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.

• Water and marine resource conservation
• Pollution prevention and control
• Circular economy

2a. Do you agree or disagree with these proposed principles as the foundation for the taxonomy?

Strongly agree

2b. Please share the reason for your answer in the space provide

I agree with these proposed principles because they provide a strong foundation for developing a credible and effective sustainable finance taxonomy. The principles ensure that climate considerations are integrated consistently and transparently into the classification of economic activities, reducing ambiguity and the risk of greenwashing. They also promote a taxonomy that is practical to apply, aligned with international standards, adaptable to future developments, and tailored to Canada's unique economic and regional context.

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?

Agree

4b. Please explain your answer in the space below

agree with the proposed partial alignment approach because it promotes transparency while providing flexibility during the implementation of the Canadian Sustainable Finance Taxonomy. Requiring entities to disclose the extent to which they meet the Do No Significant Harm (DNSH) criteria and Minimum Social Safeguards (MSS), rather than requiring immediate full compliance, allows investors and other stakeholders to assess an organization's level of alignment and identify areas for improvement. This approach encourages broader participation in the taxonomy, supports continuous progress toward full compliance, and reduces barriers for organizations that are still developing their sustainability practices, while maintaining accountability through clear disclosure. transparency over perfection. Rather than excluding organizations that have not yet achieved full DNSH/MSS compliance, the approach allows them to demonstrate progress while giving investors the information needed to make informed decisions.

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

I agree with the proposed scope of objectives to be covered under the Do No Significant Harm (DNSH) and Minimum Social Safeguards (MSS) frameworks. The proposed objectives provide a balanced approach by ensuring that activities contributing to climate mitigation do not create significant negative impacts on other environmental objectives, such as biodiversity, water resources, and pollution prevention, or on social values and legal rights. Including both environmental and social safeguards strengthens the credibility of the taxonomy, reduces the risk of unintended consequences and greenwashing, and promotes a more holistic approach to sustainable finance. This comprehensive scope helps ensure that investments support long-term environmental sustainability while respecting fundamental social and legal standards. climate action alone is not sufficient—activities should also avoid harming other environmental objectives and uphold minimum social safeguards.

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

I agree with the proposed approach of grounding the Do No Significant Harm (DNSH) and Minimum Social Safeguards (MSS) frameworks in Canadian legislation while going beyond existing laws and standards where necessary. Using Canadian legislation as the foundation provides a clear, credible, and enforceable baseline that is familiar to organizations and consistent with Canada's legal framework. However, environmental science, international best practices, and sustainability expectations continue to evolve, and legislation may not always keep pace. Allowing the taxonomy to establish more rigorous criteria where appropriate helps ensure that it remains credible, aligns with international standards, and effectively supports Canada's long-term climate and sustainability objectives.

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

It is necessary to go beyond existing laws and standards in areas where current regulations do not fully address emerging environmental and social risks or where international best practices have advanced beyond the legal minimum. This includes areas such as biodiversity conservation, climate resilience and adaptation, greenhouse gas emissions, and Indigenous rights and meaningful consultation. Strengthening the Do No Significant Harm (DNSH) and Minimum Social Safeguards (MSS) frameworks in these areas helps ensure that activities classified as taxonomy-aligned deliver genuine environmental benefits without causing significant harm to ecosystems or communities. Going beyond legal requirements also enhances the credibility of the taxonomy, reduces the risk of greenwashing, and better aligns Canada's sustainable finance framework with evolving global standards.

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

I agree that different DNSH/MSS standards should apply to projects or entities of different sizes, provided that the core environmental and social safeguards remain consistent. A proportional approach recognizes that smaller organizations and projects may have fewer resources and less capacity to meet complex disclosure requirements compared with larger entities. Streamlined reporting requirements for smaller participants can encourage broader participation in the taxonomy while reducing unnecessary administrative burdens. However, larger projects and entities, which typically have greater environmental and social impacts, should be subject to more comprehensive disclosures and assessments. This approach maintains accountability while ensuring that the taxonomy remains practical, accessible, and effective across Canada's diverse economic sectors. This also aligns with the earlier principle of usability: a taxonomy that is too burdensome may discourage participation, while a taxonomy that is too flexible may reduce credibility. A proportional approach attempts to balance both.

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

Yes, there are potential gaps in the proposed DNSH/MSS framework that could result in unintended environmental or social harms if not adequately addressed. In particular, the framework should consider the risk that activities may achieve reductions in emissions intensity while still resulting in increased absolute emissions due to expanded production or increased demand.

Additional consideration should be given to lifecycle emissions, cumulative environmental impacts, and the potential for taxonomy-aligned investments to prolong dependence on high-emitting infrastructure. This is particularly important for sectors where emissions reductions may not be sufficient to align with Paris Agreement pathways.

