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
• Water and marine resource conservation

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

Agree

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

Not that 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?

Disagree

4b. Please explain your answer in the space below

WBA strongly supports the Do No Significant Harm criteria and Minimum Social Safeguards as essential components of a credible sustainable finance taxonomy. While transparency regarding the extent to which individual criteria are met is important, disclosure alone should not be sufficient for an activity to claim taxonomy alignment where material environmental or social safeguards have not been satisfied.

Taxonomy alignment provides an important signal to investors and other market participants about which economic activities contribute credibly to the transition. Allowing activities to claim alignment while disclosing non-compliance with material DNSH or MSS criteria risks weakening that signal and creating a distinction between technical climate mitigation performance and the wider environmental and social integrity of the transition.

WBA's assessment of 280 influential companies across oil & gas, electric utilities, steel and automotive demonstrates why minimum social safeguards are particularly important. While companies are increasingly developing climate commitments, the social dimension of transition planning remains significantly underdeveloped. Only 15% of companies assessed base their just transition planning on social dialogue, stakeholder engagement or assessment of social impacts, and only 8% combine this with valid climate targets. Furthermore, only 4% have measurable, time-bound targets addressing transition impacts on workers and 3% for affected communities.

These findings suggest that disclosure requirements alone are unlikely to provide sufficient protection against adverse social impacts. WBA therefore recommends that material DNSH and MSS requirements should operate as minimum conditions for taxonomy alignment, particularly where potential impacts concern human rights, workers, affected communities and significant environmental harm. Disclosure should complement these minimum requirements by providing transparency on how they are being met, rather than substitute for them.

Where a phased approach is considered necessary to support implementation, the taxonomy could distinguish between activities progressing towards compliance and those eligible to claim full taxonomy alignment. This would preserve transparency and encourage improvement without weakening the integrity of the taxonomy-aligned label.

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

WBA supports a broad DNSH and MSS framework that recognises that an activity contributing to climate mitigation should not create significant adverse impacts elsewhere, environmentally or socially. In particular, we welcome the recognition that transition activities need to be considered not only in terms of their emissions impact, but also in relation to human rights, workers, communities and other environmental objectives.

We recommend that the MSS framework gives explicit and substantive consideration to the social consequences of economic transition, including impacts on workers and affected communities, meaningful stakeholder and social dialogue, decent work, reskilling and access to alternative economic opportunities. These considerations are particularly important in sectors and regions characterised by high levels of fossil-fuel dependency.

WBA's recent assessment of 280 influential companies across oil & gas, electric utilities, steel and automotive demonstrates the scale of this gap. Only 19% of companies meaningfully engage their workforce on just transition, while only 9% engage affected communities in addition to their workforce. Only 18% commit to creating or supporting decent employment through the transition, while just 4% have measurable, time-bound targets addressing impacts on workers and 3% have such targets for affected communities.

This evidence reinforces the importance of ensuring that Canada's taxonomy does not define transition solely through an environmental or technological lens. A climate-aligned investment should contribute to a managed and just transition rather than shifting environmental, economic or social costs onto workers, communities or other affected stakeholders.

WBA would therefore encourage the DNSH and MSS objectives to explicitly capture meaningful engagement with affected stakeholders, management of workforce and community impacts, respect for internationally recognised human and labour rights, and measures supporting a just transition where activities involve significant structural economic change

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

WBA supports grounding the DNSH and MSS frameworks in Canadian legislation while allowing the taxonomy to go beyond existing legal requirements where necessary. Anchoring the framework in domestic legislation provides legal coherence and a clear baseline for implementation. However, compliance with existing law alone should not necessarily be considered sufficient to demonstrate that an activity does no significant harm or meets the minimum social safeguards expected of a credible transition activity.

Sustainable finance taxonomies are intended to help direct capital towards activities consistent with future climate and sustainability objectives. They should therefore be capable of reflecting forward-looking expectations and internationally recognised standards, particularly where existing legislation has not yet evolved sufficiently to address emerging transition-related environmental and social risks.

WBA's assessment of 280 influential energy and energy-intensive companies demonstrates the importance of clear policy and regulatory signals. Sectors operating within clearer regulatory transition pathways show more advanced corporate transition planning, while fragmented or insufficient policy signals can slow capital reallocation and structural transformation.

WBA therefore supports an approach in which Canadian legislation provides the foundation for DNSH and MSS, complemented where appropriate by credible internationally recognised frameworks and standards. This is particularly important in relation to human and labour rights, just transition, impacts on affected communities and environmental objectives where taxonomy alignment should represent a higher standard than minimum legal compliance.

