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
• Pollution prevention and control
• Circular economy

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

These six principles provide a robust and practical foundation for Canada's sustainable finance taxonomy. Striking a careful balance among them is essential: maintaining credibility ensures alignment with the Paris Agreement and Canada's 2050 net-zero targets while preventing greenwashing; ensuring usability and interoperability reduces transaction costs and aligns with global capital markets; remaining dynamic allows the framework to evolve alongside emerging technologies; and incorporating regional specificity and prioritization ensures the taxonomy accurately reflects Canada's unique resource-based economy and directs capital where it can have the greatest decarbonization impact.

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

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?

Strongly disagree

4b. Please explain your answer in the space below

Requiring only partial alignment risks creating loopholes that undermine the credibility of Canada’s sustainable finance framework. To prevent greenwashing and ensure strict alignment with Paris Agreement goals, issuers must be held to full compliance standards for both Do No Significant Harm (DNSH) and Minimum Social Safeguards (MSS) to claim taxonomy alignment.

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

Strongly disagree

5b. Please explain your answer in the space below

The overarching taxonomy framework must prioritize absolute ecological and climate integrity above all else. Capital must be systematically steered toward Paris-aligned, zero-emission solutions rather than sustaining high-emitting industries under the guise of transition or abatement. By enforcing stringent, non-negotiable DNSH and MSS criteria, Canada can establish a globally respected taxonomy that attracts credible international capital and genuinely delivers on clean growth and decarbonization.
Capital must be redirected toward Paris-aligned alternatives. Supporting fossil fuel production—Canada's largest source of greenhouse gas emissions—conflicts directly with net-zero targets when scalable renewable alternatives already exist. As the draft report acknowledges, absolute emissions can still rise if production volumes scale up.

If the Abatement Category Proceeds: If the category is implemented despite these systemic risks, the following strict guardrails must be mandated:
• Exclude all capacity expansion and new asset development.
• Establish an exceptionally high threshold for "significant emissions reductions."
• Prohibit Enhanced Oil Recovery (EOR), as using captured carbon to extract more hydrocarbons fundamentally undermines climate integrity.
• Rely primarily on mandatory government regulations rather than sustainable finance incentives to drive operational decarbonization in fossil fuel sectors.

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 agree

6b. Please explain your answer in the space below

Grounding the DNSH and MSS frameworks in existing Canadian legislation provides a reliable baseline, but laws alone are insufficient to meet international commitments under the Paris Agreement. Where existing standards lag behind net-zero trajectories, the taxonomy must explicitly go beyond current laws to prevent greenwashing and establish a credible, high-integrity benchmark for sustainable investments.

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

The taxonomy must exceed current baseline regulations in several critical areas to ensure true climate alignment:
• Emissions Thresholds: Establishing rigorous, science-based greenhouse gas intensity thresholds that decline over time, rather than defaulting to looser compliance metrics found in legacy environmental legislation.
• Methane and Fugitive Emissions: Mandating near-zero leakage and strict continuous monitoring for fossil fuel and industrial sectors that surpass current provincial and federal regulatory minimums.
• Biodiversity and Ecosystem Protection: Requiring robust, mandatory offsets and net-positive biodiversity impacts for projects operating in ecologically sensitive regions.
• Indigenous Rights and Consent: Raising the bar from mere consultation to the explicit implementation of Free, Prior, and Informed Consent (FPIC) across all tier categories.

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

While administrative burden is a valid consideration for smaller entities, applying weaker DNSH or MSS standards based on size creates a fragmented framework and dangerous loopholes. Environmental and social harms do not scale inversely with project size. Instead of lowering standards, the taxonomy should provide streamlined reporting templates, technical assistance, or phased compliance timelines for smaller participants while maintaining a single, uncompromising threshold of integrity for all sustainable finance claims.

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

o Carbon Lock-in: Treating emissions-intensive activities or abatement measures as "sustainable" creates systemic risks of locking in fossil fuel infrastructure for decades.
o Scope 3 Emissions Omissions: Failing to fully account for downstream Scope 3 emissions—particularly for exported oil and gas—hides the true global climate impact of Canadian energy projects.
o Weak Enforcement Mechanisms: Without independent, third-party verification and mandatory transparency, voluntary disclosure models risk enabling greenwashed capital allocation that diverts funds away from true zero-emission solutions.

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?

To genuinely incorporate the UN Declaration on the Rights of Indigenous Peoples (UNDRIP), the taxonomy must operationalize Free, Prior, and Informed Consent (FPIC) as an absolute prerequisite within the Minimum Social Safeguards (MSS) framework:
o Mandatory Proof of Consent: Require independent, third-party verified documentation of Indigenous consent before any project can claim taxonomy alignment.
o Equitable Benefit-Sharing: Ensure transparent frameworks for long-term economic participation and community-led environmental monitoring.
o Veto Power: Respect the right of Indigenous nations to withhold consent for developments that threaten traditional territories, cultural heritage, or ecological security.

