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

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

Neutral

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

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?

Disagree

4b. Please explain your answer in the space below

Full alignment with all DNSH/MSS criteria should be met to be aligned with the EU taxonomy and also remaining in line with the approach proposed for Canada in 2022 Taxonomy Roadmap. Failure to meet any DNSH/MSS criteria would prevent an activity from achieving taxonomy-aligned status. The proposed partial alignment approach may lead to projects that do not meet the DNSH/MSS criteria to be considered as taxonomy-aligned and without stronger requirements to meet the MSS criteria, there is a risk of false designation of sustainability that is fundamentally incompatible with the framework's commitment to Indigenous rights. Partial alignment risks treating respect for Indigenous rights to be treated as optional rather than mandatory and put disproportionate and additional burden of addressing rights violations on Indigenous communities and nations.

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

The proposed objectives covered in Canada’s DNSH framework include climate change adaptation, protection of biodiversity and healthy ecosystems, water conservation, pollution prevention and control, and circular economy. Canada’s MSS framework's proposed objectives of Indigenous rights, human rights, labour standards, corruption and bribery controls, and taxation integrity. Climate Action Network Canada notes that all these objectives are important to the taxonomy’s integrity.

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

The MSS framework should be grounded in existing Canadian environmental and human rights law. In particular, the Constitution Act, 1982, the UNDRIP Act, and DRIPA should be particularly noted as a foundation of the framework, recognizing the need to go beyond existing laws and standards where they fall short of meeting the minimum standards established by the UN Declaration. Going beyond these in the DNSH/MSS framework will also encourage efforts to meet international standards for best practices and set high standards.

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

Canadian legislation including UNDRIP Act and DRIPA should serve as the minimum standard. Canada must go beyond existing national laws and standard where necessary to meet the minimum protections and principles affirmed in UNDRIP to fully and meaningfully uphold Indigenous rights.
Regarding nature and biodiversity, Canadian legislation do not fully reflect the realities of evolving scientific evidence like the findings of the Intergovernmental Panel on Climate Change and the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services. Furthermore, Canadian laws do not always fully capture the evolving nature of Canada's international commitments like the Paris Agreement, Kunming-Montreal Global Biodiversity Framework, Canada's Nature Strategy, and Quebec's Nature Plan. DNSH criteria should help address these gaps by considering cumulative impacts, ecosystem connectivity, and alignment with internationally recognized frameworks such as the TNFD.

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

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

Under the proposed framework, an activity can achieve taxonomy-alignment status even if it fails to meet some DNSH/MSS criteria. This could result in unintended environmental or social harms and a binary approach with a grace period for compliance should be adopted to ensure it avoids such unintended consequences and aligned with taxonomy approach adopted by Canada's close partners like the EU.

Operationalizing Indigenous rights, including UNDRIP principles and FPIC is essential to ensuring that activities designated as “environmentally sustainable” reflect genuine ecological sustainability rather than sustainability assessed in isolation from the rights, laws, and knowledge systems of the Indigenous Peoples who have longstanding relationships with those lands and waters.

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 MSS framework should include specific and mandatory criteria that ensure activities violation Indigenous rights cannot receive taxonomy-aligned status. Criteria should be grounded in UNDRIP and exclude any activities that proceed without FPIC and undermine Indigenous Peoples' rights to self-determination and sovereignty.

Operationalizing UNDRIP and FPIC principles should include specific requirements that demonstrate compliance and adherence with Indigenous rights, evidence that FPIC obligations were properly met rooted in and appropriate for the rights-holder's unique system of governance, evidence that all necessary and relevant information was provided in culturally appropriate and accessible formats, evidence that sufficient time were given for community's decision-making process, evidence that decisions were made through Indigenous peoples' own representative institutions and provided free and voluntary consent required under UNDRIP, documentation that consent can be withdrawn or renovated if circumstances materially change, and requiring verification with rights-holders that FPIC was appropriately obtained and maintained, rather than relying on companies' self-reporting and disclosure.

Any infringement of Indigenous rights, failure to obtain and maintain FPIC, and human rights violations should automatically disqualify an activity from receiving the designation.

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

Neutral

12b. Please explain your answer in the space below

While the methodology presents a strong definition for green activities, the label's value is at risk if it is not supported by a strict fossil-fuel-free framework. Climate Action Network Canada recommends that both the green and transition categories exclude any fossil fuels and that the taxonomy requires transition plans from companies within a certain timeframe after receiving taxonomy financing.

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

Agree

13b. Please explain your answer in the space below

A key strength of the definition is that it “would not include activities related to oil and gas production” (Methodology Report, page 25). Another strength is that it includes activities that “have the potential to decarbonize sufficiently to align with the green definition (i.e., zero to near-zero emissions) by mid-century” and with stable or growing demand in Paris-aligned pathways, such as steel, cement, and chemicals manufacturing (Methodology Report, page 29).

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

Climate Action Network Canada recommends the inclusion of entity-level
guardrails for both the whole-of-activity and the transition measures pathway. It is necessary for both pathways to have guardrails that ensure the eligible activities and facilities do not enable the production of or prolong the use of fossil fuel-based energy, including liquefied natural gas.

