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Compliance 5 min read Published Updated Credibility 86/100

Fighting Against Forced labor and Child labor in Supply Chains Act

Canada's Fighting Against Forced labor and Child labor in Supply Chains Act requires annual reporting starting in 2025. If you are a Canadian company or one that does business in Canada with C$20M+ in revenue, you need to report on your supply chain due diligence efforts to identify and address forced labor risks. First reports were due May 31, 2024.

Kodi C.

Editor & Research Lead

Accuracy-reviewed by the editorial team

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Canada’s Fighting Against Forced labor and Child labor in Supply Chains Act (Bill S-211) entered into force in January 2024, requiring covered entities to file annual transparency reports to Public Safety Canada by 31 May. The 2025 reporting cycle intensifies scrutiny as federal authorities analyze first-year submissions, publish compliance guidance, and prepare enforcement actions. Companies operating in Canada—or listed on the Toronto Stock Exchange—must refresh governance, universal opt-out safeguards, supplier diligence, and evidence programs to deliver defensible reports while protecting the rights of workers whose data powers monitoring systems. this analysis outlines how to orchestrate the 2025 compliance surge.

Regulatory context and expectations

  • Scope and deadlines. Bill S-211 captures entities producing, selling, or distributing goods in Canada, importing goods into Canada, or controlling such entities when they meet size thresholds. Reports for the 2024 financial year are due 31 May 2025 to Public Safety Canada and must be approved by the governing body.
  • Disclosure content. Reports must describe structure, activities, due diligence processes, risk management, remediation, training, and effectiveness metrics. The 2025 template emphasizes measurable outcomes, supply-chain mapping, and worker engagement.
  • Public accessibility. Reports must be posted on corporate websites and, for listed companies, filed with Corporations Canada. Public access heightens reputational risk and drives the need for verifiable evidence.
  • Enforcement posture. Public Safety Canada has showed it will review 2024 submissions, issue deficiency notices, and may publish non-compliance lists. Penalties reach CAD 250,000 per offense, and directors/officers face personal liability for authorising non-compliant reporting.

Governance alignment and board oversight

  • Mandate a supply-chain transparency steering committee chaired by the chief ethics officer with representation from procurement, legal, human rights, sustainability, internal audit, and privacy. Establish biweekly cadences through June 2025.
  • Refresh board charters to explicitly reference Bill S-211 obligations. Require the board (or delegated committee) to approve the 2025 report, review universal opt-out adherence, and receive dashboards on supplier risk trends.
  • Integrate transparency reporting into enterprise risk management (ERM) frameworks. Document risk appetite statements, scenario plans, and control testing results for internal audit sign-off.
  • Update policies—supplier code of conduct, human rights policy, whistleblower policy—to reference Canadian requirements, opt-out rights for data subjects, and remediation commitments.

Universal opt-out and worker data stewardship

  • Map personal data collected during supply-chain diligence: worker interviews, grievance hotlines, third-party audits, IoT sensors, and whistleblower portals. Ensure opt-out or consent withdrawal requests from workers, contractors, and community members are honored across all diligence systems.
  • Implement privacy-by-design reviews for worker voice tools. Provide multilingual notices describing data usage, retention, cross-border transfers, and opt-out procedures. Store acknowledgment logs to prove informed participation.
  • Coordinate with suppliers to extend opt-out protections. Incorporate contractual clauses requiring suppliers to honor opt-out requests, document how they segregate suppressed data, and notify your organization of privacy complaints within defined SLAs.
  • Design grievance processes that allow anonymous or opt-out-compliant reporting, ensuring individuals can raise forced labor concerns without exposing personal data beyond what is necessary for remediation.

Supply-chain mapping and risk assessment

  • Maintain an end-to-end supplier map covering direct and indirect tiers, geolocation, product categories, workforce composition, and known risk indicators (for example, sectors flagged by U.S. CBP, ILO, or Canadian advisories). Link each node to opt-out status, audit history, and corrective action plans.
  • Run risk assessments combining country risk indices, commodity-specific forced labor prevalence, and supplier past performance. Use scoring models to prioritize due diligence, ensuring metrics respect opt-out commitments by anonymising worker-level data where feasible.
  • Conduct improved diligence for high-risk geographies, including unannounced audits, worker voice surveys, and verification of recruitment fee reimbursements. Capture signed attestations and evidence of remediation.
  • Align risk assessment outputs with the transparency report narrative, demonstrating how findings inform policy updates, training, and supplier engagement.

