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
• Protection of biodiversity and healthy ecosystems
• Pollution prevention and control

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

Neutral

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

These are the fitting foundational principles, provided that "usable" is never allowed to override "credible." But we would flag a deeper tension the principles list does not resolve: the taxonomy is voluntary, and voluntary sustainable finance frameworks have a poor track record of being taken up by the issuers whose behaviour most needs to change. Without a mandate or a clear regulatory backstop, a taxonomy tends to be used selectively by issuers who are already credible performers, while the highest-emitting and most consequential actors have little incentive to engage with it at all. On its own terms, a framework that is "credible" in design but ignored in practice is not credible in outcome. We recommend the Council set out, alongside these principles, a roadmap toward mandatory application.

3. Please rate each of the principles below on a scale from “very important” to “not at all important.”

Credible

Very important

Usable

Important

Interoperable

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?

Strongly disagree

4b. Please explain your answer in the space below

A disclosure-only model for DNSH/MSS creates a loophole comparable to the one we flag in 2b. Furthermore, it allows an issuer to claim alignment with the taxonomy while disclosing significant, unresolved harm. We recommend a minimum compliance floor for taxonomy alignment, with disclosure used to show progress beyond that floor.

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

We support the proposed scope but recommend Indigenous rights be treated as an explicit, freestanding pillar of the MSS framework rather than folded into a general human rights category, given Canada's specific history and its constitutional and treaty obligations.

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

Canada has begun codifying UNDRIP (United Nations Declaration on the Rights of Indigenous Peoples) in law. For example, UNDRIP received Royal Assent in June 2021 and established a federal framework for implementation and alignment to align with Canadian law. But the degree of project-level implementation is uneven and not yet fully consistent across all approvals, especially at the level of individual projects. So the taxonomy should not treat bare legal compliance as sufficient for a sustainability label.

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

Free, Prior and Informed Consent (FPIC) processes for Indigenous communities; cumulative and lifecycle impact assessment (rather than single-project assessment); methane emissions (satellite readings, not estimates); just transition protections for workers in transitioning sectors.

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

Applying different DNSH/MSS standards based on project size could create a loophole, allowing large companies to split major projects into multiple smaller ones to qualify for less stringent requirements while the overall impact remains unchanged. If different standards are necessary, they should be based on the activities of the parent entity and all connected entities rather than the individual project. This would better reflect who is ultimately benefiting and reduce the risk of distorted reporting or regulatory avoidance.

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

Yes. The framework as described relies substantially on issuer self-disclosure with no independent verification mechanism. It does not clearly address cumulative harms across multiple smaller projects in the same watershed, region, or Indigenous territory.

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?

FPIC should be treated as an ongoing, revocable consent process rather than a one-time approval. It should require documented, third-party-verifiable evidence of consent. It should further include conditional and withdrawn consent categories, and mandate revalidation whenever project scope, impacts, or governance arrangements change.

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

NA

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

Agree

12b. Please explain your answer in the space below

As the term "green" is contested and controversial, particularly following recent debates over the classification of gas under the EU Taxonomy, it is essential to restrict the green category to activities that achieve absolute zero or near-zero emissions. This definition should be based on absolute emissions rather than emissions intensity and should exclude reliance on carbon capture utilisation and storage (CCUS) or other offsetting technologies that claim to achieve net-zero outcomes, as these technologies have not yet been proven at the necessary scale and have not captured the anticipated amount of carbon to date. Maintaining a strict definition of green will help preserve the credibility of the taxonomy. The framework should also explicitly exclude activities that rely on other forms of carbon reduction or voluntary carbon credit markets from qualifying as green.

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

Neutral

13b. Please explain your answer in the space below

The concept is sound for genuinely hard-to-abate sectors, such as steel, where no low-carbon substitute is currently available at scale. However, the credibility of a transition category depends on the inclusion of robust guardrails. Otherwise, as academic research has shown, transition categories can be exploited to justify the continued expansion of business-as-usual activities rather than supporting genuine transition. Much of the critique relating to these guardrails has already been addressed in our response to Question 14b.

