As outlined in our prior bulletins on this topic, Canada's
supply chains legislation, the Fighting Against Forced
Labour and Child Labour in Supply Chains Act(Act), requires
reporting entities to complete and submit to the federal government
a mandatory online questionnaire and report about measures taken to
prevent and reduce the risk of forced labour and child labour in
their supply chains during their previous fiscal year. Reports are
due annually by May 31 (or earlier for certain federally
incorporated entities that provide annual financial statements to
shareholders before May 31 of each year). The current reporting
cycle opened January 1, 2026.
On December 19, 2025, Public Safety Canada (Public Safety)
released updated guidance on the reporting process (Updated
Guidance). The changes in the Updated Guidance are described by
Public Safety as clarifications only, intended to make the
reporting process clearer and easier to follow. Importantly, the
Updated