Canada, Australia And The UK Release Multi-jurisdictional Report Structure For Forced Labour And Child Labour Reporting

In July 2025, the Australian, Canadian and United Kingdom governments jointly released an optional multi-jurisdictional reporting template (the Template) for companies subject to reporting obligations on measures taken to prevent forced and child labour in their operations and supply chains. The Template is designed to ease the administrative burden on organizations subject to supply chain reporting requirements in several of these jurisdictions.

The Template groups the legislative requirements found in all three jurisdictions' modern slavery legislation into seven overarching categories for organizations to consider. Additionally, the Template provides guidance on how to meet current legislative requirements in addition to outlining suggested best practices regarding reporting

What you need to know

• The Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Canadian Act) entered into force on January 1, 2024. The Canadian Act (1) imposes a reporting requirement on organizations and government institutions on measures taken to combat the risk of forced labour or child labour in their operations and supply chains and (2) strengthens an import ban on goods manufactured by forced labour and child labour. Public Safety Canada has provided guidance to aid entities required to report under the Canadian Act, which we discuss in previous bulletins¹.
• The United Kingdom and Australia have comparable legislation in place: the Modern Slavery Act 2015 (the UK Act) and the Modern Slavery Act 2018 (the Australian Act). While there are certain differences among the Canadian, Australian and UK Acts, they are all aimed at promoting and encouraging responsible business practices by compelling businesses to report their efforts to address forced labour and child labour in their operations and supply chains.
• For organizations operating in Canada, Australia and the UK, the Template brings together the reporting requirements from all three jurisdictions into seven categories, facilitating compliance for multi-jurisdictional entities by aligning the separate reports for each jurisdiction into a single document.

The Template

Core reporting requirements

The Template sets out seven categories of reporting requirements, meeting the legislative requirements of all three jurisdictions. These categories are similar to, and based on, the reporting requirements set out in section 11(3) of the Canadian Act. The Template indicates that entities should report the following:

1. The organization's structure (including its operations, activities and supply chains).
2. The organization's policies in relation to modern slavery, forced labour and child labour.
3. The risk management processes in place to assess and address the risk of modern slavery, forced labour and child labour and any related remediation measures in place.
4. The organization's due diligence processes in relation to modern slavery, forced labour and child labour in supply chains, and any related remediation measures in place.
5. The training provided to employees on modern slavery, forced labour and child labour.
6. How the organization assesses the effectiveness of the actions it has taken to prevent and respond to modern slavery, forced labour and child labour, and its due diligence processes.
7. Any other information the organization considers relevant.

Levels of reporting

The Template sets out two levels or depths of disclosure for each reporting requirement: Level 1 covers the information organizations must include in their statements and annual reports to comply with UK, Australian and Canadian reporting laws; Level 2 indicates additional disclosure that organizations may consider to show progress and leadership in supply chain transparency and reporting. As the common goal of all three Acts is to encourage continuous improvement, Level 2 disclosure may provide organizations with ideas on additional measures to implement in future years.

What's next

While the next annual reports under the Canadian Act are not due until May 31, 2026, organizations with reporting obligations in two or more of these jurisdictions may consider how the Template may prove a helpful tool to decrease the administrative burden of reporting during their next reporting cycle.

Footnote

1 Please see our series of bulletins that cover this matter further, from most recent to oldest: (1)Fighting Against Forced Labour and Child Labour in Supply Chains Act: further updated guidance from the Minister; (2)Canada launches consultations to strengthen anti-modern slavery regime; (3)Fighting Against Forced Labour and Child Labour in Supply Chains (Bill S-211): Updated Guidance from the Minister; (4)Fighting Against Forced Labour and Child Labour in Supply Chains Act (Bill S-211): 10 key clarifications from the Minister; (5)Fighting Against Forced Labour and Child Labour in Supply Chains (Bill S-211): government publishes guidance;(6)Is your supply chain ready for Canada's modern slavery legislation?and (7)Canada's modern slavery legislation to create reporting obligation.

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.