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 provide

We agree that principles should emphasize quantitative metrics / evaluation criteria where possible to provide clear guidance for what would be considered taxonomy aligned. We also agree that the taxonomy should be usable – promoting feasible and cost-effective technology pathways while limiting reporting burden.

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

Credible

Important

Usable

Very important

Interoperable

Important

Dynamic

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?

Strongly agree

4b. Please explain your answer in the space below

For complex, multi-jurisdictional industries, achieving binary alignment with every DNSH/MSS criteria is practically impossible and would limit taxonomy uptake. A partial alignment approach provides necessary transparency for investors while remaining usable.

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

Generally agree with the proposed scope, provided that key terms are clearly defined and expectations around supply chain due diligence are practical and proportionate.

The proposed DNSH criteria (adaptation, biodiversity, water, pollution, and circular economy) and MSS criteria (Indigenous rights, human rights, labour, anti-corruption, and taxation integrity) capture the key environmental and social considerations that would be expected in a sustainable finance framework. However, some elements would benefit from further clarification. For example, "taxation integrity" is not a clearly defined concept and could be interpreted in different ways. If it is intended to refer to compliance with Canadian tax laws and regulations, that should be stated explicitly.

Similarly, supply chain expectations under the human rights criteria should be scoped in a way that is practical and achievable. Limiting due diligence requirements to Tier 1 suppliers would provide a clearer and more workable approach, while avoiding the significant challenges associated with tracing and verifying lower tiers of complex supply chains.

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?

Strongly disagree

6b. Please explain your answer in the space below

Strongly disagree with going beyond existing laws. The framework should use existing Canadian environmental and social laws as its foundation. Experience in other jurisdictions, particularly the EU, suggests that when DNSH and MSS requirements extend beyond domestic legislation, implementation becomes significantly more challenging. It creates additional administrative burdens, data availability issues, and lower levels of company participation. Australia has largely avoided these challenges by grounding its MSS in domestic legal requirements and using international frameworks, such as the IFC Performance Standards, as reference guidance rather than as mandatory compliance criteria.

Canada is not starting from a blank slate. We already have robust environmental, labour, and social protections in place, including under the Canada Labour Code. Creating additional requirements based on international standards may introduce overlap and legal uncertainty without delivering materially better outcomes

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

Canada already has robust environmental, labour, and anti-corruption frameworks in place. Where gaps exist, particularly in global supply chains, the taxonomy should leverage existing legislative requirements rather than creating new, standalone obligations. For example, human rights due diligence expectations should align with Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act and other applicable laws, providing a clear and practical basis for compliance.

Experience in other jurisdictions, particularly the EU, suggests that when DNSH and MSS requirements extend beyond domestic legislation, implementation becomes significantly more challenging. It creates additional administrative burdens, data availability issues, and lower levels of company participation. Australia has largely avoided these challenges by grounding its MSS in domestic legal requirements and using international frameworks, such as the IFC Performance Standards, as reference guidance rather than as mandatory compliance criteria.

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?

Disagree

8b. Please explain your answer in the space below

Do not differentiate requirements based on the size of the entity. Instead, apply requirements based on the scale and potential impacts of the specific project or activity.

The level of assessment and disclosure should be tied to the environmental and social impacts of an activity, not the size of the company undertaking it. An approach based on entity size could result in large organizations facing more extensive requirements for routine, low-impact activities.

A more practical and risk-based approach would apply requirements proportionate to the potential impacts and complexity of the project itself. This would help ensure that effort is focused where risks are greatest, while avoiding unnecessary administrative burden for low-impact activities.

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

Yes. One key concern is that narrowly defined DNSH criteria could exclude projects that deliver significant overall environmental benefits based on a single metric or localized impact.

DNSH criteria should be applied in a way that considers the overall environmental outcome of a project. A rigid approach that focuses on individual impacts in isolation could unintentionally disqualify projects that deliver substantial emissions reductions or other environmental benefits. For example, temporary land disturbance, localized habitat impacts, or operational noise may occur as part of infrastructure projects that generate meaningful long-term climate benefits. If these localized impacts automatically prevent a project from qualifying, the taxonomy risks discouraging investments that are important to the low-carbon transition.

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?

Implement FPIC in a way that aligns with existing Canadian laws, regulatory processes, and Indigenous engagement requirements. A risk-based approach, similar to the Australian Taxonomy, should be considered, with enhanced due diligence focused on projects that are more likely to affect Indigenous rights and interests. Requiring companies to demonstrate FPIC or UNDRIP alignment beyond existing legal and regulatory requirements creates significant uncertainty and may be difficult to apply consistently in practice. A more workable approach would focus additional due diligence on projects that have the potential to directly impact Indigenous rights, title, or traditional lands, particularly where agreements or established engagement processes are not already in place. Where formal agreements, like Impact Benefit Agreements, or corporate frameworks like an Indigenous Reconciliation Action Plan already exist, the taxonomy should recognize these instruments as satisfying the FPIC requirements to avoid requiring duplicative efforts and potential audits.

