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
• Other (please specify)

1b. Specify priority

Animal Welfare
World Animal Protection sees animal welfare as part of the solution to global sustainability challenges in food systems – food systems sustainability can be enabled through animal welfare. The taxonomy should formally recognize that high animal welfare is structurally tied to lower environmental risk. Agricultural eligibility can be based on the Five Domains of animal welfare (Nutrition, Environment, Health, Behavior, and Mental State), moving beyond bare-minimum survival metrics and encourage systemic shifts to plant-based and alternative proteins. There is growing evidence and expert recommendations to meaningfully impact climate mitigation to reduce dependence on intensive animal agriculture and adopt policies that support protein diversification. Plant-forward diets are recommended by IPCC, Chatham House, EAT-Lancet, and others. Regenerative techniques and crop diversity in agriculture production are key to creating resilience and protecting farmer livelihoods, as well as promoting biodiversity and reduce agricultural emissions. Canada is a leader in pulse production; integrating these crops provide a financial opportunity for farmers and strong buffer against impacts of climate disasters and certain pulses like lentils are drought-resistant and reduce dependence on nitrogen inputs.
World Animal Protection supports holistic ESG metrics that factor in broader externalities like water pollution, antimicrobial resistance, deforestation, and biodiversity loss alongside carbon metrics. We are concerned that industrial livestock production may be classified as ‘green’ or ‘transition’ without sufficient consideration of multiple ESG risks related to GHG emissions, biodiversity, water use and antimicrobial resistance, eutrophication and soil degradation. High welfare farming practises overlap with lower GHG emissions, reduced stocking densities and improved soil sequestration.

World Animal Protection invites the Taxonomy Council to consider progressively aligning its taxonomy with the concept of One Health, One Welfare recognizing that human, animal and plant health are linked and that economic activity ultimately depends upon healthy ecosystems and the stability of Earth's life-support systems. Investments that reduce greenhouse gas emissions while simultaneously degrading biodiversity, freshwater resources or ecosystem resilience should not qualify as environmentally sustainable.

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

Agree

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

Partially Agree: It should be interoperable with global frameworks and sustainability reporting systems, without lowering the bar or creating inconsistency. For example, alignment with EU Taxonomy that prevented the industrial meat and dairy sector from receiving a "sustainable" green label, and adopting the EU's precedent of excluding highly intensive livestock operations that do not meet strict biodiversity and circular economy targets.

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

Credible

Important

Usable

Important

Interoperable

Very important

Dynamic

Not that important

Regionally Specific

Not that important

Prioritized

Not that 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?

Disagree

4b. Please explain your answer in the space below

Full alignment with DNSH and MSS criteria should be required for any activity to qualify as taxonomy-aligned. Failure to meet any DNSH or MSS requirement should prevent an activity from receiving taxonomy-aligned status. The proposed partial alignment approach would weaken the taxonomy by allowing projects to receive a sustainability designation even if they fail to meet criteria related to issues such as biodiversity protection or Indigenous rights. A partial alignment approach could be used to allow intensive livestock agriculture activities to receive a sustainability designation, which is problematic.

5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?

Disagree

5b. Please explain your answer in the space below

The proposed objectives covered in Canada’s DNSH framework include climate change adaptation, protection of biodiversity and healthy ecosystems, water conservation, pollution prevention and control, and circular economy. The proposed objectives covered in Canada’s MSS framework include Indigenous rights, human rights, labour standards, corruption and bribery controls, and taxation integrity. These are all essential, however, the objectives currently omit animal welfare and high-risk practices like routine antibiotic use in farming. Research indicates that low welfare systems are dependent on high AMU to compensate for suboptimal conditions that comprise animal welfare making animals more susceptible to disease and infection.
The DNSH criteria may be expanded to include negative impacts on animal welfare and restrictions on harmful agricultural inputs. Intensive livestock production cannot be labeled "sustainable" or "harm-free" if it causes degrades ecosystem integrity and widespread animal suffering.

