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
• 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 provided

We believe the proposed principles provide an appropriate foundation for the taxonomy, particularly their emphasis on credibility, usability, interoperability, and the ability of the framework to evolve over time. We also support prioritizing taxonomy development based on climate impact, market relevance and feasibility.

Regional specificity warrants additional consideration. Canada's geographic and operating conditions may justify flexibility where they materially affect the feasibility of climate-aligned activities. However, this flexibility should operate within a common national framework and should not result in materially different standards of climate alignment for comparable activities across regions.

This is a genuine and material issue in the Canadian context. Electricity grid carbon intensity, for example, varies enormously by province – from near-zero in provinces served predominantly by hydro or nuclear power to considerably higher levels in provinces with gas- or coal-reliant grids – and many northern, rural, and Indigenous communities are not connected to any grid at all. A single national criterion tied to available low-carbon infrastructure could therefore be straightforward to meet in some regions and effectively unattainable in others, through no difference in effort or ambition on the part of the companies involved.

We recommend addressing this without creating different definitions of what counts as a green or transition activity in different parts of the country. Specifically, the underlying performance threshold that determines eligibility (for example, the emissions level required to qualify as green) should remain constant nationally, while the permitted pathway and timeline for reaching that threshold is allowed to vary by region. This could be operationalized using an objective, publicly available reference point, such as Environment and Climate Change Canada's published provincial grid-intensity data, to place activities into transparent, transition-measure eligibility tiers, each with a defined "sunrise" date by which its flexibility narrows as regional infrastructure improves. This approach preserves a single national bar for what ultimately qualifies as taxonomy-aligned, keeps classifications for comparable activities consistent and comparable across the country, and avoids the credibility risk of regionally adjusted thresholds, while still reflecting genuine differences in what is currently achievable on the ground.

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

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?

Agree

4b. Please explain your answer in the space below

We generally support the proposed partial-alignment approach, which may improve usability while providing transparency regarding unmet DNSH and MSS criteria. However, the framework should clearly distinguish partial from full alignment and define what qualifies as partial alignment, which unmet criteria must be disclosed, and when the designation may be used.

This distinction matters because market participants might otherwise treat partial alignment as equivalent to full alignment, masking unmet safeguards. Clear rules would improve comparability across projects, reduce the risk of misleading claims, and help users understand the significance of any outstanding gaps. The framework should also consider whether certain fundamental DNSH or MSS requirements should be treated as minimum conditions that must be met before any taxonomy-alignment claim can be made.

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

The proposed scope appropriately captures the principal environmental and social considerations relevant to the DNSH and MSS frameworks. For DNSH, the proposed objectives capture the principal environmental harms that could arise even where an activity contributes to climate mitigation. For MSS, the proposed objectives provide an appropriate baseline to help ensure that taxonomy-aligned activities do not come at the expense of fundamental rights, responsible business conduct or public trust.

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

We generally agree with the proposed approach. Canadian laws and regulations should provide the baseline for the DNSH and MSS frameworks, as this promotes clarity, consistency and alignment with Canada's existing legal framework. However, the circumstances under which the taxonomy would go beyond existing laws and standards should be more clearly articulated. Any taxonomy-specific criteria that go beyond existing requirements should have a clear rationale and be supported by evidence that they are necessary to achieve the taxonomy's objectives. This would help maintain both the credibility and practical usability of the framework.

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

We would not take a firm position at this stage on whether the DNSH or MSS frameworks should formally go beyond existing laws and standards. That said, two areas seem worth flagging as illustrative candidates for the Council to explore further, without committing to either as a required departure from current law.

The first is Indigenous rights and Free, Prior, and Informed Consent. We raise this because current requirements are not a single national standard: they vary across federal, provincial, and territorial jurisdictions, and across project-specific consultation processes. A taxonomy that simply defers to “existing Canadian law” in this area may, in practice, inherit whatever inconsistency already exists between jurisdictions, rather than establishing one clear expectation. We note that the Methodology Report itself already points to international reference points such as IFC Performance Standard 7 and the Equator Principles in this context (Box 3), which suggests the Council may already see a need to look beyond domestic law here. We raise this as a question for the Council and Indigenous rights-holders to consider together, not as a specific criterion we are proposing.

The second is methane measurement and verification for oil and gas-related activities. We raise this because current regulatory reporting for methane relies substantially on self-reported estimates and periodic inspection, whereas independent, continuous verification technology, including satellite-based monitoring, is available and already used in Canada in other contexts. Whether this, or any other specific verification approach, should become part of a formal taxonomy requirement is a technical question best assessed by the Council together with relevant experts; we raise it only because verification quality seems particularly relevant to the credibility of the abatement measures category, given the greenwashing risk associated with continued financing of fossil fuel activity.

Beyond these two illustrative examples, we agree that further candidates should be considered case-by-case as sector-specific criteria are developed, informed by relevant legal, technical and subject-matter expertise.

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

8b. Please explain your answer in the space below

We generally agree with a proportionate approach, but do not believe project or entity size alone should determine the applicable DNSH or MSS standards. The underlying level of environmental and social protection should remain consistent, as smaller projects may still have material environmental or social impacts.

However, disclosure and assessment requirements should be proportionate to the size, complexity and risk of the activity. A risk-based approach can reduce unnecessary administrative burden for lower-risk activities while ensuring that activities with greater potential impacts are subject to appropriate due diligence and reporting.

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

N/A

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?

Indigenous rights-holders and organizations should be central to the development of any criteria or guidance intended to operationalize UNDRIP and FPIC within the taxonomy. This would be consistent with the methodology's broader emphasis on Indigenous engagement in taxonomy development.

