Public Safety Canada: Supply Chains Act Reports Due by May 31

Businesses must prepare to comply with the updated reporting requirements of the Supply Chains Act to address the risks of forced and child labour in their supply chains.

Public Safety Canada is reminding businesses that the deadline to submit their annual report under the Fighting Against Forced Labour and Child Labour in Supply Chains Act is May 31, 2025.

Forced labour is a global issue. According to the International Labour Organization (ILO), 27.6 million people worldwide are affected by it, including 17.6 million in the private economy.

Considering the complexity of global supply chains, there is a risk that goods entering the Canadian market may have been produced using forced or child labour.

In response, the Supply Chains Act was introduced to help fulfil Canada’s international commitment to combat forced labour and child labour—through certain reporting obligations.

As part of the 2025 reporting cycle, entities must complete a new online questionnaire in addition to submitting an annual report.

Public Safety Canada advises entities to review the online questionnaire in advance and prepare their responses before the deadline.

Entities should also be aware that updated definitions of key terms such as goods, assets, and importers now apply—following amendments made in November 2024.

Who must submit a report

To increase transparency and hold businesses accountable, the law requires certain entities to disclose the steps they took during the previous financial year to prevent and reduce the risk of forced labour or child labour in their supply chains.

This applies to Canadian entities that produce, sell, or distribute goods in Canada or elsewhere, or import goods into Canada.

Under the Supply Chains Act, an entity is defined as a corporation, trust, partnership, or other unincorporated organization that meets any of the following criteria:

• It is listed on a stock exchange in Canada.
• It 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 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
• It is prescribed by regulations.

Content of the report

The report must include the following elements:

• A description of the entity’s structure, activities, and supply chains.
• Details of the entity’s policies and due diligence processes in relation to forced labour and child labour.
• The parts of the business and supply chains where there is a risk of forced or child labour being used, along with the steps taken to assess and manage those risks.
• Any measures taken to remediate any forced or child labour.
• Actions taken to remediate income loss for vulnerable families affected by the elimination of forced or child labour.
• The training provided to employees on forced and child labour.
• How the entity assesses its effectiveness in ensuring that forced and child labour are not being used in its business or supply chains.

If entities are submitting a joint report, only one entity should fill out the online questionnaire on behalf of all entities included in the report.

Moreover, entities must make the report publicly available, including by publishing it on their website.

How Cole International can help

At Cole International, we provide customs and compliance consulting to help you navigate changing regulations and ensure full compliance.

Please reach out to one of our trade professionals for more information on the reporting requirements and recent updates to key definitions under the Act.