Forced Labour in Canada: Supply Chain Reporting Requirements and FAQs

Last Updated: Aug. 21, 2026

F​orced labour and child labour can occur at different stages of global supply chains, creating risks for businesses that produce, sell, distribute, or import goods.

Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act, also known as the Supply Chains Act, requires certain entities to report annually on the steps they have taken to prevent and reduce the risk of forced labour and child labour in their activities and supply chains. The Act came into force on January 1, 2024.

Here are answers to common questions about Canada’s supply chain reporting requirements.

Who has to report?

The reporting obligation applies to an entity that meets the definition under the Supply Chains Act and engages in at least one of the activities covered by the legislation.

Public Safety Canada’s current reporting obligations guidance states that an entity must meet the applicable definition and then:

• Produce goods in Canada or elsewhere
• Import goods produced outside Canada
• Control another entity that produces goods or imports goods produced outside Canada

An entity generally meets the definition if it:

• Is listed on a stock exchange in Canada; or
• Has a place of business in Canada, does business in Canada, or has assets in Canada and, based on its consolidated financial statements, meets at least two of the following three conditions for at least one of its two most recent financial years:
  • At least $20 million in assets
  • At least $40 million in revenue
  • An average of at least 250 employees

Public Safety Canada’s current guidance confirms these thresholds and explains that entities must assess their own circumstances to determine whether the Act applies.

Does Every Canadian Importer Have to File a Report?

No.

Simply importing goods into Canada does not automatically mean a company must file a report.

The company must first meet the Act’s definition of an entity and then engage in an activity covered by the legislation, such as importing goods produced outside Canada.

A smaller importer that does not meet the entity definition generally does not have a reporting obligation under Part 2 of the Act.

Our Company Does Not Meet the Size Requirements, but Our Parent or Sister Companies Might. Do We Have to File?

Companies should assess their corporate structure and control relationships rather than simply adding the figures of separate companies.

Under the Act, an entity can have a reporting obligation if it controls another entity that produces goods or imports goods produced outside Canada. The Act defines control broadly as direct or indirect control, subject to applicable regulations.

Public Safety Canada’s current guidance also allows qualifying entities to submit a joint report covering multiple entities in certain circumstances. For example, a parent and subsidiary that are both reporting entities may submit a joint report when the information in the report generally applies to both entities.

Companies that are unsure whether their corporate structure creates a reporting obligation should review the Act and Public Safety Canada’s guidance and seek legal advice where appropriate.

When Is the Report Due?

A reporting entity must submit its report on or before May 31 of each year.

The report covers the steps the entity took during its previous financial year, not necessarily the previous calendar year. Section 11 of the Act specifically uses the previous financial year as the reporting period.

For example, an entity with a December 31 fiscal year-end would report on activities during the previous January 1 through December 31 financial year.

The 2026 reporting deadline was May 31, 2026. The next annual deadline is May 31, 2027.

What Information Must the Report Include?

The report must describe the steps the entity took during its previous financial year to prevent and reduce the risk of forced labour or child labour in its activities and supply chains.

The Act requires the report to include information about:

• The entity’s structure, activities, and supply chains
• Its policies and due diligence processes relating to forced labour and child labour
• The parts of its business and supply chains that carry a risk of forced labour or child labour and the steps taken to assess and manage that risk
• Measures taken to remediate forced labour or child labour
• Measures taken to remediate the loss of income to the most vulnerable families resulting from measures taken to eliminate forced labour or child labour
• Training provided to employees on forced labour and child labour
• How the entity assesses its effectiveness in preventing and reducing the risk of forced labour and child labour

Public Safety Canada’s current guidance for entities provides additional information about the mandatory report requirements and the characteristics of a compliant report.

Does the Report Have to Prove That a Company’s Supply Chain Is Free From Forced Labour?

No.

The reporting requirement focuses on the steps an entity has taken to prevent and reduce the risk of forced labour and child labour.

Companies must report on the risks they identify and the measures they take to assess and manage those risks. The Act does not require an entity to certify that its supply chain contains no forced labour or child labour.

Does the Act Require Companies to Eliminate Every Forced Labour Risk?

The Act requires reporting entities to report on their policies, due diligence processes, risk assessment and management measures, remediation measures, training, and effectiveness assessments.

It does not state that a reporting entity must certify that it has eliminated every forced labour or child labour risk from its supply chain. The focus of Part 2 remains the entity’s reporting obligations and transparency regarding the measures it has taken.

How Do Companies Submit the Report?

Public Safety Canada requires reporting entities to prepare a report addressing the mandatory requirements of the Act and submit it through the government’s reporting process.

The report must be submitted in PDF format and must meet Public Safety Canada’s formatting requirements. The current guidance states that the PDF must not exceed 100 MB and must follow the prescribed naming convention.

Entities also need to publish their report in a prominent place on their own website after submitting it to the Minister. Public Safety Canada states that entities do not need to wait for the report to appear in the government’s online catalogue before publishing it on their website.

Is the Supply Chains Act the Same as Canada’s Forced Labour Import Ban?

No. These are separate requirements.

The Supply Chains Act establishes reporting obligations for qualifying entities and government institutions.

Separately, Canada’s customs legislation prohibits the importation of goods manufactured or produced wholly or partly by forced labour. The Supply Chains Act itself amended the Customs Tariff to establish this prohibition.

This distinction matters for importers. A company may have a reporting obligation under the Supply Chains Act, while the separate customs prohibition applies to goods produced wholly or partly by forced labour.

What Changed in 2026?

Canada introduced Bill C-35, An Act respecting the prohibition of the importation of goods produced by forced labour, in June 2026. The proposed legislation would create a new framework for enforcing Canada’s existing prohibition on importing goods produced with forced labour.

The proposed legislation should not be described as a new Supply Chains Act reporting requirement. The existing reporting obligations continue under the Supply Chains Act, which the Department of Justice currently lists as amended on January 1, 2024 and current to June 21, 2026.

Where Can I Find More Information?

Public Safety Canada’s reporting obligations page provides current information about who must report and the annual reporting requirement.

Its guidance for entities explains the reporting process, mandatory information, approval and attestation requirements, joint reports, formatting, and website publication.

For the legal requirements, importers and other businesses can consult the current Fighting Against Forced Labour and Child Labour in Supply Chains Act.