Canada’s Modern Slavery Act: Highlights From the 2025 Annual Report to Parliament

As outlined in our prior bulletins on this topic, Canada’s modern slavery 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 and child labour in their supply chains during their previous fiscal year. The Act came into force on January 1, 2024. Reports are due annually by May 31 (or earlier for certain federally incorporated entities that provide audited financial statements to shareholders before May 31 of each year). The next reporting cycle commences January 1, 2026.

In this bulletin, we provide an overview of some of the key insights and statistics on reporting in 2025, drawn from the “2025 Annual Report to Parliament on the Fighting Against Forced Labour and Child Labour in Supply Chains Act” published by Public Safety Canada (2025 Annual Report).

Reporting Insights

The 2025 Annual Report indicates that the 2025 reporting cycle saw a notable shift in submission patterns compared to the inaugural reporting cycle:

• Decrease in total on-time reports: By the May 31, 2025, deadline, the government received 4,313 reports, a decrease from 5,650 reports in 2024. Of the 2025 submissions, 135 were filed by government institutions, while 4,178 came from entities.
• Increase in proportion of joint reports: 2025 saw a rise in joint reports, which allow entities to consolidate reporting for corporate groups. In 2025, 1,652 joint reports were submitted, representing 40% of entity filings. This suggests growing adoption of streamlined reporting practices.
• Utilization of the option to submit revised reports to correct or update information: In 2025, 149 revised reports were filed before the deadline, with only the revised versions counted in the analysis.
• Decrease in entities reporting an obligation in other jurisdictions: In 2025, 708 entities reported being subject to such legislation, compared to 796 in 2024. The majority of entities — 3,469 in 2025 versus 4,853 in 2024 — indicated they were not subject to other jurisdictions’ requirements

Finally, late reporting continues to be permitted for transparency purposes. Between May 31 and July 31, 2025, Public Safety Canada received 863 late submissions, a sharp increase from approximately 500 late reports in 2024. By July 31, the total number of reports for the 2025 cycle reached 5,176, and additional reports continue to be added to the online catalogue with late-filing indicators.

Key Market Statistics

The 2025 Annual Report provides valuable insight into current market practices in Canada aimed at addressing the risk of child and forced labour in entities’ operations and supply chains.

• Where are the reporting entities located? In 2025, 79.5% of reporting entities indicated they are headquartered or principally located in Canada, and 20.5% indicated they are headquartered or principally located in another country.
• Which sectors are most represented? The government updated the Questionnaire in 2025, allowing for increased specificity with respect to sectors in which entities operate. In 2025, entities reported for the following industry sectors: Manufacturing (24.9%), Wholesale Trade (11.8%), Retail Trade (8.9%), Mining, Quarrying, and Oil and Gas extraction (6.5%), and Transportation and Warehousing (5.8%).
• How far along in the process are other reporting entities? In a slight increase from 2024, 44.2% (compared to 38.2%) of reporting entities confirmed that they had identified parts of their activities and supply chains that carried a risk of child and forced labour. Whereas 39.2% had started the process but identified gaps in their assessments, and 16.6% had not started the process of identifying risks (down from 22.4% in 2024).
• What are others doing to prevent and reduce the risk of forced and child labour? The most common step selected by reporting entities to prevent and reduce risks in their operations and supply chains was embedding responsible business conduct into policies and management systems (96.6%). This was followed by identifying and assessing potential and actual adverse impacts in operations, supply chains and business relationships (49.8%), ceasing, preventing or mitigating those impacts (34.3%), tracking implementation and results (29.3%), providing for or cooperating in remediation when appropriate (25.7%), and communicating how impacts are addressed (22.9%).
• How common are policies and due diligence processes? In a significant increase from 2024, 84.1% of the reporting entities in 2025 indicated they had policies and due diligence processes in place.
• Do other entities provide training to their employees? Almost two-thirds of reporting entities reported that they provide training (61.7%). Of those that provided training, 37.8% indicated that it was mandatory for all employees.
• How do other entities assess the effectiveness of their efforts to prevent and reduce the risk of forced and child labour? Of the reporting entities that monitor the effectiveness of their efforts (51.2%), key performance indicators and annual reviews were the most commonly reported way in which effectiveness was assessed.

The second reporting cycle under the Act appears to reflect a maturing compliance landscape. While the total number of on-time reports declined, the increase in joint reporting and the rise in entities implementing policies and due diligence processes suggest that organizations are moving toward more integrated and structured approaches to addressing forced and child labour risks. The uptick in late submissions may indicate ongoing challenges with internal readiness and resource allocation. Finally, more entities are identifying risk areas and embedding responsible business conduct into their operations, potentially signalling a gradual but meaningful shift toward proactive compliance and supply chain transparency.

For more information, please contact the authors or any member of our International Trade group.