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?

Strongly disagree

14b. Please explain your answer in the space below

For the abatement measures category, activity-level guardrails are insufficient without entity-level tests of transition credibility. An entity can invest in a qualifying transition activity while simultaneously expanding overall high-carbon capacity elsewhere in its business. This is a loophole that has been exploited to justify business-as-usual activities. We recommend that the abatement measures category require evidence of absolute, entity-level emissions reductions, including across parent companies where relevant, consistent with Paris-aligned pathways, rather than relying solely on activity-level or project-level compliance.

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

We strongly oppose the inclusion of an abatement measures category covering oil and gas, for the following reasons.
1. The proposed guardrails for the abatement measures category face a number of challenges regarding their scientific validity and practicality. First, they do not address downstream (Scope 3) combustion emissions, the vast majority of the oil and gas sector's climate impact (Suzuki, 2025). Second, the guardrails rely on activity-level criteria but ignore entity-level transition credibility. Fossil fuel companies can invest in abatement while simultaneously expanding production. To date, no Canadian oil and gas companies have acknowledged the need for a managed decline. Third, distinguishing between "existing" and "new" infrastructure is nearly impossible because oil and gas operations often expand incrementally. Similarly, it is unclear how eligible activities could be limited to those that do not extend the lifetime of existing assets – CCUS is shown to prolong the life of fossil fuel infrastructure (Davoodi et al., 2024). The only credible guardrail to protect the taxonomy’s credibility is exclusion of oil and gas.

2. The abatement measures category is fundamentally misaligned with scientific models for achieving net-zero emissions in line with the goals of the Paris Agreement. Global research from the International Energy Agency (IEA) and the Intergovernmental Panel on Climate Change (IPCC) shows that oil and gas production must be rapidly phased down to limit global warming to well below 2°C (IEA, 2021; IPCC, 2022; IPCC, 2023). The abatement measures category does not contribute to the phase-out of oil and gas. Similarly, research from Canada’s Energy Regulator shows that the phase-out of oil and gas is necessary to achieve net-zero by 2050 in Canada. The Methodology report notes “most of the emissions reductions to the natural gas sector…occur as a result of declining demand rather than abatement measures in the sector” in the 2023 net-zero model from the Canada Energy Regulator. The Methodology Report also cites findings from the Canada Energy Regulator’s 2026 report that suggest that global demand for oil and gas may not decrease rapidly prior to 2050. Regardless of demand decline timing, climate science shows that oil and gas production must be rapidly phased down to achieve net-zero. The taxonomy should be based in science, rather than projected supply and demand trends.

3. Under the abatement measures category, listed examples of eligible technologies are not proven to provide high levels of emissions reductions. Carbon capture, utilization, and storage projects are found to be used more commonly for enhanced recovery of oil and gas for commercial purposes than for climate mitigation, and typically underperform predicted capture levels (Fraser Institute, 2026). CCUS cannot realistically be expected to sequester more than a small fraction of emissions from Canada’s overall energy sector (Ibid). For advanced economies like Canada, the IEA actually recommends early retirement of older plants rather than retrofitting them with CCUS (IEA, 2020). The IPCC notes it is one of the least feasible and most expensive solutions for the energy system (IPCC, 2023 pages 86, FN 136, 103).

4. With no enforcement mechanism, the abatement measures category may result in capital flowing to oil and gas companies based on commitments to decarbonize that are never upheld. If oil and gas activities are not simply excluded from the taxonomy, firms can make promises to reduce emissions in the future, secure preferential capital, and then fail to deliver. Many of Canada’s largest oil and gas producers made net-zero commitments that they never acted on and have since walked away from (Price & Scott, 2025). 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.

