Chapter 04 · People & supply chainsSupply Chain & Due Diligence
Canada — Fighting Against Forced Labour and Child Labour in Supply Chains Act
Definition
A Canadian statute (S.C. 2023, c. 9; originating as Bill S-211) requiring government institutions and private entities that meet size thresholds — at least two of C$20 million in assets, C$40 million in revenue, or 250 employees — and that produce, sell or import goods, to report annually to the Minister of Public Safety on steps taken to prevent and reduce the risk of forced labour and child labour in their operations and supply chains. In force 1 January 2024; reports are due on or before 31 May each year.
References
In force 1 January 2024; 31 May deadline; 4,313 reports in 2025; seven content areas incl. remediation and effectiveness assessment; public catalogue; ~50% effectiveness-policy finding.
S.C. 2023, c. 9; size thresholds ($20M assets / $40M revenue / 250 employees, two of three); December 2025 updated guidance.
Overview
What it means
The Act follows the transparency model — reporting, not substantive due diligence — but its required content is unusually detailed: seven mandated areas including policies, risk assessment, remediation measures (specifically of forced or child labour found, including remediation of loss of income to vulnerable families), training, and an assessment of effectiveness. Reports go into a public online catalogue.
The 2025 cycle drew 4,313 reports; Public Safety Canada's report to Parliament noted only around half of reporting entities had policies assessing the effectiveness of their actions. Updated guidance (December 2025) clarified expectations. Failure to report is an offence; critics press for mandatory due diligence on the European model.
How it is used
Covered entities file annual reports and publish them on their websites; investors and NGOs mine the public catalogue; Canadian subsidiaries of global groups align Canadian reports with UK/Australian modern-slavery statements.
Why it matters
The Act extended modern-slavery reporting to the North American market at scale and, with its effectiveness-assessment requirement, pushed transparency regimes a step beyond disclosure-for-disclosure's-sake.