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

Agree

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

Agree

13b. Please explain your answer in the space below

– We agree that these activities should be eligible in the Taxonomy so they can access financing for decarbonizing. However, we suggest combining Green and Transition categories to simplify the Taxonomy. Creating separate Green and Transition categories misaligns with the 'usability' principle. Consider combining Green and Transition categories into the same category (perhaps an 'Aligned' category). This will simplify the evaluation criteria (for example, you only have to create criteria that would ensure companies meet the threshold for Transition instead of criteria for both Green and Transition). There can still be measures pathways in a version where Green and Transition categories are combined, to support specific measures that can be used to help decarbonize broader activities. This simplicity will increase usability and promote industry uptake of the taxonomy.
– In addition, the methodology should consider how selecting an alternate 'lowest emissions' activity that provides the same function can reduce overall emissions. For example, all freight transport activities could be assessed using a common carbon-intensity (such as X gCO2e/tonne-km for ALL freight transport modes), rather than mode-specific carbon intensities (such as a Y gCO2e/tonne-km for rail freight transport and Z gCO2e/tonne-km for truck freight transport). A common carbon-intensity framework would better recognize investments that reduce economy-wide emissions through modal shift from higher-emitting transport modes to lower-emitting transport modes. This approach would align taxonomy eligibility with actual emissions outcomes, encourage efficient capital allocation, and support transportation decarbonization at a system level.

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?

Disagree

14b. Please explain your answer in the space below

– The distinction between the whole-of-activity and measures pathways requires further clarification. Specifically, if an activity satisfies the criteria for whole-of-activity eligibility, it is unclear whether all associated CapEx, OpEx, and revenues are considered taxonomy-aligned, or whether individual expenditures must still be assessed for consistency with the activity's decarbonization pathway. Additional guidance on how non-aligned investments within an otherwise eligible activity should be treated would improve the Taxonomy's usability and reduce the risk of inconsistent interpretation across sectors.
– Furthermore, it is unclear what whole-of-activity means for a large distributed operation or network that is not a single site like a plant or building. For example, how would a transportation and logistics business be treated under the whole-of-activity definition? Is the activity the entire network or individual mobile combustion units (i.e., trucks, trains, marine vessels)? The examples in the methodology do not provide clarity on these types of distributed operations.

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

– Merging the Green and Transition categories could simplify the classification framework.
– The classification framework should be able to address 'lowest emissions' alternatives that provides the same function but at lower overall emissions. For example, all freight transport activities could be assessed using a common carbon-intensity (such as X gCO2e/tonne-km for ALL freight transport modes), rather than mode-specific carbon intensities (such as a Y gCO2e/tonne-km for rail freight transport and Z gCO2e/tonne-km for truck freight transport). A common carbon-intensity framework would better recognize investments that reduce economy-wide emissions through modal shift from higher-emitting transport modes to lower-emitting transport modes.

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

The proposed approach leverages existing taxonomies that should serve as a good guide for Canada's taxonomy. Criteria should promote low carbon technologies that are commercially feasible. Engagement with industry experts from Canadian companies are a key element for assessing commercial feasibility and the viability of technical screening criteria. Industry engagement can help ensure that proposed criteria are ambitious yet realistic / achievable.

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

– In general, criteria should not prescribe what specific technologies are eligible in the taxonomy. If the goal is to mitigate GHGs, then it should not matter what technologies are used to achieve desired GHG reductions. Criteria should be framed to be technology-agnostic, where possible.
– The methodology should consider how selecting an alternate 'lowest emissions' activity that provides the same function can reduce overall emissions. For example, all freight transport activities could be assessed using a common carbon-intensity (such as X gCO2e/tonne-km for ALL freight transport modes), rather than mode-specific carbon intensities (such as a Y gCO2e/tonne-km for rail freight transport and Z gCO2e/tonne-km for truck freight transport). A common carbon-intensity framework would better recognize investments that reduce economy-wide emissions through modal shift from higher-emitting transport modes to lower-emitting transport modes. This approach would align taxonomy eligibility with actual emissions outcomes, encourage efficient capital allocation, and support transportation decarbonization at a system level.
– Technical screening criteria should remain as simple as possible to promote uptake. Complex and nuanced screening criteria will serve as a barrier to adopting the taxonomy and companies attempting to demonstrate alignment with it.

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?

Agree. Primarily focusing on scope 1 emissions promotes usability. It seems reasonable that scope 2 and 3 emissions are indirectly covered in other sector criteria.

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?

– The methodology should explicitly recognize sustainable biofuels and other low-carbon fuels as potential transition measures for mobile combustion applications where commercially viable zero-emission alternatives are not yet available at scale. Future technical screening criteria should evaluate fuels based on demonstrated lifecycle GHG reductions, sustainability requirements, and alignment with net-zero pathways rather than excluding specific fuel pathways. This would support emissions reductions in hard-to-abate transportation sectors while maintaining the taxonomy's focus on measurable climate outcomes.
– We recommend that activity selection and technical screening criteria of those activities be developed in consultation with industry experts to ensure that they are practical / economically feasible.
– We recommend that the taxonomy be developed to be as simple as possible to enhance usability, with the goal of reducing administrative and reporting burden and to encourage uptake from stakeholders. A few ways to simplify the taxonomy includes:
– Merging the Green and Transition categories.
– Developing the taxonomy to promote the 'lowest emission alternatives' across activities instead of within one activity type to maximize economy-wide GHG reductions. For example, by providing technical screening that applies to all land freight transport instead of criteria that applies to specific land freight transport modes. This will reduce complexity while reducing cross-activity emissions.
– Limiting the complexity and detailed requirements of technical screening criteria.