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?
Select
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?
Select
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 disagree (i.e., disagree on fundamentals)
15b. Please explain your answer in the space below
This category is fundamentally misaligned with the goals of the taxonomy. It provides a loophole for activities that admittedly cannot achieve life-cycle emissions reductions to somehow be counted as "sustainable" anyway. It appears to apply primarily to oil and gas, whose primary emissions come from Scope 3 use, and the category seems based on a naive hope for declining demand. Meanwhile, the industry is working as hard as it can to make sure demand does not decline.
The most likely technology to receive funding from this category would be carbon capture, utilization and storage (CCUS). To date, most CCUS projects have been for enhanced oil recovery, which merely makes it possible to produce even more oil and gas, something that is antithetical to the goals of the program.
The only credible pathway forward to a sustainable energy transition is to rapidly phase out the use of oil and gas. This entire abatement measures category needs to be removed from the taxonomy.
The oil and gas industry is currently enjoying windfall profits from Donald Trump and Bibi Netanyahu's war of choice on Iran. They do not need any government subsidies to fund their own future activities.
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.
16. Should any additional guardrails be considered?
Yes. The only credible guardrail is to eliminate oil and gas investments from the taxonomy. Allowing government to subsidize oil and gas through funding new pipelines or CCUS projects will merely serve to extend the lifespan of an industry that needs to be phased out. Moreover, it will use up scarce government funding that would have otherwise gone to other sectors that will make a real contribution to the energy transition.
There is no enforcement mechanism in the abatement measures category, so oil and gas companies might make "commitments" to invest in CCUS that never materialize. Indeed, The Oil Sands Alliance in Canada originally committed to reduce emissions by 22 MT by 2030 with its CCS project, and to achieve net-zero by 2050 from oil sands production (Bulowski & McIntosh, 2026). They have received tax credits and, recently, commitments for operational subsidies, but the emissions reduction target has been revised down to 6 MT by 2035, with only an additional 10 MT by 2045 (Ibid). As there is no enforcement or oversight mechanism built into the taxonomy, there is nothing to prevent the abuse of the abatement measures category by industry.
References
Bulowski, N., & McIntosh, J. (2026, July 13). Feds lower carbon capture project targets and offer new subsidies as costs double. Canada's National Observer. https://www.nationalobserver.com/2026/07/13/news/feds-lower-carbon-capture-project-targets-offer-new-subsidies-costs-double
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?
Unsatisfied