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 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 annual financial statements to shareholders before May 31 of each year). The next reporting cycle opens January 1, 2026.
To assist reporting entities in meeting and streamlining supply chain transparency reporting obligations across three jurisdictions, Public Safety Canada, in collaboration with the United Kingdom (U.K.) and Australian governments, has released an optional international reporting template for supply chain reporting (Template).
In this bulletin, we provide an overview of the joint initiative aimed at responding to the growing compliance burden faced by multinational organizations by supporting the preparation of one report that can assist in satisfying requirements in all three countries.
Practical Guidance
- Organizations should focus on mapping supply chains proportionately, concentrating on higher-risk areas (e.g., migrant worker recruitment, high-risk geographies and vulnerable industries)
- Organizations may consider having policies reference international standards such as the United Nations (UN) Guiding Principles, Organization for Economic and Co-operation and Development (OECD) guidance and International Labour Organization (ILO) conventions, but this is not required under Canadian law
- Companies are encouraged to disclose training programs, key performance indicators (KPIs), stakeholder engagement efforts and remediation outcomes
- Multi-jurisdictional reports must still meet each jurisdiction’s specific administrative requirements and deadlines (e.g., approval and publication rules in the U.K., filing through Australia’s Modern Slavery Register and Canada’s May 31 annual deadline with Public Safety Canada)
Seven Core Reporting Areas Common to Each Jurisdiction
The Template represents a joint effort by U.K., Australian and Canadian authorities to bring together reporting requirements into seven broad categories that overlap in each jurisdiction. For each area, the Template also provides suggestions about details to consider including in the report:
- Level 1 (baseline/statutory) disclosures: The recommended level of disclosure that authorities suggest entities provide to comply with Canadian, U.K. and Australian legislation when preparing a multi-jurisdictional report. The Template expressly acknowledges that some of the information labelled “Level 1” may exceed the statutory minimum in some jurisdictions.
- Level 2 (enhanced) disclosures: These disclosures represent the governments’ recommended disclosure under the new international Template to show leadership in this area and set a standard for entities to work towards where appropriate. These enhanced disclosures exceed the statutory minimums in many cases, especially in Canada.
This Template does not change the reporting obligations under the Act. When reporting in Canada only, the guidance continues to advise that there is no prescribed level of detail for the Canadian reports. Entities are encouraged to use their discretion in determining the appropriate level of detail proportionate to their size and risk profile, respecting the specified size requirements for the report. Additionally, entities engaged in multi-jurisdictional reporting are free to adopt an approach that complies with the minimum statutory requirements of all applicable jurisdictions.
However, when preparing a multi-jurisdictional report, reporting entities can refer to this chart to benchmark their current reporting against the government’s guidance in the Template and identify areas where moving toward Level 2 disclosures may help to reduce risk exposure, strengthen stakeholder trust and position the business as a leader in transparency.
Level 1 vs. Level 2 Disclosures: A Practical Comparison | ||
Reporting Area | Level 1 – Baseline / Statutory Compliance | Level 2 – Enhanced Disclosure |
Structure & Supply Chains | Describe structure, activities, size, sectors, countries of operation and supply chain profile. Identify entities covered by the statement. | Provide detailed supply chain mapping down to lower tiers (raw materials). Explain recruitment pathways, migrant worker flows, long-term vs. spot suppliers and what is not yet known about the supply chain. |
Policies | Summarize relevant policies (codes of conduct, recruitment, purchasing, prohibitions on child labour, harassment, confiscation of identification documents, etc.). Reference UN, OECD and ILO standards. | Show how policies are implemented, monitored and enforced. Provide case studies, stakeholder engagement evidence, translations, supplier assessments and improvements in purchasing practices. |
Risk Management | Identify high-risk areas of business/supply chains. Disclose how risks are assessed (audits, research, worker engagement, questionnaires). | Provide a modern slavery risk register, with detailed analysis of leverage. Show continuous engagement with workers, NGOs and unions. Set outcome-oriented targets and disclose improvements in purchasing practices. |
Due Diligence & Remediation | Outline due diligence, prevention and mitigation steps, grievance mechanisms and remediation measures. Where applicable, discuss incidents found and remediation actions taken. | Provide in-depth case studies beyond Tier 1 suppliers. Disclose survivor-informed remediation, multilingual grievance access, data on compensation outcomes, judicial results and consideration of whether KPIs/business models create risks. |
Training | Describe relevant training and audiences (frontline staff, HR, procurement, executives, suppliers). | Deliver tailored training by role and sector risk. Collaborate with NGOs/unions/survivors in design. Provide evidence of supplier training, resources (e.g., ethical recruitment tools), update cycles and outcome metrics. |
Assessing Effectiveness | Set goals, identify KPIs, assign accountability and use qualitative and quantitative data to measure progress. | Provide case studies of success. Engage workers directly in evaluations. Disclose short-, medium- and long-term plans. Show evidence of learning from best practices and adapting approaches over time. |
Other Relevant Information | Note year-on-year progress, challenges and additional relevant context. | Provide forward-looking steps for the next reporting cycle, specific improvement commitments and show integration with broader ESG/industry initiatives. |
The Template signals a move toward global alignment of reporting standards on modern slavery and forced labour. For multinational entities, it offers an opportunity to consolidate reporting efforts across three similar reporting markets while strengthening transparency and stakeholder trust. Under this Template, the federal government is encouraging companies not only to meet baseline legal obligations but also to consider, where appropriate, Level 2 disclosures — although such disclosures may not be legally required.
The next report to comply with the Act in Canada is due on or before May 31, 2026.
For more information, please contact the authors or any member of our International Trade group.
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