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

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

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

The DNSH and Minimum Social Safeguards frameworks should explicitly extend to the biodiversity, water, and animal welfare impacts of industrial animal agriculture, not climate mitigation alone.
Zoonotic/pandemic disease risks: Ignoring animal density and immune stress in industrial farming under green finance labels risks incubating pathogens, undermining One Health objectives tied to public health safety. The systemic biosecurity hazards of concentrated animal feeding operations (CAFOs), which are primary drivers of zoonotic spillover and antimicrobial resistance.

Public health threats AMR: The overuse of antimicrobials in high-density livestock farming accelerates global AMR risks. A credible taxonomy must treat AMR as a critical environmental and public health metric.
• Zero Routine Prophylactic Use: Disallow sustainable classification for any farm practicing routine mass medication (prophylaxis or metaphylaxis) of herds or flocks in the absence of diagnosed disease.
• Ban on Critically Important Antimicrobials: Total restriction on the use of human "Highest Priority Critically Important Antimicrobials" (HPCIAs), as defined by the World Health Organization, for veterinary purposes.
• Stocking Density Limits: Tie eligibility to maximum indoor stocking densities and provisions of enrichment that allow animals to express natural behaviors, which drastically lowers stress, boosts natural immunity, and reduces the systemic reliance on antibiotics

Any Canadian financial institution with meaningful agri-food lending exposure is, in effect, carrying transition risk that current taxonomy frameworks do not yet require it to price or disclose in a standardized way. Transition and stranded-asset risk are a real risk for the largest livestock producers.

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?

We agree that the UNDRIP & FPIC are essential and defer to Indigenous Nations and organizations on the specific details of how to operationalize.

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

Agree

12b. Please explain your answer in the space below

World Animal Protection recommends that both the green and transition categories exclude any expansion of intensive animal agriculture.

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

Disagree

13b. Please explain your answer in the space below

The “transition” status should be earned against explicit, science-based thresholds, not assumed as a sector's default classification. The Canadian taxonomy must ensure that labeling an agricultural practice as "green" or "transition-aligned" looks beyond simple greenhouse gas metrics to evaluate environmental and human health trade-offs. In sum, conditional transition criteria must be established, based on specific numeric thresholds.

The transition category must distinguish between those economic activities of agriculture firms that are genuinely ‘green’, those that are transitioning, and those merely paying lip service to issues like climate change and deforestation. Transition distinctions require definitions that clearly separate genuinely green agricultural activities from transitional practices and harmful baseline operations in most present-day industrial agriculture operations.

The most significant issue, looking ahead to consultations and technical criterial related to agriculture, will be over whether, and how, industrial animal agriculture can qualify as a "transition" activity. The most difficult, unresolved question is not whether to have a taxonomy applied to agriculture, but how to treat sub-sectors of the agriculture economy (eg. intensive animal agriculture) that are neither clearly sustainable nor clearly excludable. World Animal Protection's core ask is structured accordingly: not a wholesale blanket exclusion, but a specific, evidence-based position on what conditions industrial animal agriculture would need to meet to earn a "transition" label, modelled on the PSF's 2022 thresholds, with an explicit fallback position that inclusion without such conditions should be treated as a design flaw serious enough to undermine the whole taxonomy's credibility.
World Animal Protection looks forward to serving the public interest through Canada's taxonomy development process, offering evidence as a technical contributor with science-based criteria. Our contributions will target the specific numeric thresholds Canada's technical sub-committee sets for agriculture and forestry — the actual bar an activity must clear to be labelled “transition” — not simply argue for the sector's inclusion or exclusion in the abstract.

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

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

The overarching taxonomy framework must prioritize absolute ecological and climate integrity above all else. Capital must be systematically steered toward Paris-aligned, zero-emission solutions rather than sustaining high-emitting industries under the guise of transition or abatement.

