Canada’s Latest Guidance On Reporting Under The Supply Chains Act: What You Need To Know

The Fighting Against Forced Labour and Child Labour in Supply Chains Act came into force on January 1, 2024 (the “Supply Chains Act”). We provided an overview of the requirements under the Supply Chains Act under the previous guidance here.

The core requirements and obligations of the Supply Chains Act remain unchanged: reporting entities are required to complete an online questionnaire and a report regarding the entity’s guardrails in place to prevent and reduce the risk of forced labour and child labour in their supply chains with respect to their previous fiscal year. Reports are due annually by May 31st.

In December 2025, Public Safety Canada updated its guidance to clarify certain aspects of the reporting process (“Updated Guidance”). These updates consist of minor clarifications to the pre-existing obligations.

We have summarized below these latest updates and highlighted what each of these updates means for a reporting entity.

1. Minor Dealings Exclusion

   An entity that needs to report includes one that:

   • produces, sells or distributes goods (not services) in Canada or elsewhere; or
   • imports into Canada goods produced outside Canada; or
   • controls another entity that does either of two above things.

   Public Safety Canada has clarified that while there is no specific threshold for the minimum value of goods an entity must produce or import to trigger the reporting obligation, it is understood that “very minor dealings” are excluded. This interpretation aligns with generally accepted de minimis principles and that a entity’s reportable activities should be evaluated within the context of the entity’s overall operations.

   Reporting Entity: If you import or produce goods that are incidental, low-volume, or peripheral to your core business, they may be considered very minor dealings, and therefore you would not be subject to the reporting obligation. Entities should use discretion, taking into account the scale, frequency, and relevance of such activities in relation to their broader operations.

2. Attestation Requirement

   Prior to submitting a report, an entity’s governing body must approve the report by including a statement confirming that the report was approved, signed by one or more of its members that approved the report.

   An entity submitting a joint report, a report covering its actions and those of any entities it controls (i.e., its subsidiaries), the statement must also identify whether the report was approved by the governing body of each entity in the report, or just by the controlling entity.

   The Updated Guidance provides clarification with respect to the acceptable signature formats as part of the attestation which is required for the report to be published in Public Safety Canada’s catalogue.

   Reporting Entity: Be sure to allow enough time before the May 31 deadline for the report to undergo the approval process. A valid signature must be provided by a governing body member and can be wet, typed, or digitally inserted. Leaving a blank signature space is not acceptable.

3. Protecting Personal Information

   The Updated Guidance emphasizes that reports must not contain personal information. Any report that includes such information will not be published and will need to be corrected before resubmission.

   Reporting Entity: Prior to submitting an annual report, you must verify that the PDF does not contain any personal information. Personal information includes, but is not limited to, addresses, phone numbers, email addresses, IP addresses, Social Insurance Numbers, and other personal identifiers.

4. International Template Support

   Public Safety Canada recognizes that many entities operating internationally are subject to reporting requirements under supply chain legislation in multiple jurisdictions, such as the United Kingdom's Modern Slavery Act 2015 and Australia's Modern Slavery Act 2018.

   Entities may use the same report prepared for other jurisdictions, provided it includes all the reporting requirements of the Supply Chains Act and covers the appropriate reporting period as specified by the Canadian legislation. It is the entity's responsibility to ensure that the report submitted to the Minister of Public Safety fully complies with all mandatory requirements of the Supply Chains Act.

   The governments of Canada, the United Kingdom, and Australia have collaborated to create a reporting template designed to streamline reporting across these jurisdictions. This resource is intended to assist entities in understanding and meeting transparency requirements in all three countries.

   However, due to varying legal requirements across jurisdictions, entities should carefully review the relevant legislation and government guidance to ensure they understand their specific obligations. This includes familiarizing themselves with the administrative requirements and reporting deadlines for each jurisdiction before submitting their annual report.

   Reporting Entity: If you operate internationally and subject to international reporting requirements under various supply chain legislation, you may use this optional template as a guide to adopt best practices and continuously improve the preparation of their annual reports.

5. Improved Transparency

   Reporting entities are required to complete the online questionnaire in order to submit their report. It is essential that all responses provided in the questionnaire are accurate and consistent with the information outlined in the report, which serves as the public-facing document available in the library catalogue. If additional context or clarification is needed, participants are encouraged to include such details directly within their PDF reports.

   Each reporting entity must ensure their report is prominently published on their website, making it easily accessible to the public. Reports submitted to Public Safety Canada will be made available through a searchable online catalogue.

   The Updated Guidance has clarified that only reports and select data submitted through the online questionnaire will be published on the Public Safety Canada website, following a high-level quality assurance review.

   Reporting Entity: You are required to publish your report on your website and ensure that the responses provided in the questionnaire align with the information in your report.

Conclusion

While these updates do not alter the core reporting requirements, they do provide greater clarity on certain aspects of the process. Our team is available to assist you with navigating the reporting requirements and preparing any necessary supporting documents to ensure compliance.

Footnote

1. Certain federal companies may be subject to different deadlines.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.