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
• Other (please specify)

1b. Specify priority

Sequencing climate mitigation first, then moving to adaptation and resilience, matches our perception of emerging international practice; we recommend deferring biodiversity, water, pollution, and circular economy objectives until definitional consensus matures.

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

Agree

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

We agree with the six principles and with the report's candour that they trade off against one another. Credibility and interoperability are the load-bearing principles: usability serves uptake, but uptake of a label investors do not trust defeats the purpose of the exercise. Regional specificity requires the most disciplined application. Differentiated or tiered regional criteria are defensible for Canada's geography, but each regional divergence from an established comparator criterion should carry documented justification and objective qualifying tests, as we've argued for in other climate and sustainability-related standards feedback. The review cadence should also privilege stability so the taxonomy can be relied upon in long-horizon mandates and applications.

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

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?

Agree

4b. Please explain your answer in the space below

We agree with the graduated architecture, subject to four conditions. The evidence against binary alignment is in our view decisive based on the evidence from the EU model. A binary test over predominantly qualitative criteria produces false precision and defensive under-reporting. We note the Australian alignment in approach with agreement, but believe that given the scarcity of consensus in approach that this design must therefore supply its own credibility through thoughtful conditions, of which we suggest as a starting point: (1) a mandatory core that remains pass/fail, given that compliance with applicable law and FPIC obligations where triggered cannot be "partially" met and then support any alignment claim; (2) a standardized, machine-readable disclosure template for criteria met and unmet, so "partially aligned" is computable and comparable across issuers for clarity in classification based on the evidence and facts; (3) a remediation clock with consequences, on the ASEAN model, where persistent non-compliance within a defined period ends the alignment claim (the draft currently attaches no consequence to indefinitely unmet criteria); and (4) criteria drafted so that claims can be verified on a reasonable assurance basis. We would be happy to provide our full reasoning and citations if helpful, and as this detail is further scoped in development of the taxonomy.

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

Agree

5b. Please explain your answer in the space below

We note the DNSH objective set mirrors the architecture of Article 9 of the EU Taxonomy Regulation, which supports interoperability. The MSS scope extends beyond the EU baseline in two respects we support: the explicit inclusion of Indigenous rights consistent with our past positions, and the naming of taxation integrity and anti-corruption domains. We recommend the final framework name its reference instruments explicitly to support clarity in interoperability (such as the UN Guiding Principles, ILO fundamental conventions, OECD Guidelines for Multinational Enterprises, IFC Performance Standards 2 and 7).

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

Grounding generic criteria in existing Canadian law follows international practice and reduces duplicative assessment burden. The capacity to exceed domestic law is appropriate where international standards are stronger, and should be exercised deliberately: each instance should carry documented justification and objective qualifying tests, not rest on general appeals to ambition.

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

First, verification: no Canadian statute requires assurance of taxonomy-alignment claims, so the framework must build that requirement itself where needed. Second, operationalizing FPIC through a defined trigger and IFC Performance Standard 7 gives effect to the direction of the UNDRIP Act ahead of complete legislative implementation across provincial jurisdictions, a gap the report itself acknowledges. Third, standardized alignment disclosure.

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

Disclosure obligations should scale with entity and project size; the substantive standards should not. Simplified, proportionate reporting for smaller entities is appropriate. A lower bar for what constitutes significant harm would be a different label for the same claim and would undermine comparability and integrity of the framework.

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

No response.

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?

We offer a simple three-part process recommendation rather than a resolution of the underlying legal debates, which belong to rights-holders and governments. First, a defined trigger: FPIC-based engagement obligations should activate wherever an activity has potential or actual impact on Indigenous rights or interests. Second, a suggested movement toward adoption or development of an auditable operational standard: IFC Performance Standard 7 is the instrument through which other jurisdictions have operationalized Indigenous rights in project assessment, is already contractually familiar in Canadian project finance through Equator Principles institutions, and provides documented, verifiable process steps that an assurance regime can test. Third, Indigenous-led co-design of the criteria through the Indigenous Technical Working Group the report commits to, with capacity support for participation.

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

No response.

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

Agree

12b. Please explain your answer in the space below

No response.

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

Agree

13b. Please explain your answer in the space below

No response.

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?