The framework should also ensure robust protections for biodiversity, Indigenous rights, and affected communities, including meaningful engagement and respect for Indigenous decision-making processes. Clear criteria, strong disclosure requirements, and regular review will be necessary to ensure that the DNSH/MSS framework supports genuine sustainability outcomes and does not unintentionally enable activities that undermine Canada's climate objectives.

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?

The taxonomy should operationalize the principles of the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP), including Free, Prior, and Informed Consent (FPIC), by establishing clear requirements for meaningful Indigenous engagement throughout the lifecycle of taxonomy-aligned activities. This should include early consultation before decisions are made, access to relevant and understandable information, opportunities for Indigenous communities to influence project design and implementation, and respect for Indigenous governance systems and decision-making processes.

The Minimum Social Safeguards framework should require evidence that FPIC has been appropriately considered and obtained where projects may affect Indigenous rights, lands, resources, cultures, or livelihoods. The framework should also recognize that engagement is an ongoing process rather than a one-time consultation requirement, with mechanisms for continued dialogue, monitoring, and addressing concerns throughout a project's lifecycle.

Embedding UNDRIP principles within the MSS framework would strengthen the credibility of the taxonomy, support reconciliation efforts, reduce the risk of social harm, and ensure that sustainable finance activities respect Indigenous rights and perspectives. This is consistent with the broader purpose of MSS: ensuring that activities considered sustainable are not only environmentally beneficial but also socially responsible and respectful of fundamental rights.

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

The proposed MSS/DNSH framework provides an important foundation for ensuring that taxonomy-aligned activities deliver meaningful environmental benefits while avoiding unintended social and environmental harms. Additional consideration should be given to ensuring that the framework remains adaptive and responsive as scientific understanding, technology, and social expectations evolve.

The framework would benefit from clear guidance on implementation, consistent disclosure requirements, and practical tools to help organizations demonstrate alignment. It should also include mechanisms for ongoing review, stakeholder engagement, and incorporation of Indigenous perspectives to ensure that the criteria remain relevant and effective. Particular attention should be given to cumulative environmental impacts, regional differences, and the long-term social impacts of economic transitions.

Overall, a strong MSS/DNSH framework will be essential to maintaining the credibility of the Canadian taxonomy by ensuring that sustainable finance supports not only climate objectives but also broader environmental protection, social responsibility, and equitable outcomes.

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

Strongly agree

12b. Please explain your answer in the space below

I agree with the proposed approach of limiting the green category to activities with zero or near-zero emissions, or activities that directly enable zero to near-zero emissions solutions. This approach provides a clear and credible definition of what qualifies as environmentally sustainable and helps prevent the dilution of the term "green" through the inclusion of activities that only provide incremental improvements.

Focusing the green category on activities that make a substantial contribution to climate change mitigation ensures that investments are directed toward solutions consistent with long-term climate objectives. Including enabling activities, such as the manufacturing of technologies that support emissions reductions, recognizes the importance of supply chains and infrastructure needed to accelerate the transition to a low-carbon economy. This approach strengthens the credibility of the taxonomy while providing clarity for investors and businesses seeking to identify genuinely sustainable activities. The taxonomy should ensure the criteria for "near-zero emissions" and "enabling activities" are clearly defined so that transitional improvements are not unintentionally excluded from supporting Canada's broader decarbonization pathway.

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

Strongly agree

13b. Please explain your answer in the space below

I support the inclusion of a transition category, provided that it is limited to activities with credible, science-based pathways to achieve zero or near-zero emissions and where technically feasible low-carbon alternatives are not currently available. A transition category is important because some sectors, such as steel, cement, and chemicals, require significant technological innovation and investment before they can fully decarbonize.

However, strict guardrails are necessary to ensure that the transition category does not become a pathway for continued high emissions or carbon lock-in. Eligibility should require measurable emissions reductions, clear timelines, alignment with Paris Agreement pathways, and evidence that investments are supporting a genuine transition rather than extending the operation of high-emitting assets.

The transition category should prioritize sectors where decarbonization is necessary and achievable, while excluding activities that are incompatible with long-term climate goals or where expansion of high-emitting infrastructure would undermine emissions reductions.

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

I agree that the proposed guardrails for the transition category provide an appropriate balance between maintaining science-based credibility and supporting usability. A transition category is necessary to recognize that some high-emitting sectors cannot immediately shift to zero or near-zero emissions due to technological and economic limitations. The proposed guardrails help ensure that only activities with credible decarbonization pathways are included, reducing the risk of carbon lock-in and preventing the transition label from being used to justify continued high emissions.

