FAQs Forced Labour – New Reporting Requirements FAQs

Forced Labour – New Reporting Requirements FAQs

Trade Talk Blog


orced labour is a serious human rights violation that affects millions of people around the world. It refers to any work or service that is performed involuntarily under the threat of penalty or coercion. Forced labour can also occur in global supply chains, where businesses may inadvertently source goods or services from suppliers that exploit workers in violation of international standards.

The Canadian government has taken steps to combat forced labour and promote responsible business conduct in global supply chains. One of these steps is the mandating of a report on what companies are doing to prevent forced labour being used in their supply chain. Here are some common questions that have been asked regarding these new reporting requirements.

Who has to report?

Any business whose activities include producing, selling or distributing goods in Canada or elsewhere importing goods into Canada, or controlling an entity engaged in these activities. The entity must also either be listed on a stock exchange in Canada or have a place of business in Canada, do business in Canada or have assets in Canada and meet two of these three criteria for at least one of its two most recent financial years:

  • $20 million or more in global assets (including intangible assets)
  • $40 million or more in global revenue
  • An average of 250 or more employees over the year

Our single company does not meet the size requirements, but our parent and/or sister companies, combined, might. Do we have to file?

This is addressed in the following link – Prepare a report – Entities – the legislation generally adopts a broad interpretation for its terms, so if a combined corporate entity is over the thresholds, a report is likely required. Please reach out to Public Safety if your company needs clarification.

When is the report due?

The report for each calendar year needs to be submitted by May 31st of the following year.

What information must be included on the report?

Public Safety Canada has provided a questionnaire at this link: Forced Labour Report.

Where do I go for more information, or for questions I may have for Public Safety?

We strongly encourage all our clients to read the requirements for themselves if they aren’t sure if they’re required to file a report, or if they want more information on the requirements. The homepage for Public Safety’s information on this reporting is here: Forced Labour in Canadian Supply Chains.

This content is provided for informational purposes only and is not intended to be exhaustive or a substitute for professional advice. While every effort has been made to ensure accuracy, the rapidly evolving nature of laws and policies related to forced labour and supply chain management means that specifics may change over time. Readers are encouraged to consult with our Global Trade Services team for advice tailored to their particular circumstances.

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