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ARTICLE · 26 MARCH 2025

Do You Still Need To Report? Thoughts On The Second Reporting Cycle Under The Supply Chains Act

Borden Ladner Gervais LLP
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Given updated guidance from Public Safety Canada (PSC), some businesses that prepared reports on forced labour and child labour in their operations and supply chains in 2024 may not need to report in 2025.

CanadaCorporate/Commercial Law
Benedict S. Wray
Benedict S. Wray
Laura Levine
Laura Levine
Bethany Keeshan
Bethany Keeshan
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Given updated guidance from Public Safety Canada (PSC), some businesses that prepared reports on forced labour and child labour in their operations and supply chains in 2024 may not need to report in 2025.

Takeaways

  • PSC's updated guidance has clarified the meaning of "assets" and the types of activities that will trigger a reporting obligation under the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Supply Chains Act).
  • Some businesses may no longer qualify as "entities" under the Supply Chains Act, and others that are "entities" may no longer have a reporting obligation.
  • Reporting entities should ensure sufficient time to prepare their reports and seek approval from their governing body to meet the May 31, 2025, deadline.

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