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

The overarching taxonomy framework must prioritize absolute ecological and climate integrity above all else. Capital must be systematically steered toward Paris-aligned, zero-emission solutions rather than sustaining high-emitting industries under the guise of transition or abatement. By enforcing stringent, non-negotiable DNSH and MSS criteria, Canada can establish a globally respected taxonomy that attracts credible international capital and genuinely delivers on clean growth and decarbonization.

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

Strongly disagree

12b. Please explain your answer in the space below

Limiting the green category strictly to zero or near-zero emissions solutions and direct enablers preserves the integrity of the taxonomy. It establishes a clear, uncompromised benchmark for climate-aligned investments, prevents greenwashing, and ensures that capital is actively directed toward solutions that genuinely support Canada's 2050 net-zero target

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

Agree

13b. Please explain your answer in the space below

Including hard-to-abate sectors (such as steel, cement, and chemical manufacturing) that face stable or growing demand and lack immediate low-carbon substitutes is necessary for a pragmatic transition. However, inclusion must be strictly conditioned on rigorous, verifiable decarbonization pathways toward near-zero emissions by 2050 to completely eliminate the risk of long-term carbon lock-in.

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 currently proposed guardrails require tightening to prevent loopholes. To truly protect scientific credibility and avoid carbon lock-in, the framework must mandate binding interim milestones, transparent third-party verification, and absolute caps on emissions intensity rather than relying on qualitative transition intent alone.

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

Capital must be systematically redirected toward Paris-aligned alternatives rather than supporting high-emitting fossil fuel sectors (upstream production, refining, and distribution) that face inevitable demand decline. Treating fossil fuel expansion or abatement measures as "sustainable" undermines net-zero targets, especially when absolute emissions can still rise if production volumes scale up.

16. Should any additional guardrails be considered?

If an Abatement Category proceeds despite these systemic risks, the following strict guardrails must be mandated:
• Exclude Expansion: Explicitly exclude all capacity expansion and new asset development.
• High Thresholds: Establish an exceptionally high, scientifically rigorous threshold for "significant emissions reductions."
• Prohibit EOR: Strictly prohibit Enhanced Oil Recovery (EOR), as using captured carbon to extract more hydrocarbons fundamentally undermines climate integrity.
• Regulatory Focus: Rely primarily on mandatory government regulations rather than sustainable finance incentives to drive operational decarbonization in fossil fuel sectors.
sectors.

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

The taxonomy must prioritize absolute ecological and climate integrity above all else. Blurring the lines between true climate solutions and fossil fuel abatement measures risks compromising international credibility and misallocating vital capital away from the clean energy transition.

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

While structured technical screening criteria are necessary, the proposed approach lacks the stringency required to prevent greenwashing. To maintain climate integrity, criteria must establish non-negotiable, science-based emissions thresholds that decline rapidly over time, completely excluding activities that rely on fossil fuel expansion or unproven abatement offsets.

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

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 criteria must be highly prescriptive and technologically rigorous rather than overly flexible. Permitting broad technological neutrality or qualitative intent allows entities to greenwash business-as-usual fossil fuel operations. Clear, mandatory performance benchmarks ensure capital is unambiguously directed toward true zero-emission solutions.

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?

Focusing exclusively or primarily on Scope 1 emissions creates a massive blind spot, particularly for fossil fuel production, refining, and distribution where over 80% of total emissions are downstream Scope 3. The technical screening criteria must mandate comprehensive accounting and strict caps on Scope 3 emissions to capture the true climate impact of Canadian energy assets and prevent carbon leakage.

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

Unsatisfied

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

•While the development of a national sustainable finance taxonomy is a critical step for Canada's net-zero transition, the inclusion of a flawed "Abatement" category that permits fossil fuel investments severely compromises the framework's environmental integrity and risks enabling greenwashing.
•Prioritize True Climate Solutions: The taxonomy must strictly align with a 1.5°C Paris-aligned pathway by completely removing loopholes or categories that accommodate fossil fuel expansion and high-emitting abatement measures.
•Strengthen Safeguards: Mandate rigorous, independent third-party verification for all technical screening criteria, embed strict Scope 3 emissions accounting, and operationalize Free, Prior, and Informed Consent (FPIC) as a mandatory component of the Minimum Social Safeguards.
•Global Credibility: Ensuring high standards will protect Canada's international reputation, attract credible global capital, and prevent the misallocation of financial resources away from genuine zero-emission alternatives.