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
- Protection of biodiversity and healthy ecosystems
- Water and marine resource conservation
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?
Agree
2b. Please share the reason for your answer in the space provided
WSP supports the proposed principles and considers usability, interoperability, and credibility to be the most important foundations of the taxonomy.
For WSP, usability is a critical principle. The taxonomy should be practical to apply, supported by clear definitions, technical screening criteria, and evidence requirements that reporting entities can reasonably obtain, verify, and assure. Our analysis of EU Taxonomy demonstrates that complexity can create significant implementation and interpretation challenges without necessarily improving decision-useful outcomes.
Usability should also consider the role of the professional services sector. The taxonomy should be applicable not only to asset owners and operators, but also to organizations that support the planning, design, implementation, optimization, and management of climate-aligned/ sustainable projects and infrastructure. These services are often a critical starting point for climate-aligned investments and play an important role in enabling climate outcomes. As the taxonomy develops, consideration should be given to how definitions, activity classifications, and criteria can be meaningfully applied to professional services activities that directly support climate-aligned investments.
WSP also supports interoperability with major international taxonomies to promote consistency, comparability, and reduced reporting burden for multinational organizations. A dynamic taxonomy is important to reflect advances in science and technology, provided changes are introduced through predictable review cycles that allow reporting entities sufficient time to adapt.
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
- Very important
- Dynamic
- Important
- Regionally Specific
- Not that important
- Prioritized
- Not that 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?
Agree
4b. Please explain your answer in the space below
WSP supports the proposed partial alignment approach. A partial alignment approach would provide more decision-useful information than a binary aligned/not aligned outcome by improving transparency around the extent to which DNSH and MSS criteria have been met, while also highlighting areas where requirements are unmet or evidence is unavailable.
From an implementation perspective, this approach better reflects the practical realities of taxonomy reporting. Experience with EU taxonomy assessment shows that a company may be able to demonstrate substantial alignment with climate-related criteria even if evidencing not every DNSH and MSS requirement can be demonstrated. A strict pass/fail approach risks understating progress and reducing the usefulness of disclosures.
This would preserve credibility while improving usability and providing stakeholders with a more complete picture of performance.
For professional services organizations, the approach may also be more practical where certain DNSH or MSS assessments depend on project-specific, supply chain, or third-party information that may not always be readily available or directly controlled by the reporting entity.
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 generally agree with the proposed scope of objectives under the DNSH and MSS frameworks. The proposed environmental and social objectives are broadly aligned with international taxonomy approaches and support the credibility of the framework.
As the framework develops, equal consideration should be given to usability and implementation. The practical application of these objectives will depend on clear criteria, proportionate evidence requirements, and the availability of information that reporting entities can reasonably obtain and verify.
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?
Disagree
8b. Please explain your answer in the space below
WSP supports the application of consistent DNSH and MSS standards across projects and entities to maintain comparability, credibility, and consistency of taxonomy outcomes. While implementation guidance should be practical and proportionate, applying different standards based on project or entity size may reduce comparability and create additional complexity. The focus should instead be on providing clear, practical guidance that enables consistent application of the framework across different types of organizations.
11. Is there any other feedback you would like to provide on the proposed MSS/DNSH framework?
DNSH and MSS criteria should be supported by clear guidance, consistent interpretation, and evidence requirements that reporting entities can reasonably obtain, verify, and assure. We encourage alignment with existing legislation, recognized standards, and international taxonomy approaches where possible to support consistency, comparability, and efficient implementation.
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.
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?
Select
20. When thinking about the taxonomy’s credibility and usability, how technologically specific or prescriptive should the technical screening criteria be?
Technical screening criteria should be primarily outcome-based rather than technology-prescriptive. This allows flexibility for different technologies and approaches that can achieve equivalent outcomes while supporting innovation and usability.
Final questions
22. Overall, how satisfied are you with the proposed sustainable finance taxonomy framework?
Select
23. Is there any other feedback you would like to provide on the methodology report as a whole that has not already been covered?
As the taxonomy develops, additional implementation guidance will be important for organizations whose activities are not easily linked to a specific asset, facility, or production process. This includes activity mapping, such as determining how services that support multiple projects, sectors, or outcomes should be classified and how associated revenue, CapEx, and OpEx should be allocated. There should be clear definitions which are easily understood, implementable and adopt based on nature of activity. Periodic guidance documents including Illustrations for across industries is also another area where taxonomy should consider improving.
We encourage the development of criteria that are outcome-focused, adaptable, and supported by practical implementation guidance. The framework should be capable of evolving as technologies, markets, and reporting practices mature, while remaining applicable across a broad range of industries and business models, including professional services organizations undertaking activities such as engineering and design, environmental assessment, programme management, asset management, and decarbonization advisory services, where climate and outcomes aligned with other environmental objectives may be delivered without direct ownership or operation of physical assets.