Forced Labour and Increasing Supply Chain Scrutiny: Long-awaited Guidance Released on Canada's Forced Labour Reporting Requirements

  • 06 février 2024
  • Kathleen Wang and Jessica Horwitz

On May, 3, 2023, the Canadian Parliament passed a supply chain transparency law, the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act).[1] Among other amendments to Canada's import laws, notably, the Act introduces a forced labour diligence public reporting requirement that will apply to both private sector entities and government institutions. The first reporting deadline approaching, with reports due by May 31, 2024.

Government institutions and private sector organizations that meet the definition of "entity" under the Act will have to:

  1. Prepare a public report that is to be uploaded to a government registry and also posted on the entity's website; and
  2. Respond to an online questionnaire that aligns with the various supplementary information specified in the Act.

The public annual reports filed by private sector entities must include the steps the organization took during the previous financial year to prevent and reduce the risk that forced labour or child labour is used or in the entity's supply chains. The report must also include the following information in respect of each applicable reporting entity: