenous Procurement and Equity Participation
Where the taxonomy contemplates or implies equity participation by Indigenous communities in projects (particularly in mining and critical minerals), CCIB emphasizes that equity returns are typically long-term and uncertain for many communities. Indigenous procurement — direct contracting, supply chain participation, and meaningful set-aside opportunities for Indigenous businesses — delivers immediate, measurable economic benefits, employment, and capacity development plus align these supply chain activities with Indigenous values.
CCIB recommends that strong Indigenous procurement commitments be recognized as a primary indicator of social and economic contribution within the Minimum Social Safeguards framework and any future sector criteria. Equity participation is welcome and needed but should not be presented as the sole measure of Indigenous benefit. Procurement requirements provide more reliable and near-term economic reconciliation outcomes.
Minimum Social Safeguards and Free, Prior, and Informed Consent
CCIB supports the inclusion of Indigenous rights within the proposed Minimum Social Safeguards (MSS) framework and the report’s reference to the UNDRIP Act and Section 35. However, the current treatment remains underdeveloped. Operationalizing Free, Prior, and Informed Consent (FPIC) requires clear, enforceable standards that respect Indigenous governance structures and decision-making timelines, rather than procedural consultation alone.
CCIB further recommends that MSS assessments explicitly consider the extent to which projects deliver Indigenous procurement and local economic benefits, in addition to consent processes. Without this, there is a risk that taxonomy-aligned projects could proceed while delivering limited tangible economic benefit to affected Indigenous communities.
Sector Observations and Usability
CCIB notes the six priority sectors identified for criteria development. In mining and critical minerals, forestry, and electricity, the taxonomy must avoid creating criteria that disadvantage Indigenous businesses or community-owned enterprises, particularly those operating in remote or northern regions. Reporting and verification requirements should be practical for Indigenous SMEs and should not impose disproportionate burdens relative to the scale of activity.
CCIB also supports the report’s recognition of the need for regional differentiation. This principle should be applied concretely in sector criteria to reflect the distinct economic realities and opportunities in Indigenous communities.
Governance and Future Engagement
Meaningful Indigenous participation in the governance of the taxonomy is essential. CCIB recommends dedicated Indigenous representation on the Council and advisory bodies, as well as specific Indigenous Knowledge workstreams within the Technical Working Groups for relevant sectors. Participation must extend beyond the application of safeguards to the actual development of definitions and criteria.
CCIB is prepared to contribute constructively to this work, including through nominations to Technical Working Groups and participation in future sector consultations.
Conclusion
The draft Methodology Report represents an important step in developing Canadian sustainable finance guidance. However, without explicit integration of Indigenous Knowledge into the core definitions of sustainability, and without placing economic reconciliation and Indigenous procurement as integral to the framework, the taxonomy risks becoming another mechanism that talks about Indigenous inclusion while delivering the opposite outcome and actually preventing or limiting Indigenous participation.
CCIB urges the Council to address these gaps in the final report so that the taxonomy supports, rather than constrains, Indigenous economic prosperity.
We welcome the opportunity to discuss these comments further.