Are You a Reporting Entity? Canada’s Forced Labour and Child Reporting Demystified

Canadian employers subject to the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”) must assess their reporting obligations, gather detailed information on their supply chains, submit an annual report by May 31, 2025, and make the report publicly available.

This blog guides employers through each step, providing a self-assessment questionnaire, outlining required report content, recommending processes for compilation, detailing submission protocols, and identifying best practices for public disclosure.

Self-assessment questionnaire: Is my organization a reporting entity under the Act?

In compliance with the Act, reporting entities must produce and publish a report that attests their efforts in identifying and eradicating forced labour and child labour along their supply chain operations.

How to determine if your organization is a “reporting entity” under the Act? Below is a set of questions that should clarify your obligations under the Act:

1. Is the organization a corporation, partnership, trust, or other organization listed on a Canadian stock exchange?
2. Does the organization have a place of business, carry on business, or own assets in Canada?
3. In at least one of its two most recent financial years, has the organization met at least two of these thresholds?

• $20 million in assets
• $40 million in revenue
• An average of 250 employees

4. Does the organization produce, purchase, or distribute goods in Canada or abroad, or import goods into Canada? 

5. Does the organization control another entity that engages in any of the above activities?

If the answer to these questions is “yes,” the organization is required to report to the Minister of Public Safety and Emergency Preparedness by May 31 each year on steps taken to prevent and reduce the risk of forced labour or child labour in its activities and supply chains.

What is the required report content?

Every annual report must include the following mandatory elements:

Structure, activities, and supply chains

A description of the organization’s corporate structure and scope of operations.

Policies and due-diligence processes

The policies, procedures, and risk-assessment frameworks implemented to identify and mitigate forced labour or child labour risks.

Risk-exposed segments

Identification of supply-chain segments at risk of forced labour or child labour and steps taken to assess and manage those risks.

Remediation measures

Actions taken to address any identified use of forced labour or child labour.

Income-loss remediation

Measures to mitigate income loss among vulnerable families affected by elimination measures.

Employee training

Details of training programs provided to employees on forced labour and child labour issues.

Effectiveness assessment

Methods and metrics used to evaluate the success of prevention and mitigation efforts.

Each report must be approved by the entity’s governing body and include a signed attestation confirming its completeness and accuracy.

What are some best practices for preparing a compliance report?

To compile the required information efficiently, best practices for reporting entities can be:

Establish cross-functional teams

Include representatives from procurement, legal, compliance, human resources, and operations.

Map supply chains

Use supplier questionnaires, site visits, and third-party audits to identify high-risk suppliers and geographies.

Document policies and procedures

Maintain written records of anti-forced-labour policies, due-diligence protocols, and corrective-action plans.

Implement tracking tools

Use data-management software to monitor supplier performance and remediation activities.

Conduct regular reviews

Schedule quarterly or biannual risk assessments and review sessions to update risk profiles.

Secure governance approval

Prepare board-level briefing materials and secure formal sign-off on the final report and attestation.

What are the submission details for 2025?

Reports covering the financial year ending in 2024 must be submitted on or before May 31, 2025, through Public Safety Canada’s online questionnaire platform. Each report must include a PDF of the full report and responses to the platform’s structured questionnaire. Employers should verify submission confirmation to ensure compliance with statutory deadlines.

What are my public disclosure obligations and best practices?

The Act requires that every report must be made publicly available in a prominent location on the reporting entity’s website and in Public Safety Canada’s online catalogue:

Dedicated webpage

Create a stand-alone page where you can host your organization’s yearly report.

Clear labeling

Use consistent file names and headings (e.g., “2024 Modern Slavery Report – [Entity Name]”).

Accessibility

Ensure the report PDF meets accessibility standards (e.g., searchable text, tagged headings).

Promotion

Announce the report’s availability via press release, social media, or stakeholder newsletters.

Archiving

Maintain past reports in an “Annual Reports” section to demonstrate ongoing compliance and transparency.

How should entities handle the submission of joint reports with their subsidiaries?

Entities may submit a joint report covering both a parent company and its subsidiaries under subsection 11(2) of the Act by observing the following requirements:

Eligibility

A parent and any subsidiary it controls may file a single report instead of separate filings, provided the same general information applies across all entities covered.

Identification of covered entities

The joint report must clearly list the legal name of each entity included, so readers can distinguish which subsidiaries are part of the submission.

Completion of the online questionnaire

Only the entity submitting the report (typically the parent company) needs to complete Public Safety Canada’s online questionnaire and upload supporting documents.

Applicability of content

Joint reporting is appropriate only when risk profiles, policies, and due-diligence processes are broadly consistent among the parent and its subsidiaries. If subsidiaries have materially different practices or exposures, separate reports should be filed to ensure accuracy.

Specification of subsidiary measures

Even within a joint report, entities must describe any distinct steps taken by individual subsidiaries-such as tailored supplier audits or training programs-alongside group-wide strategies.

Need support ensuring compliance with these changes?

Compliance with the Fighting Against Forced Labour and Child Labour in Supply Chains Act requires Canadian employers to conduct a careful self-assessment, gather comprehensive supply-chain data, secure governance approval, submit a detailed report by May 31 each year, and publicize the report.

Whether you need support complying with these changes or professional guidance on any HR or health and safety matter, Peninsula can help. To learn more about how our services can benefit your business, call us today: 1 (833) 247-3652