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 Guidance does not change the Act’s reporting requirements, and reports prepared using earlier versions of the guidance will continue to be accepted.
Key Updates
The Updated Guidance is intended to provide greater transparency around the reporting process, clarify signature and attestation expectations, and introduce strengthened direction on protecting personal information. It also adds practical examples to support entities preparing reports under Canadian and international modern slavery legislation.
Below is an overview of the key updates.
Clarification About “Very Minor Dealings”
The Updated Guidance provided additional context to assist entities in understanding Public Safety’s description of what may constitute “very minor dealings,” a concept that does not appear in the Act but has been referenced in prior guidance. Earlier versions acknowledged that entities whose production or importation activities were de minimis might fall outside the intended scope of the Act’s reporting obligations but failed to provide practical directions on how to assess that threshold.
The December 2025 update now offers more specificity. It explains that production or importation activities that are “incidental, low in volume, or not central to an entity’s core business” may reasonably be considered “very minor dealings.” The guidance emphasizes that entities should apply their own judgment, taking into account the “scale, frequency, and relevance of these activities” within the context of their overall operations.
This added clarity may assist organizations that engage in only limited production or importation in determining whether their activities rise to the level that would trigger a reporting requirement under the Act or whether they fall within this narrow exclusion.
Enforcement Statement: Selling and Distributing
The Updated Guidance revises the wording previously used by Public Safety regarding entities whose activities are limited to selling or distributing goods. Earlier versions of the guidance explicitly stated that, while such entities fell within the Act’s prescribed list of activities, Public Safety did not expect them to report and would not take enforcement action if they did not do so. In the Updated Guidance, Public Safety has removed the explicit reference to no enforcement action from this section.
The Updated Guidance still states that entities engaged only in selling or distributing goods are not expected to report under the Act. While Public Safety has not provided an explanation for this change, the substantive direction remains consistent: entities whose activities are limited to selling or distributing goods, and who do not otherwise produce or import goods, continue to enjoy an exception from Public Safety’s expectations to file a report under the Act.
Increased Transparency in the Review Process
The Updated Guidance provides meaningful additional insight into the steps Public Safety undertakes after an entity submits its annual report through the online questionnaire and before that report appears in the federal library catalogue.
The Updated Guidance now outlines the workflow more clearly. Once a report is submitted, Public Safety conducts a “high-level quality assurance review” to verify that the submission meets the administrative requirements of the Act. This review is not a substantive assessment of the content of the report; rather, it is intended to ensure that the report is complete, properly formatted, includes the required attestation, and does not contain personal information or other elements that would prevent publication. If issues are identified, such as missing signatures, improper file format or the presence of personal information, Public Safety has confirmed that it will not publish the report until the entity files a revised report with the necessary corrections.
Multijurisdictional Reporting Templates
The Updated Guidance now expressly comments on practices and considerations that may apply to multijurisdictional reporting. Specifically, the Updated Guidance links directly to the optional international reporting template (Template) for supply-chain reporting released by Public Safety in collaboration with the United Kingdom and Australian governments. Our prior detailed guidance about the Template is summarized in the September 2025 Blakes Bulletin: Canada, the U.K. and Australia Release Joint Modern Slavery Supply Chain Reporting Template.
Attestation and Signature Requirements
To reduce delays in publishing reports, the Updated Guidance clarifies what constitutes an acceptable signature on the required attestation. Acceptable options include wet signatures, typed signatures or digital image signatures, while simply typing the word “signed” is insufficient. This clarification reinforces existing requirements rather than creating new ones.
Practical Takeaways
Public Safety has emphasized that these updates are minor, clarifying in nature and do not change the substance of reporting obligations under the Act. Nevertheless, the additional details now provided, as discussed above, should help entities better navigate the practical steps involved in preparing and submitting their annual reports.
For entities now planning for the 2026 reporting cycle, reviewing the Updated Guidance may help streamline internal workflows, reduce avoidable processing delays and provide greater certainty around how Public Safety will administer its review and publication process.
While reports prepared using prior versions of the guidance will continue to be accepted, organizations may wish to incorporate the updated expectations into their upcoming reporting to promote consistency, minimize the need for future revisions and align with emerging best practices under Canada’s modern slavery reporting regime.
For more information, please contact the authors or any member of our International Trade group.