Operational controls and remediation playbooks

  • Implement standard operating procedures for supplier onboarding, periodic reviews, incident escalation, and contract termination when forced labor indicators emerge. Document universal opt-out decision trees within each SOP.
  • Develop remediation pathways: halting purchase orders, funding worker restitution, partnering with NGOs for victim support, and updating procurement criteria. Store evidence of remediation in the governance vault.
  • Coordinate with customs brokers and trade compliance teams to prevent imports associated with forced labor findings. Integrate opt-out data to ensure individuals who withdrew consent are not exposed in regulatory filings.
  • Maintain whistleblower response teams trained to protect anonymity, manage opt-out requests, and escalate substantiated allegations to senior leadership and the board.

Evidence management and reporting readiness

  • Build an evidence register capturing supplier contracts, audit reports, remediation records, training attendance, grievance logs, opt-out metrics, and communications. Tag artifacts against Bill S-211 disclosure sections.
  • Use secure collaboration platforms to assemble the 2025 report. Enforce version control, track approvals, and store signed board resolutions, legal opinions, and assurance reviews.
  • Engage internal audit or an independent assurance provider to review accuracy, completeness, and opt-out compliance. Document methodology, sampling, and findings to include in the report or supporting materials.
  • Plan for bilingual publication (English/French) and accessible formats. Ensure web postings respect opt-out preferences by removing personal data from case studies or testimonials unless explicit consent exists.

Integration with other regimes

  • Map overlaps with U.S. Uyghur Forced Labor Prevention Act (UFLPA), U.K. Modern Slavery Act, EU Corporate Sustainability Due Diligence Directive (CSDDD), and Germany’s Lieferkettensorgfaltspflichtengesetz. harmonize controls while adjusting narratives to address Canadian specifics.
  • Coordinate ESG reporting teams to align Bill S-211 disclosures with sustainability reports, climate transition plans, and investor briefings. Ensure metrics are consistent and opt-out safe.
  • Synchronize with privacy, security, and HR compliance programs to prevent conflicting guidance on opt-outs, data retention, or worker communications.

Metrics and continuous improvement

  • Track KPIs: suppliers assessed, corrective actions closed, restitution payments delivered, opt-out fulfillment time, grievances resolved, and training penetration. Compare year-over-year progress and tie incentives to improvement targets.
  • Host quarterly lessons-learned sessions with procurement and compliance teams to iterate on tools, supplier engagement, and opt-out handling.
  • Publish public updates (press releases, website hubs) summarizing progress and inviting stakeholder feedback, while safeguarding personal data for opt-out participants.

90-day execution timeline

  1. Days 0-30: Confirm governance structures, refresh supplier risk assessments, launch opt-out capability reviews, and gather evidence for 2024 activities.
  2. Days 31-60: Draft the 2025 report, obtain legal and internal audit feedback, execute remediation on outstanding supplier issues, and prepare board briefing materials.
  3. Days 61-90: Secure board approval, publish the report on corporate channels, submit to Public Safety Canada, file with Corporations Canada if required, and archive evidence for potential federal reviews.

This brief fortifies Canadian supply-chain transparency programs by synchronizing governance, universal opt-out stewardship, supplier diligence, and audit-ready documentation that withstands regulator and investor scrutiny.

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Coverage intelligence

Published
Coverage pillar
Compliance
Source credibility
86/100 — high confidence
Topics
Fighting Against Forced Labor and Child Labor in Supply Chains Act · Modern slavery reporting · Supply chain due diligence · Canada
Sources cited
3 sources (laws-lois.justice.gc.ca, publicsafety.gc.ca, iso.org)
Reading time
5 min

Further reading

  1. Fighting Against Forced Labor and Child Labor in Supply Chains Act — laws-lois.justice.gc.ca
  2. Public Safety Canada guidance for supply chain transparency reports — publicsafety.gc.ca
  3. ISO 37301:2021 — Compliance Management Systems — International Organization for Standardization
  • Fighting Against Forced Labor and Child Labor in Supply Chains Act
  • Modern slavery reporting
  • Supply chain due diligence
  • Canada
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