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
- Circular economy
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?
Strongly agree
2b. Please share the reason for your answer in the space provided
It is important to prioritize climate change adaptation and resilience as a key objective for future phases of the taxonomy. Many Indigenous communities, particularly those in rural, remote, and northern regions, are already experiencing the impacts of wildfires, flooding, erosion, and extreme weather events. These impacts threaten housing, community infrastructure, local businesses, and broader economic development, and adaptation is necessary to protect the progress that has already been undergone by communities.
It’s also important to prioritize the development of the circular economy, as this reflects the organisations values to promote economic development with traditional knowledge in a regenerative, relational economic model. Prioritizing the circular economy will not only help eliminate waste, but also will subsequently lead to healthy ecosystems, and reduced pollution.
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?
Strongly disagree
4b. Please explain your answer in the space below
I would disagree with the proposed partial alignment approach. While we recognize that the approach is intended to encourage broader participation and support the early adoption of the taxonomy, allowing entities to achieve taxonomy alignment without meeting minimum DNSH and MSS requirements risks undermining the credibility of the framework.
If the purpose of the taxonomy is to direct capital toward sustainable investments, then respect for Indigenous rights and other social and environmental safeguards should be considered core requirements rather than optional considerations. Investments that do not uphold Indigenous rights cannot reasonably be characterized as fully sustainable.
I therefore support the binary approach, whereby alignment with minimum DNSH and MSS criteria is required for taxonomy eligibility. At a minimum, further consideration should be given to how the taxonomy will support Indigenous communities as rights-holders and promote meaningful Indigenous participation in, and benefit from, sustainable investment opportunities.
5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?
Neutral
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 support the proposed approach of grounding the DNSH/MSS frameworks in Canadian legislation while also going beyond existing laws and standards where necessary. Canadian legislation should serve as a baseline, not a ceiling, particularly in areas where legal frameworks have not fully kept pace with evolving best practices related to Indigenous rights, environmental stewardship, and sustainable development.
In particular, I believes the framework should reflect a stronger commitment to the implementation of Free, Prior, and Informed Consent, consistent with the principles of the UNDRIP. Compliance with existing legal requirements alone may not be sufficient to ensure meaningful Indigenous participation or protect Indigenous rights and interests.
7. In which areas, if any, is it necessary to go beyond existing laws and standards for the DNSH/MSS framework?
The DNSH/MSS framework should maintain requirements for comprehensive environmental assessment and Indigenous rights protections, even where legislation such as Bill C-5 provides for expedited project approvals.
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 support a proportional approach to DNSH/MSS disclosure requirements, where the level of reporting and administrative burden reflects the size, complexity, and risk profile of a project or entity. In particular, consideration should be given to streamlined disclosure requirements for Indigenous-led projects and businesses. Many Indigenous communities and organizations face capacity constraints and limited administrative resources, particularly in rural, remote, and northern regions. Excessive reporting requirements can unintentionally exclude Indigenous projects from accessing sustainable finance opportunities. A proportional and flexible approach would help maintain the integrity of the DNSH/MSS framework while ensuring Indigenous participation is not undermined by administrative burden.
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?
I believe the MSS framework should operationalize the principles of UNDRIP and FPIC through a clear, transparent, and measurable approach that recognizes varying levels of Indigenous involvement in project development and governance.
One option would be to establish different levels of classification or certification based on the degree of Indigenous engagement, partnership, and consent. For example, distinctions could be made between:
Indigenous-led projects, where Indigenous communities or organizations hold decision-making authority and ownership interests;
Indigenous partnership projects, where Indigenous communities are equity partners and have meaningful governance roles, including FPIC-based decision-making processes; and
Indigenous participation-enabled projects, where Indigenous communities have been consulted and engaged, but do not hold ownership or governance authority.
Such an approach would provide greater transparency for investors while creating incentives for proponents to move beyond minimum consultation requirements toward meaningful partnership, shared decision-making, and Indigenous ownership.
11. Is there any other feedback you would like to provide on the proposed MSS/DNSH framework?
I would encourage further consideration of how Indigenous Peoples will be involved in the application and assessment of the MSS and DNSH frameworks.
In particular, greater clarity is needed regarding how Indigenous perspectives will be incorporated into determinations of whether an investment meets MSS and DNSH requirements, and whether affected Indigenous communities will be informed, consulted, and engaged directly in the evaluation of projects that may impact their rights, lands, or interests.
Additionally, further clarification on how much impact DNSH and MSS will have on the classification of investments, as it currently isn’t included in the framework included in the methodology report, would be welcomed.
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?
Strongly agree
12b. Please explain your answer in the space below
I agree with the proposal that the green category should be limited to activities with zero to near-zero emissions that make a substantial contribution to climate change mitigation, or that directly enable zero to near-zero emissions climate solutions.
To maintain the credibility and integrity of the taxonomy, the green category should represent the highest standard of environmental performance. It should be reserved for activities that are clearly aligned with long-term net-zero objectives and deliver significant climate benefits with minimal environmental impact.
Maintaining a high threshold for entry into the green category will help prevent greenwashing, provide clarity to investors, and ensure that the designation remains a trusted indicator of climate leadership.
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?
Neutral
15b. Please explain your answer in the space below
Potential risk of abatement category being abused by companies unwilling to adapt to clean energy.
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.
17. Is there any other feedback you would like to provide on the proposed activity classification framework?
I would welcome additional clarity on how DNSH and MSS considerations are incorporated into the Activity Classification framework.
Specifically, it is unclear at what stage of the assessment process DNSH and MSS criteria are evaluated and how they influence a project's classification as green, transition, or abatement.
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?
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 am broadly supportive of the proposed sustainable finance taxonomy framework. The objectives and overall approach are well aligned with Canada's climate and economic priorities and have the potential to provide greater clarity for investors and project proponents.
However, the Council should consider a more ambitious approach to the inclusion of Indigenous Peoples within the framework. As currently proposed, Indigenous rights are largely considered through a risk-management and "do no harm" lens. While these safeguards are important, the taxonomy should also recognize Indigenous Peoples as partners, rights-holders, and drivers of sustainable economic development.
By incorporating Indigenous ownership, participation, and economic reconciliation outcomes more explicitly into the framework, Canada has an opportunity to distinguish itself as a global leader in sustainable finance and demonstrate how climate action and economic reconciliation can be advanced together.