Agree

14b. Please explain your answer in the space below

The guardrails are directionally sound, and we specifically acknowledge features that exceed international practice: categorization on gross emissions with offsets excluded, capital and operational expenditure-only claims for transition measures, and a whole-of-activity pathway requiring Scope 1 alignment with net-zero-2050 pathways. Three items will need to be addressed as this process moves forward: quantitative definitions of materiality for "materially reduce"; verification-capable criteria; and a consequence mechanism for activities that fall away from their pathway between reviews, with any grandfathering time-limited and disclosed.

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

Agree (i.e., agree in principle, with conditions)

15b. Please explain your answer in the space below

We're generally in support of a defined category presented with the alternative. Three considerations support a defined category. First, label integrity: decarbonization investment in demand-decline sectors will be financed regardless of the taxonomy's design, and in the absence of a defined category the market defines its own terms; existing international guidance already tolerates demand-decline activities within "transition" labels. Our past commentary on related consultations identified undefined labels as the primary greenwashing vector, and that logic applies with greater force here. Second, the design as proposed protects the transition category by routing oil and gas production out of "transition" and into a separate, more restrictive category, preserving the transition label for activities that can reach green alignment by mid-century. Third, information value: the distinction between stable-demand and demand-decline activities is useful, and precisely the risk distinction investors must price, and collapsing the categories discards information. Our agreement is conditional because every protective feature of the category is currently provisional: the guardrails are "potential," "significant reduction" is undefined, and development will proceed into a period of predictable political and commercial pressure. The conditions set out in our response to Question 16 should be treated as prerequisites to operationalization, not options for future research. Our full reasoning and citations are available upon request.

16. Should any additional guardrails be considered?

The illustrative list is well constructed; our recommendations concern its status and completion. (1) Elevate the seven guardrails from illustrative to a mandatory core adopted in the final Methodology Report, with the 2027 research phase directed at their calibration rather than their selection. (2) Add verification: abatement-alignment claims should be capable of verification on a reasonable assurance basis before any claim reaches market, with verifier competence standards in place; self-assessed abatement claims would place the entire taxonomy's credibility at risk. (3) Add distinct nomenclature: abatement-aligned investments should not be marketable as "green" or "sustainable" without qualification, and the category's name should survive into labelled-instrument guidance and any sovereign issuance framework. (4) Add automatic expiry: if technical screening criteria are not finalized by a date certain, the category should lapse rather than persist as an undefined marketing designation. (5) Add periodic retesting of the category's activity list against Paris-aligned demand scenarios at each review cycle, with sunset dates binding. For the calibration phase, we draw attention to the Projected Abatement Capacity framework developed by CPP Investments, which classifies abatement potential as proven, probable, or uneconomic against stated carbon-price assumptions under an explicit net-present-value rule; it offers a Canadian-origin, quantitative candidate for defining "significant reduction" that carries implicit investor buy-in, recognition, and relevance.

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

No response.

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

Agree

18b. Please explain your answer in the space below

No response.

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

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?

Criteria should be quantitative, outcome-based, and technology-neutral wherever possible, prescribing performance rather than technologies. This supports innovation, comparability, and durability of the criteria between reviews.

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?

For the green and transition categories, we agree. Scope 1 primacy reflects operator control and current data maturity, where other exposure is already internalized in the classification framework's demand-risk logic, and the committed expansion toward life-cycle thresholds as disclosure quality improves is the right trajectory, for when that matures. The abatement measures category is the exception. That category exists precisely because end-use combustion emissions cannot be abated by the producer and drive structural demand decline. An abatement claim architecture measuring only Scope 1 and 2 performance would in our view be incomplete and structurally misleading: it would certify emissions reductions at the asset while remaining silent on the emissions profile that defines the asset's risk. To the extent feasible, there should be an attempt for both upstream and downstream Scope 3 emissions to bind abatement-category claims.

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

Satisfied

23. Is there any other feedback you would like to provide on the methodology report as a whole that has not already been covered?

We urge the Council to commit, in the final report, to developing an assurance framework in parallel with the first tranche of technical screening criteria: alignment claims capable of verification on a reasonable assurance basis, competence standards for verifiers, and assurance directed at the design and implementation of policies and processes. If and where possible, this should take a utility-like approach to develop commonly needed adoption and assurance support technologies to ensure maximal adoption at the minimum cost, without demanding extensive professional services engagements of those issuers seeking to otherwise comply. We would welcome the opportunity to contribute to the 2027 research phase on the abatement measures category and to the sector-level consultations beginning this fall. Our supporting research and relevant citations are available upon request.