However, the effectiveness of these guardrails will depend on strong implementation, transparent disclosure, and regular review of transition pathways to ensure they remain aligned with climate science and Canada's net-zero objectives. Clear emissions reduction targets, timelines, and accountability mechanisms will be important to distinguish genuine transition activities from those that delay meaningful action.

Overall, the proposed approach appropriately balances the need for a practical and usable taxonomy with the need to preserve the scientific integrity and credibility of the transition category.

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

I strongly disagree with including an abatement category for oil and gas production within the sustainable finance taxonomy. The purpose of the taxonomy should be to direct capital toward Paris-aligned investments and activities that support long-term decarbonization. Continued investment in fossil fuel production, which remains a major source of greenhouse gas emissions in Canada, should not be classified as sustainable finance, particularly where renewable energy alternatives and lower-emissions technologies exist.

While measures such as methane abatement and carbon capture and storage may reduce emissions from existing operations, they do not necessarily reduce total emissions if production continues to increase. As recognized in the Report, emissions reductions at the project level may be offset by increased production levels, creating a risk that the taxonomy could unintentionally support continued fossil fuel dependence.

If fossil fuel production continues in the near term, emissions reductions should be addressed through regulatory requirements rather than through inclusion in a sustainable finance taxonomy. If an abatement category is included, it should be narrowly defined and subject to the strongest possible safeguards. All proposed guardrails should apply to every eligible measure, the requirement for a “significant reduction” should establish a high threshold based on science-based pathways, eligibility should be limited to existing assets and exclude expansion, and carbon capture measures should not include enhanced oil recovery, as using captured carbon to enable additional oil extraction is not consistent with sustainable finance objectives.

A credible taxonomy must ensure that abatement measures support genuine emissions reductions without delaying the transition away from fossil fuels or creating a pathway for continued investment in activities inconsistent with a net-zero future.

16. Should any additional guardrails be considered?

The proposed guardrails are an important step toward limiting the risk of carbon lock-in and maintaining the credibility of an abatement measures category. However, additional and more stringent guardrails should be considered given the significant risk that this category could unintentionally support continued fossil fuel production rather than accelerate the transition to a low-carbon economy.

Additional guardards should include a requirement that all eligible abatement measures demonstrate measurable and verifiable reductions in absolute emissions, not only reductions in emissions intensity. The criteria should also exclude any measures that enable expansion of fossil fuel production or extend the operating life of high-emitting assets beyond what is consistent with Paris-aligned pathways. Eligibility should be limited to existing assets, with clear timelines, emissions reduction milestones, and ongoing monitoring requirements.

Carbon capture and storage should also be subject to strict criteria and should not include applications such as enhanced oil recovery, where captured carbon is used to increase additional fossil fuel extraction. Such applications risk undermining the purpose of the taxonomy by using emissions reduction technologies to support continued production.

Additional consideration should also be given to lifecycle emissions, cumulative impacts, transparency of emissions reporting, and alignment with independent climate scenarios. Ultimately, the abatement category should remain narrowly focused on achieving genuine emissions reductions and should not become a mechanism for classifying continued fossil fuel production as sustainable.

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

The proposed activity classification framework provides a useful structure for distinguishing between green, transition, and abatement activities; however, maintaining clear boundaries between these categories will be essential to preserving the credibility of the taxonomy. The framework should prioritize directing capital toward activities that are aligned with Paris Agreement pathways and avoid creating ambiguity about what constitutes a sustainable investment.

The green category should remain limited to activities that make a substantial contribution to climate mitigation through zero or near-zero emissions solutions. The transition category should be reserved for sectors where credible pathways to zero or near-zero emissions exist and where significant technological barriers remain. Strong criteria will be necessary to prevent the transition category from becoming a means of extending high-emitting activities that do not have a realistic pathway to decarbonization.

The proposed abatement category requires particular caution. While certain emissions-reduction measures may provide short-term climate benefits, they should not result in fossil fuel production being classified as sustainable or create incentives for expanding high-emitting infrastructure. If included, the category should be narrowly defined, limited to existing assets, supported by rigorous emissions reduction requirements, and subject to transparent monitoring and disclosure.

Overall, the taxonomy should prioritize credibility over broad applicability. A clear, science-based framework that directs capital toward genuine climate solutions will better support Canada's transition to a low-carbon economy and maintain confidence among investors, businesses, and the public.

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

I agree with the proposed approach for developing technical screening criteria, provided that the criteria remain grounded in climate science, transparent methodologies, and alignment with Canada's net-zero commitments. Establishing clear technical thresholds is essential to ensuring that taxonomy-aligned activities deliver meaningful emissions reductions and that the framework remains credible for investors, businesses, and other stakeholders.