5. There is no need for the abatement measures category or label under the taxonomy: oil and gas companies can otherwise access funds for marginal emissions reduction measures. The taxonomy should maintain its mandate of only identifying activities that align with the climate transition. The inclusion of the category is not necessary for the oil and gas sector to continue accessing capital – the taxonomy does not prohibit investment in any sector. Canadian oil and gas companies are currently achieving windfall profits (Bakx, 2026; Canadian Press, 2026). Significant public subsidies are already available to the sector for CCUS investments (Krugel, 2026). The Government of Canada has provided $85.2 billion CAD to the industry since 2020 (Environmental Defence Canada, 2026). Private investors can make independent decisions to invest in oil or gas related projects regardless of the taxonomy. Attaining a label under Canada’s taxonomy is not necessary.

6. Targeted emissions reductions in the oil and gas sector are more likely to be achieved through regulation (e.g. industrial carbon pricing, an oil and gas emissions cap, methane regulations, bans, and moratoria) than through voluntary frameworks like the taxonomy (Canadian Climate Institute, 2024; International Institute for Sustainable Development, 2024).

7. The precedent to create a fossil-fuel-free taxonomy in a country that is a large fossil fuel producer has already been set by Australia (Kelly, 2026).

8. It is inherently contradictory to include activities that are “unable to achieve the life cycle emissions reductions necessary to align with Paris-aligned global pathways” while “anchoring the taxonomy in the ambition of the Paris Agreement” (quotations are from the Methodology Report).

9. The abatement measures category would entrench carbon lock-in by directing capital towards the oil and gas sector that could have otherwise gone towards green and transition-aligned activities. Carbon lock-in occurs when fossil fuel-intensive systems perpetuate, delay, or prevent the transition to low-carbon alternatives. The Methodology Report acknowledges that the abatement measures category poses a high risk of carbon lock-in. By including the abatement measures category, capital that would have flown towards green and transition activities may instead flow towards the oil and gas sector – which perpetuates carbon lock-in.

The full bibliography for the references cited above is attached as a PDF in the “Supporting Documents” section.

16. Should any additional guardrails be considered?

The exclusion of oil and gas is the only guardrail that can safeguard the taxonomy's credibility and scientific integrity. Including oil and gas in a sustainable finance taxonomy would be laughable for international observers and cement Canada’s reputation as a climate laggard.

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

The carbon lock-in and entity-level credibility concerns raised above in relation to the abatement measures category (Q14, Q15b) apply with similar force to the transition category, and we would encourage the Council to apply consistent, entity-level tests across both categories.

18a. Do you agree or disagree with the proposed approach for developing technical screening criteria?

Neutral

18b. Please explain your answer in the space below

It is difficult to agree or disagree with the development of technical screening criteria because it is unclear what the framework currently means by a "high enough bar", as this is a relative concept. The overarching point is that a consistent, sector-by-sector methodology is a sensible approach. However, its credibility depends entirely on the process being led by independent technical experts who are insulated from industry influence and independent of industry lobbying. The technical screening criteria should be science-based and developed using transparent, evidence-based methodologies.

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

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?

Criteria should be reasonably prescriptive, quantitative, and, where relevant, time-bound. They should be anchored to explicit, sector-specific thresholds drawn from recognised science-based pathways, rather than relying on qualitative or self-defined benchmarks. This would reduce room for subjective interpretation and greenwashing, while a regular review cycle would allow thresholds to tighten over time as technology and scientific evidence evolve.

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?

Strongly Disagree

We recommend Scope 2 and 3 accounting be mandatory, not conditional, especially for sectors like oil and gas where downstream combustion emissions of its products represent the large majority of lifecycle climate impact (Suzuki, 2025). A Scope 1-centric approach understates exactly the activities most likely to seek transition or abatement classification.

22. Overall, how satisfied are you with the proposed sustainable finance taxonomy framework?

Very unsatisfied

23. Is there any other feedback you would like to provide on the methodology report as a whole that has not already been covered?

NA