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
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
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
- Important
- Dynamic
- Important
- Regionally Specific
- Very important
- Prioritized
- Important
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?
Neutral
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?
Neutral
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?
Neutral
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?
Agree
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?
Strongly agree
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 generally agree that the proposed guardrails provide a strong foundation for maintaining the science-based credibility of the transition category. The framework recognizes the importance of transition finance and includes safeguards intended to reduce carbon lock-in risks. However, clarity would be beneficial regarding the application of lock-in principles, treatment of phased decarbonization pathways, regional differences across Canada, and implementation within multi-tenant building environments – particularly in the industrial sector.
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?
Disagree (i.e., disagree because of how category is designed)
15b. Please explain your answer in the space below
I recognize the value of emissions-reduction investments within demand-decline sectors and support further research into how these activities may be reflected within the taxonomy. However, I have concerns that a distinct abatement category could blur the distinction between activities that are aligned, or capable of alignment, with a net-zero economy and those that are not. Before introducing a third category, additional analysis should be undertaken to ensure clear differentiation from the transition category, maintain science-based credibility, and avoid market confusion regarding the long-term climate alignment of eligible activities.
If an abatement category is ultimately pursued, eligibility criteria should be highly rigorous, time-bound, and focused on demonstrable emissions reductions that do not extend the economic life of emissions-intensive activities beyond what is consistent with Canada's net-zero objectives.
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?
Agree
18b. Please explain your answer in the space below
The emphasis on science-based thresholds, alignment with net-zero pathways, sector-specific expertise, regional considerations, and interoperability with international taxonomies provides a strong foundation for a credible and practical framework.
I particularly support the proposed principles of technological neutrality, regional specificity, and periodic review, as these will be important for ensuring the taxonomy remains relevant across Canada's diverse economic sectors and evolving energy systems.
However, consideration should be made in the following areas as the criteria are developed:
Existing building decarbonization: The taxonomy should ensure that deep energy retrofits, electrification projects, and operational efficiency improvements are appropriately recognized as significant contributors to emissions reductions within the buildings sector.
Regional differences: Technical criteria should reflect variations in electricity grid emissions, climate conditions, infrastructure availability, and technology readiness across provinces.
Multi-tenant real estate assets: Additional guidance will be needed regarding landlord versus tenant control of emissions, particularly for industrial and commercial properties where building owners may not directly control all energy-consuming activities.
Practical implementation: Data requirements and reporting expectations should be proportionate and achievable to encourage broad adoption while maintaining credibility.
Future-focused infrastructure: As criteria are developed for emerging sectors such as data centres, consideration should be given to factors such as low-carbon electricity sourcing, energy efficiency, heat recovery opportunities, and grid impacts.
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
- Important
- Include sunset and/or sunrise dates where relevant
- Important
- Revise as necessary during regular review periods
- 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
- Important
- Informed by a range of robust methods
- Important
20. When thinking about the taxonomy’s credibility and usability, how technologically specific or prescriptive should the technical screening criteria be?
Criteria should be technology-neutral wherever possible, with technology-specific exclusions used only where necessary to maintain scientific credibility and prevent lock-in. This maximizes both usability and long-term relevance while maintaining environmental integrity.
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?
keep the framework science-based, but make sure it works for existing buildings, industrial real estate, electrification projects, and future data centre development.