The technical screening criteria should be developed using science-based pathways, measurable performance indicators, and lifecycle emissions considerations where appropriate. They should also be regularly reviewed and updated to reflect advances in technology, evolving climate science, and changes in international best practices.

It will be particularly important that the criteria maintain a high standard for transition and abatement activities. These categories should include only activities with credible emissions reduction pathways and should not allow incremental improvements to substitute for meaningful decarbonization. Clear thresholds, transparent disclosure requirements, and strong safeguards will be necessary to prevent greenwashing and ensure that the taxonomy effectively directs capital toward Paris-aligned investments.

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

Very 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 be sufficiently specific and prescriptive to ensure credibility, consistency, and accountability, but should avoid being overly technology-specific in ways that could limit innovation or prevent the adoption of emerging solutions. The criteria should primarily focus on measurable environmental outcomes, such as emissions reductions, lifecycle impacts, and alignment with Paris Agreement pathways, rather than requiring the use of specific technologies.

However, for high-risk or high-emitting sectors, more detailed requirements may be necessary to prevent greenwashing and ensure that activities genuinely contribute to climate objectives. This is particularly important for transition and abatement activities, where weak criteria could allow incremental improvements to be classified as sustainable despite continued high emissions.

A balanced approach would establish clear science-based thresholds and performance requirements while allowing flexibility in how organizations achieve those outcomes. This would support both the credibility and usability of the taxonomy by providing certainty for investors and businesses while allowing room for technological advancement.

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?

I disagree with the proposed approach of focusing primarily on Scope 1 emissions and only addressing Scope 2 and 3 emissions where feasible and/or material. While Scope 1 emissions are important for assessing an organization’s direct operational impacts, limiting the primary focus to direct emissions may not accurately reflect the full climate impact of many activities.

For sectors such as oil and gas, transportation, and certain industrial activities, Scope 2 and Scope 3 emissions can represent a substantial portion of total lifecycle emissions. Failing to adequately account for these emissions could result in activities being classified as aligned with climate objectives despite continuing to contribute significantly to overall greenhouse gas emissions.

A credible taxonomy should consider lifecycle emissions and require Scope 2 and Scope 3 emissions to be addressed where they are material to the activity’s overall climate impact. While implementation challenges should be recognized, a balanced approach that incorporates material value-chain emissions is necessary to prevent greenwashing and ensure that taxonomy-aligned activities genuinely support Paris Agreement goals.

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, I view the proposed sustainable finance taxonomy framework as a strong foundation that has the potential to improve the credibility, transparency, and consistency of sustainable finance in Canada. The emphasis on principles such as credibility, usability, interoperability, and prioritization provides an important basis for developing a framework that can effectively guide investment toward activities that support climate objectives.

The proposed approach to defining green, transition, and safeguard criteria is generally well structured and recognizes the need to balance environmental ambition with economic realities. The inclusion of Do No Significant Harm (DNSH) criteria and Minimum Social Safeguards (MSS), including consideration of Indigenous rights and meaningful engagement, are important elements in ensuring that climate-related investments also respect broader environmental and social values.

However, additional strengthening is needed to ensure that the taxonomy maintains its credibility and effectively directs capital toward Paris-aligned investments. In particular, the framework should establish clear boundaries between activities that are genuinely sustainable, activities that are transitioning toward alignment, and activities that are only reducing the impacts of continued high-emitting operations. The inclusion of an abatement category for fossil fuel production presents a significant risk that emissions reductions in high-emitting sectors could be interpreted as sustainable finance activities, even where total emissions may continue to increase.

If an abatement category is retained, it should be narrowly defined and subject to the strongest possible safeguards, including requirements for absolute emissions reductions, alignment with science-based pathways, exclusion of production expansion, and restrictions on measures such as carbon capture and storage used for enhanced oil recovery. Lifecycle emissions, including material Scope 2 and Scope 3 emissions, should also be considered to ensure that the taxonomy captures the full climate impact of activities.

The taxonomy should also remain dynamic and adaptive, with regular review periods, clear timelines, and the ability to strengthen criteria as climate science, technology, and market conditions evolve. Maintaining rigorous technical screening criteria and prioritizing credibility over broad applicability will be essential to preventing greenwashing and ensuring confidence among investors, businesses, Indigenous communities, and the public.

Overall, the proposed methodology represents a meaningful step toward establishing a Canadian sustainable finance framework. With stronger safeguards around high-emitting activities and continued emphasis on science-based criteria, the taxonomy can become an effective tool for directing capital toward genuine climate solutions and supporting Canada's transition to a net-zero economy.