Where the framework goes beyond existing Canadian legislation, the additional expectations should be clearly defined, transparent and consistently applicable, providing companies and investors with the certainty needed to incorporate them into transition planning and investment decisions

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

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?

WBA recommends that the MSS framework explicitly recognise the UN Declaration on the Rights of Indigenous Peoples (UNDRIP) and operationalise Free, Prior and Informed Consent (FPIC) as a substantive safeguard for taxonomy-aligned activities where Indigenous Peoples and their rights, lands, territories, resources or livelihoods may be affected.

Importantly, FPIC should not be reduced to a requirement to disclose whether consultation has taken place. The framework should distinguish between stakeholder consultation and rights-based engagement leading to Free, Prior and Informed Consent, consistent with UNDRIP. Where FPIC is applicable, issuers should be expected to demonstrate how Indigenous Peoples were identified and engaged, how information was provided sufficiently early and in an accessible form, how Indigenous Peoples' own representative institutions and decision-making processes were respected, and how consent and any associated agreements are documented and monitored.

The MSS framework should therefore establish clear minimum requirements for FPIC where applicable, supported by transparent evidence and ongoing engagement throughout the lifecycle of the activity. Where FPIC is required but has not been obtained, disclosure of that fact alone should not be sufficient for the activity to claim full taxonomy alignment.

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

Agree

12b. Please explain your answer in the space below

Maintaining a clear and ambitious threshold for the green category is important for the credibility of the taxonomy and for providing an unambiguous signal to investors about the activities and technologies that are consistent with a low-carbon economy

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

Agree

13b. Please explain your answer in the space below

The transition category has an important role in recognising activities that remain necessary in a Paris-aligned economy but currently have materially high emissions and require significant transformation to reach zero or near-zero emissions. This is particularly relevant for hard-to-abate sectors where technically and commercially viable substitutes are not yet available at sufficient scale.

WBA's assessment of energy-intensive sectors illustrates both the importance and scale of this challenge. In steel, for example, transition pathways require significant capital investment in new production infrastructure, including renewable-powered electric arc furnaces and green hydrogen-based production. Yet only 14 of the 57 steel companies assessed report low-carbon capital expenditure, averaging just 15% of total CapEx against a sectoral expectation of 80%.

WBA would therefore encourage the taxonomy to ensure that classification within the transition category reflects not only improvements in the emissions performance of an individual activity, but a credible pathway towards the green threshold. This should include clear time-bound decarbonisation trajectories and evidence that capital expenditure and relevant business-model decisions are consistent with that trajectory.

WBA's evidence shows that commitments to low-carbon business models are not always matched by investment. Across the sectors assessed, capital allocation remains a major constraint on transition, demonstrating why forward-looking commitments need to be supported by actual investment decisions.

Finally, the transition category should avoid supporting investments that create or prolong carbon lock-in. The ACT (Accelerating low Carbon transition) framework considers low-carbon business models to be those that contribute substantially to climate mitigation while neither hampering the development of low-carbon alternatives nor locking in assets incompatible with climate mitigation.

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?

Neutral

14b. Please explain your answer in the space below

WBA broadly supports the proposed guardrails but considers that additional safeguards may be needed, particularly for the measures pathway, to minimise the risk of carbon lock-in.

Taxonomy alignment should provide confidence that qualifying investments contribute to a credible pathway towards zero or near-zero emissions, rather than delivering incremental emissions reductions while extending the lifetime of carbon-intensive activities.

WBA’s assessment of 280 influential companies across energy and energy-intensive sectors shows why this matters. Across all four sectors assessed, low-carbon investment falls substantially short of levels expected under 1.5°C-aligned pathways, with capital allocation emerging as a critical barrier to transition.

We therefore recommend that the guardrails consider whether investments are consistent with a time-bound transition pathway, avoid extending high-carbon assets or creating carbon lock-in, and are supported by capital allocation consistent with the required transformation. This would strengthen the science-based credibility of the category while maintaining usability.

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

WBA strongly disagrees with the creation of a separate abatement measures category. Reducing operational emissions from existing fossil-fuel activities, including through methane reduction, electrification and reduced flaring, remains important. However, reducing emissions from producing oil and gas is not the same as transitioning away from fossil fuels. Operational improvements can reduce Scope 1 emissions, but they do not address the much larger emissions associated with the use of oil and gas, nor the need for oil and gas production and demand to decline in Paris-aligned pathways.

WBA's evidence reinforces this concern. Our global assessment of oil and gas companies finds that only 32 of 96 companies report any low-carbon CapEx, averaging just 19% of total CapEx, with forward-looking investment plans showing no acceleration. This indicates that capital allocation continues to reinforce rather than reduce fossil-fuel dependence.

