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
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?
Agree
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
- Very important
- Dynamic
- Very important
- Regionally Specific
- Very 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?
Disagree
4b. Please explain your answer in the space below
Suggest to have limited minimum DNSH/MSS criteria that are required to be met by all, with wider list of criteria to disclose on the the extent whether they are or are not met.
5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?
Select
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
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
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?
Agree
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?
Agree
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
The proposed transition category may exclude businesses that are making significant progress but are not yet fully Paris-aligned due to technology limitations, infrastructure constraints, or growth-related emissions.
The taxonomy should accommodate activities demonstrating meaningful emissions-intensity reductions, even where absolute emissions reductions are challenging due to population growth, housing demand, infrastructure expansion, or electrification requirements.
Consider allowing eligibility for activities that:
– Achieve significant emissions-intensity improvements;
– Deploy best-available technologies;
– Demonstrate a credible decarbonization trajectory; and
– Maintain a clear pathway toward net zero over time.
This would better support investment in hard-to-abate and growing sectors while maintaining the scientific credibility of the framework
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?
Prefer not to answer
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.
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?
Strongly agree
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
- Not that important
- Revise as necessary during regular review periods
- Very 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
- Very important
Final questions
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?
1. Ensure Construction Expertise Is Incorporated into Buildings Sector Criteria
A successful Canadian taxonomy should recognize that decarbonization occurs not only through owning and operating low-carbon assets, but also through the construction activities that deliver them. Construction is often grouped with building ownership and operations, despite having fundamentally different emissions sources, decision-makers, and decarbonization levers.
– Construction companies play a significant role in reducing emissions through embodied carbon reduction, material selection, circularity, construction methods, and equipment electrification.
– Ensure construction industry expertise is directly represented in the development of Buildings (and other relevant) sector technical screening criteria. General contractors and construction industry representatives should be included in Buildings sector technical working groups to ensure the criteria reflect practical project delivery realities.
– The taxonomy should explicitly recognize low-carbon construction activities and construction-related transition measures, rather than focusing predominantly on operational building performance.
2. Clarify the Treatment of Infrastructure Construction Across Priority Sectors
While Transportation, and Electricity have been identified as priority sectors, it is unclear how the construction of enabling infrastructure will be included (not explicitly stated as is with Buildings sector).
– Clarify whether the construction of assets such as transmission and distribution infrastructure, renewable energy facilities, transit systems, rail networks, ports, and airports will be considered taxonomy-aligned, or whether alignment will be limited to operation of the completed asset.
– Construction is a key enabler of decarbonization across all three sectors and should be explicitly recognized within the taxonomy framework.
– Without greater clarity, the taxonomy risks overlooking a critical part of the value chain responsible for delivering the infrastructure required to achieve