Taxonomy Foundations
Please feel free to answer only the questions that are of the most interest and relevance to you.
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?
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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?
Select
5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?
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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?
Select
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?
Select
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?
Select
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?
Select
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?
Select
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?
Strongly agree (i.e., agree unconditionally)
15b. Please explain your answer in the space below
GHGSat supports the inclusion of an abatement measures category within the taxonomy. There is real value in moving quickly to support near-term abatement investments in emission-intensive sectors, and we believe the taxonomy can provide an additional incentive for action and bolster regulatory and voluntary initiatives to expedite the path to a low carbon future.
As an economy with significant fossil fuel extraction, Canada has an opportunity to lead on sustainable finance by creating an approach that other resource-dependent economies can look to and adapt. GHGSat supports Canada's effort to design a taxonomy suited to its specific circumstances, including the realities of its resource sector, that enables emissions reductions today to increase the likelihood of achieving a lower-carbon future tomorrow.
The purpose of the taxonomy is to help Canada achieve its 2050 net-zero target, and this objective should guide how the abatement category is designed and applied. With or without an abatement category, the oil and gas sector is likely to continue attracting investment as long as global demand exists. Given this, engaging with a sector that is responsible for a significant share of Canada's emissions offers an important opportunity to support meaningful, near-term emissions reductions, rather than leaving it outside the taxonomy's scope entirely. Rewarding leading companies that invest in credible decarbonization, such as methane abatement projects, can drive meaningful change within the sector, creating a financial incentive for emissions performance that may not otherwise exist. The alternative — excluding the sector — risks maintaining the status quo of slow progress, with a correspondingly low likelihood of Canada meeting its 2050 target.
At the same time, we support the development of robust guardrails to ensure abatement measures deliver credible, Paris-aligned progress within emission intensive industries. Given the uncertainty inherent in projecting global demand decline for these sectors, we would encourage an approach that can continue to drive mitigation efforts even if actual demand trajectories diverge from Paris-aligned models.
Overall, we wish the Canadian Taxonomy and Transition Planning Council success with this initiative and welcome the opportunity to further engage, particularly as work around the abatement category gets underway.
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?
Select
Final questions
22. Overall, how satisfied are you with the proposed sustainable finance taxonomy framework?
Select