This is also highly relevant in the Canadian context. WBA's 2026 assessment finds that while Canadian financial institutions perform strongly on climate governance and low-carbon financing disclosure, none of the 22 institutions assessed meet WBA's decarbonisation-levers criterion. In particular, none combine phasing out existing fossil-fuel exposure with ceasing new fossil-fuel financing. This reflects a wider gap identified in our Canadian analysis between disclosure and the structural changes and capital allocation needed for a 1.5°C-aligned transition.

Against this backdrop, an activity-level abatement category risks allowing an individual emissions-reduction investment to receive taxonomy recognition while a company's wider production, business model and capital-allocation decisions remain inconsistent with the transition. It could also redirect capital towards improving existing fossil-fuel production rather than towards green and transition activities, increasing the risk of carbon lock-in.

WBA therefore recommends maintaining a clear distinction between financing emissions reductions within existing fossil-fuel activities and financing the transition itself. Abatement measures can and should be financed where they deliver meaningful emissions reductions, but they do not require taxonomy recognition to attract investment. Maintaining this distinction will help ensure that the taxonomy provides a clear signal to companies and financial institutions to direct capital towards the structural transformation required for a 1.5°C-aligned transition.

sources: https://www.worldbenchmarkingalliance.org/benchmarks/2026-benchmark-hub#benchmark-overview-tab-group–411
https://www.worldbenchmarkingalliance.org/latest/fossil-fuel-dependence-becomes-economic-threat-key-industries-lag-turning-climate-pledges

16. Should any additional guardrails be considered?

WBA does not consider that additional guardrails can fully address the fundamental concerns associated with an abatement measures category; the most credible safeguard would be not to include oil and gas within such a category.

If the category is nevertheless developed, additional guardrails should ensure that qualifying measures are assessed in the context of the company's wider transition plan, production trajectory and capital allocation, rather than at activity level alone. Measures that enable production expansion, extend the lifetime of fossil-fuel assets or create carbon lock-in should not qualify. This is particularly important given the practical difficulty of distinguishing between new and existing infrastructure and determining whether abatement measures extend asset lifetimes.

WBA's evidence reinforces the need for this broader perspective: without shifts in corporate capital allocation and business models, fossil-fuel dependence is reproduced rather than reduced.

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

WBA encourages Canada to ensure that the activity classification framework provides a clear and credible signal for capital allocation towards a 1.5°C-aligned transition. Our evidence shows that disclosure and commitments alone are not sufficient: transition credibility ultimately depends on whether companies are shifting capital, production and business models towards low-carbon activities. Without this shift, fossil-fuel dependence risks being reproduced rather than reduced.
The taxonomy should therefore maintain a clear distinction between green activities, transition activities with a credible pathway to zero or near-zero emissions, and emissions reductions within activities whose demand must decline. Maintaining this distinction will strengthen the taxonomy's credibility and provide companies and financial institutions with clearer signals for long-term investment decisions.

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

Select

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?

WBA recognises the value of focusing on Scope 1 emissions where these represent the most direct and measurable emissions from an activity. However, Scope 2 and particularly Scope 3 emissions should be considered where they are material to understanding the activity's overall climate impact, rather than simply where it is feasible to do so.

This is particularly important for oil and gas, where the majority of lifecycle emissions arise from the downstream use of fossil fuels. A taxonomy assessment focused primarily on operational Scope 1 emissions could therefore classify significant reductions in production emissions without capturing the much larger emissions associated with the product itself.

WBA's own assessment reinforces this concern. Of 100 influential oil and gas companies assessed, only 22 have some form of long-term Scope 3 target and only eight have valid targets, covering just 9% of the sector's Scope 3 emissions.

WBA therefore recommends that materiality, rather than feasibility alone, should determine when Scope 2 and Scope 3 emissions are incorporated into technical screening criteria. Where Scope 3 emissions constitute a significant share of an activity's lifecycle climate impact, they should form an integral part of assessing taxonomy alignment.

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

Neutral

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

WBA supports several important elements of the proposed framework, particularly its ambition to provide clear and credible signals for sustainable capital allocation. However, we have significant concerns regarding the proposed abatement measures category and the risk that it could weaken the distinction between reducing emissions from fossil-fuel production and transitioning away from fossil fuels.

Addressing these concerns would strengthen our confidence in the framework and its contribution to a credible transition. WBA would welcome the opportunity to continue engaging with the Canadian taxonomy process and share evidence from our work on corporate transition planning and capital allocation.