16. Should any additional guardrails be considered?

The activity classification framework's guardrails for higher-emitting or contested sectors should apply with equal rigour to industrial animal agriculture as to any other hard-to-abate sector. The Council's own “credible” principle — grounding criteria in current science and applying guardrails against carbon lock-in — requires drawing on the EU Platform's already-completed 2022 livestock work.

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

Disagree

18b. Please explain your answer in the space below

It is essential that the technical screening criteria do not undermine the objectives of global climate and biodiversity agreements.
Inclusion and engagement with non-governmental organizations, Indigenous-led organizations, technical experts, and international advisory groups will be valuable to the process of developing technical screening criteria.
The EU's Platform on Sustainable Finance (PSF) completed detailed, auditable livestock criteria in March 2022 covering stocking density, pasture access, manure management, and antimicrobial use. PSF's 2022 criteria as a starting draft, rather than commission new technical work on a multi-year timeline Canada does not need to repeat.

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

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

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?

An emissions-only approach that leaves welfare and biodiversity criteria for a later is not sufficient. The focus on climate mitigation, with other objectives — climate resilience, water and marine resource protection, biodiversity protection, pollution control, and circular economy — held back for a future expansion phase with no confirmed date is inadequate. DNSH and Minimum Social Safeguards frameworks for agriculture should include activity-specific biodiversity and welfare thresholds the EU's Platform on Sustainable Finance already drafted for livestock in 2022 or only more general, cross-cutting safeguards. (Australia's governance model — a joint government–finance-sector structure with a dedicated technical expert group — could serve as a reasonable template for Canada)

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

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?

There is concern, as previously outlined by FAIRR for the EU Taxonomy, that industrial livestock production may be classified as ‘green’, without sufficient consideration of multiple ESG risks. Food production is responsible for a quarter of all greenhouse gas (GHG) emissions which are a significant contributor to climate change. Intensively reared livestock has extensive adverse impacts on GHG emissions, biodiversity, water use and antimicrobial resistance, as well as causing eutrophication and soil degradation.

Our organization’s position is that holistic ESG metrics are essential, and that any classification frameworks (including but not limited to agriculture) must factor in broader externalities like water pollution, antimicrobial resistance, deforestation, and biodiversity loss alongside carbon metrics.

The technical capacity to write rigorous, science-based industrial animal agriculture criteria exists as demonstrated UK, EU, Australia taxonomy.

• World Animal Protection wants to help ensure that harmful or emissions intensive practices (like intensive animal agriculture) are not inadvertently categorised as ‘sustainable.’ This will ensure the robustness of the Canadian Taxonomy.
• DNSH criteria must apply to biodiversity, water, and pollution objectives, not climate alone
• The “transition” status should be earned against explicit, science-based thresholds, not assumed as a sector's default classification
• Taxonomy Council should draw on already-completed international technical work — the EU Platform's 2022 livestock criteria (stocking density, pasture access, manure management, and antimicrobial-use thresholds)
• Taxonomy should consider the importance of organic and agro-ecological farming methods.
• Industrial animal agriculture represents a high-emitting sector requiring strict, science-backed screening boundaries to mitigate greenwashing and drive true transition. Industrial animal agriculture is directly relevant to taxonomy considerations as it implicates nearly every environmental objective a taxonomy is built to address (nature, water, health), not climate alone. Beyond climate, industrial livestock production is a documented driver of biodiversity loss and a source of disease risk that taxonomies applying Do No Significant Harm (DNSH) tests across multiple objectives cannot easily set aside.
• Any financial institution relying on a narrowly climate-focused test for "sustainable" or "transition" agriculture understates its true exposure to biodiversity, AMR, and pandemic-risk-related liabilities.

There are significant implications for financial institutions with material industrial animal agriculture exposure. Some of the risks and opportunities include: Transition and stranded-asset risk; Disclosure and compliance risk; Greenwashing liability; Reputational risk; & Systemic risk. We welcome the opportunity to provide supporting research for each of these risk categories.