Governance Briefing — Canada Fighting Against Forced Labour in Supply Chains Act reporting
Canadian and foreign entities doing business in Canada must file annual forced labour and child labour reports by 31 May each year under the new Fighting Against Forced Labour and Child Labour in Supply Chains Act.
Executive briefing: Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act (S.C. 2023, c. 9) entered into force on 1 January 2024. The first annual reports are due by 31 May 2024. Boards or governing bodies must approve the report, which discloses policies, due diligence, remediation, and risk assessments covering forced and child labour in supply chains. Entities must submit reports to Public Safety Canada and publish them prominently on their websites.
Key governance signals
- Board approval. Reports must be approved by the entity’s governing body (e.g., board of directors) and include a signed attestation.
- Scope. The law applies to entities listed on a Canadian stock exchange or meeting size thresholds (CAD 20 million in assets, CAD 40 million in revenue, or 250 employees).
- Transparency. Reports must address structure, supply chains, policies, training, remediation, and effectiveness metrics.
Action checklist
- Establish governance workflows so boards review and approve the report before the 31 May deadline.
- Consolidate global supply chain due diligence data, risk assessments, and remediation actions to support disclosure.
- Coordinate communications, legal, and sustainability teams to publish reports online and respond to stakeholder inquiries.
Enablement moves
- Implement supplier diligence platforms that track risk scores, contractual commitments, and corrective actions across jurisdictions.
- Develop training programmes for procurement and compliance teams on the Act’s requirements and escalation pathways.
- Integrate reporting outputs with ESG dashboards and investor communications to demonstrate continuous improvement.
Sources
- Fighting Against Forced Labour and Child Labour in Supply Chains Act
- Public Safety Canada — Guidance on forced labour supply chain reporting
Zeph Tech enables Canadian reporting teams to operationalise board approvals, supplier due diligence, and transparency portals for the new forced labour reporting regime.