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

Strongly disagree (i.e., disagree on fundamentals)

15b. Please explain your answer in the space below

Climate Action Network Canada strongly recommends that the proposed abatement measures category be excluded from Canada's sustainable finance taxonomy, including any eligibility for oil and gas activities.

The proposed guardrails for the abatement measures category face a number of challenges regarding their scientific validity and practicality. First, they do not address downstream (Scope 3) combustion emissions, the vast majority of the oil and gas sector's climate impact (Suzuki, 2025). Second, the guardrails rely on activity-level criteria but ignore entity-level transition credibility. Fossil fuel companies can invest in abatement while simultaneously expanding production. To date, no Canadian oil and gas companies have acknowledged the need for a managed decline. Third, distinguishing between "existing" and "new" infrastructure is nearly impossible because oil and gas operations often expand incrementally. The only credible guardrail to protect the taxonomy’s credibility is exclusion of oil and gas.

Furthermore, the abatement measures category is fundamentally misaligned with scientific models for achieving net-zero emissions in line with the goals of the Paris Agreement. Global research from the International Energy Agency (IEA) and the Intergovernmental Panel on Climate Change (IPCC) shows that oil and gas production must be rapidly phased down to limit global warming to well below 2°C (IEA, 2021; IPCC, 2022; IPCC, 2023). The abatement measures category does not contribute to the phase out of oil and gas.

There is no need for the abatement measures category or label under the taxonomy: oil and gas companies can still access funds for marginal emissions reduction measures. The taxonomy should maintain its mandate of only identifying activities that align with the climate transition. The inclusion of the category is not necessary for the oil and gas sector to continue accessing capital – the taxonomy does not prohibit investment in any sector. Canadian oil and gas companies are currently achieving windfall profits for Q1 2026 (Bakx, 2026; Canadian Press, 2026). Significant public subsidies are already available to the sector for CCUS investments (Krugel, 2026). The Government of Canada has provided $85.2 billion CAD to the industry since 2020 (Environmental Defence Canada, 2026). Private investors can make independent decisions to invest in oil or gas related projects regardless of the taxonomy. Attaining a label under Canada’s taxonomy is not necessary.

Suzuki, D. (2025, June). The burning issue of fossil-fuelled Scope 3 emissions. https://davidsuzuki.org/story/the-burning-issue-of-fossil-fuelled-scope-3-emissions/
IEA. (2021). Net Zero by 2050. A Roadmap for the Global Energy Sector. https://iea.blob.core.windows.net/assets/deebef5d-0c34-4539-9d0c-10b13d840027/NetZeroby2050-ARoadmapfortheGlobalEnergySector_CORR.pdf
International Institute for Sustainable Development. (2024, May). Transitioning Away From Oil and Gas: A production phase-out primer. IISD Report. https://www.iisd.org/system/files/2024-05/transitioning-away-from-oil-gas.pdf
IPCC. (2022). Mitigation Pathways Compatible with Long-term Goals. Chapter 3. https://www.ipcc.ch/report/ar6/wg3/downloads/report/IPCC_AR6_WGIII_Chapter03.pdf
IPCC. (2023). Sixth Assessment Report. Synthesis Report. https://www.ipcc.ch/assessment-report/ar6/
Bakx, K. (2026, April 27). The $100 barrel: oil producers begin unveiling profits and windfall spending plans. CBC. https://www.cbc.ca/news/canada/calgary/bakx-wti-iran-q1-earnings-oil-9.7176422
Canadian Press. (2026, May 5). Suncor first-quarter earnings jump to $2.1B as it reports record production. CTV News. https://www.ctvnews.ca/calgary/article/suncor-first-quarter-earnings-jump-to-21b-as-it-reports-record-production/
Krugel, L. (2026, July 13). Agreement reached on multibillion-dollar Pathways carbon capture and storage project. CBC. https://www.cbc.ca/news/canada/edmonton/alberta-ottawa-pathways-oilsands-carbon-capture-9.7268392
Environmental Defence Canada. (2026). Climate Promises, Industry Handouts. Canada’s Fossil Fuel Funding in 2025. https://environmentaldefence.ca/wp-content/uploads/2026/05/Environmental_Defence_2025_FFS_Report-1.pdf-1.pdf

16. Should any additional guardrails be considered?

The only credible guardrail to protect the taxonomy’s credibility and scientific validity is exclusion of oil and gas.

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

Engagement with Indigenous-led organizations, technical experts, industry representatives, and international advisory groups will be particularly valuable to the process of developing technical screening criteria.

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

Very 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?

The taxonomy should be similarly specific and prescriptive as the Australian taxonomy, which relies on performance-based standards for emissions intensity as well as prescriptive definitions of what does or does not count (e.g. buildings sector exclusion of all combustion of fossil fuels for normal on-site operations, specific list of eligible technologies that count as transition measures). It also relies on external standards for products (e.g. energy labels, buildings ratings).

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?

Climate Action Network Canada encourages the Council to address Scope 2 and 3 emissions expeditiously, as these are frequently higher and more material to global emissions than Scope 1 emissions. Taxonomies in other jurisdictions have formulated technical screening criteria to address Scope 2 & 3 emissions for industries where these represent the majority of emissions. The Canadian taxonomy should build on these existing best practices.

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

Select