Canadian Government Modern Slavery Reporting Requirements

Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act requires eligible businesses and government institutions to publish an annual report describing how they manage the risks of forced labour and child labour. These reports explain the governance arrangements, policies, due diligence activities, and monitoring processes used to identify, reduce, and respond to labour related risks throughout operations and supply chains. By requiring annual public disclosure, the legislation promotes greater transparency, strengthens organisational accountability, and supports more responsible supply chain management.

Read the full legislation and requirements here: https://laws.justice.gc.ca/eng/acts/F-10.6/page-1.html

Who Needs to Submit an Annual Report?

Canada's reporting framework applies to a wide range of organisations involved in producing, purchasing, distributing, selling, or importing goods. This includes government institutions operating in Canada or internationally. It also applies to corporations, trusts, partnerships, and other unincorporated entities that are either listed on a Canadian stock exchange or maintain a business presence or assets in Canada.

Private sector entities are generally required to report where they satisfy at least two of the following criteria during one of their two most recent financial years:

• At least $20 million in assets

• At least $40 million in revenue

• An average of 250 or more employees.

The legislation may also extend to organisations prescribed by regulation and to entities that control businesses carrying out these activities, allowing the reporting requirements to apply across a broad range of corporate structures.

What are the Reporting Requirements for the Act in Canada?

Canada's annual reporting framework requires organisations to explain how they identify, manage, and respond to forced labour and child labour risks throughout their operations and supply chains. Reports are generally expected to include information on:

• Activities undertaken to prevent and reduce forced labour and child labour in the production of goods

• The organisation's structure, operational activities, and supply chain arrangements

• Policies, governance frameworks, and due diligence procedures supporting labour risk management

• How labour related risks are identified, evaluated, prioritised, and addressed

• Remediation measures implemented where forced labour or child labour has been identified

• Steps taken to minimise financial impacts on vulnerable families following the elimination of exploitative labour practices

• Training and awareness programs provided to employees

• The approach used to measure, review, and improve the effectiveness of actions taken to prevent and mitigate labour related risks.

When do I Need to Report?

Each reporting entity must lodge its annual report with the Minister of Public Safety and Emergency Preparedness no later than 31 May each year. This deadline establishes the legislated timeframe for submitting the required annual disclosure.

How do I Submit my Report?

Meeting Canada's reporting requirements involves several steps beyond preparing the annual report. Reporting entities must lodge an approved PDF report together with the prescribed online questionnaire, with both submissions containing consistent information. The report must also include a signed declaration confirming approval by the organisation's governing body.

After the report has been submitted, it must be published on the organisation's website and is also made available to the public through Public Safety Canada. Organisations incorporated under the Canada Business Corporations Act are additionally required to provide the report to shareholders together with their annual financial statements.

Joint Reports

Where appropriate, organisations within the same corporate group may fulfil their reporting obligations through a single consolidated report instead of lodging separate reports for each reporting entity. This approach can be used where the report accurately applies to every participating organisation and fairly represents the operations, activities, and circumstances of each entity included in the submission.

Revised Reports

Where new information becomes available or a previously submitted report requires correction, an organisation may lodge a revised annual report. The amended version should clearly state the date of the revision and include a summary of the updates made so readers can readily identify how it differs from the original submission.

Penalties for Non-Compliance