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

N/A

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

Agree

12b. Please explain your answer in the space below

Limiting the green category to zero- or near-zero-emission activities and activities that directly enable such solutions will help maintain the credibility of the category and clearly distinguish it from the transition and abatement measures categories. A broader definition could blur these distinctions and increase the risk that incremental emissions improvements are characterized as fully green.

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

Agree

13b. Please explain your answer in the space below

The transition category should recognize high-emitting activities for which demand is expected to remain stable or grow in a Paris-aligned pathway and where technically feasible substitutes are not yet available, provided there is a credible pathway to zero- or near-zero emissions by 2050. This distinction is important for directing capital toward decarbonization in emissions-intensive sectors that cannot immediately qualify as green.

To maintain credibility, transition classification should be supported by evidence that the activity can realistically achieve the required emissions reductions, rather than relying solely on a long-term decarbonization objective.

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?

Agree

14b. Please explain your answer in the space below

We generally support the proposed guardrails, but it is difficult to assess whether they are sufficient until the sector-specific technical screening criteria are developed. Their effectiveness will depend on how terms such as material emissions reductions, technically feasible alternatives, and dead-end pathways are defined and applied.

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

Agree (i.e., agree in principle, with conditions)

15b. Please explain your answer in the space below

We support the inclusion of an abatement measures category. There can be value in recognizing tightly ring-fenced investments that deliver material near-term emissions reductions in existing activities that are expected to experience declining demand in Paris-aligned pathways.

As this category's eligibility rests on the assumption of declining global demand, the Council should confirm which demand scenario(s) will be applied consistently for this purpose, since the Methodology Report itself references demand projections (for example, its footnoted discussion of the Canada Energy Regulator's outlook, where the Regulator's 2026 report suggests oil and gas production could continue to grow within a 2°C pathway, in contrast to the IPCC-based demand-decline assumption used elsewhere in the Report to justify this category) that are not fully aligned with one another.

A distinct category also provides greater transparency by clearly differentiating these investments from green and transition activities. Given the heightened risk of carbon lock-in associated with demand-decline activities, eligibility should remain subject to robust guardrails that ensure qualifying investments deliver meaningful emissions reductions while remaining consistent with the taxonomy's long-term climate objectives.

16. Should any additional guardrails be considered?

We support the use of robust guardrails for the abatement measures category, particularly clear requirements for demonstrating significant emissions reductions against credible baselines and monitoring performance over time. However, some of the illustrative guardrails may warrant further consideration to ensure they do not unnecessarily exclude investments that deliver material emissions reductions. For example, extending the life of an existing asset should not automatically disqualify an investment. The more relevant consideration is whether the investment creates material carbon lock-in or results in an emissions trajectory inconsistent with the taxonomy's long-term climate objectives.

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

N/A

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

We agree with the proposed approach, including the emphasis on forward-looking, primarily quantitative criteria informed by science-based pathways and subject to regular review.

The methodology for setting and revising technical thresholds should be transparent enough to support consistent application by market participants.

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

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

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

The technical screening criteria should generally be technology-neutral and performance-based, allowing technologies that meet credible emissions or environmental-performance thresholds to qualify. This approach can support innovation and allow the taxonomy to adapt as technologies evolve. More prescriptive criteria may be appropriate where outcomes cannot be reliably assessed through performance thresholds alone or where necessary to protect environmental integrity.

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?

We agree in part with the proposed approach. Scope 1 emissions – generated directly by the activity itself (e.g., fuel burned on-site) – should form the main basis for classification. They are the clearest and most measurable, and can be attributed directly to the assessed activity rather than relying on third-party data.

However, the Council should go further on Scope 2 and Scope 3 emissions. As drafted, the Report only includes them where they are "material and where data is available," without defining who determines materiality or by what standard. This creates risk for inconsistent application across sectors at a time when peer taxonomies are adopting stricter approaches. For instance, the EU Taxonomy now mandates full lifecycle carbon assessments-including upstream emissions – for new buildings, with discussions to expand this approach elsewhere.

Rather than relying on case-by-case judgment, we recommend the Council mandate sector-specific technical guidance defining when Scope 2 and Scope 3 emissions must be included. This guidance should leverage established standards, such as the GHG Protocol’s Scope 3 categories, to establish clear materiality benchmarks per sector. As a later-stage taxonomy, Canada has a distinct opportunity to lead on precision rather than repeating open-ended language used in earlier frameworks.

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?

Overall, we are generally supportive of the proposed framework as it establishes a strong foundation for a credible, made-in-Canada sustainable finance taxonomy.

The proposed distinction between green, transition and abatement activities reflects the realities of Canada's economy and recognizes that mobilizing capital toward decarbonization will require more than a traditional green taxonomy approach.

From a financial sector perspective, the framework will be judged by whether it can serve as a practical tool for investment decision-making, lending, underwriting, transition planning and risk assessment. In this regard, the most important next step is the development of sector-specific technical screening criteria that are sufficiently rigorous to maintain market confidence while remaining practical to implement.

As the taxonomy evolves, particular attention should be paid to four factors:
1. Credible treatment of transition activities, including clear and science-based pathways for emissions-intensive sectors that remain viable in a net-zero economy.
2. Robust guardrails around the abatement category, ensuring that near-term emissions reductions are supported without creating undue carbon lock-in risk.
3. Interoperability with international frameworks, while maintaining flexibility to reflect Canadian economic realities and transition pathways.
4. Decision-usefulness and auditability for financial institutions, including criteria that can be consistently applied and independently verified across investment portfolios, lending activities, insurance products, transition planning, and sustainability reporting.

The ultimate measure of success will not be the framework itself, but whether it provides sufficient clarity and confidence to influence capital allocation decisions and accelerate investment into activities that are aligned with Canada's long-term transition objectives.