The tracker · Canada
A reporting statute with personal officer liability, paired with an import ban on forced and child labour goods.
Bill C-35 still awaits second reading; the government published its consultation findings on 8 October 2026.
In plain language
S-211 requires covered entities to file annual reports on the steps taken to prevent and reduce the risk of forced labour and child labour in their supply chains, with questionnaire-based filing to Public Safety Canada and board-approved public statements. The act also extended the customs prohibition to goods made with child labour.
The personal exposure of directors and officers to fines has made Canadian boards unusually attentive to a regime that is, on paper, disclosure only. Guidance has tightened each cycle, and debate continues over graduating from reporting to mandatory due diligence.
That debate moved in 2026. On 12 June the government introduced Bill C-35, a standalone forced labour import ban that would let the Minister of Foreign Affairs list high-risk goods and require importers of those goods to supply tracing information on request. Consultations from 27 July to 21 August 2026 asked whether Canadian businesses should also carry mandatory due diligence duties with civil liability, which would take Canada well beyond reporting. On 8 October 2026 the government published two reports on what it heard. Respondents supported a law requiring companies to identify, prevent and mitigate forced labour risks in their international operations and supply chains, while views divided on whether victims should be able to bring claims in Canadian courts. Bill C-35 was still awaiting second reading when Parliament returned on 21 September.
Obligations
Entities must file by 31 May each year, covering structure, policies, risk, remediation and training.
Reports require governing body approval and a signed attestation, with personal liability for false statements.
Timeline
Act came into force.
First reporting deadline passed with several thousand filings.
Guidance revisions sharpened expectations on risk assessment and remediation disclosure.
Third annual reporting deadline passed.
Bill C-35 introduced to replace the Customs Tariff import ban with a standalone, list-based framework for goods produced by forced labour.
Government opened consultations on the Bill C-35 regulations and on mandatory due diligence with civil liability, closing 21 August 2026.
Parliament returned from recess with Bill C-35 still awaiting second reading.
Government published its What We Heard reports on the import ban regulations and on due diligence with civil liability.
Changelog
Added the October 2026 consultation findings and the current stage of Bill C-35.
Added Bill C-35 and the 2026 consultations on mandatory due diligence and civil liability.
Third cycle filing statistics and revised guidance incorporated.
Exposed export value at full application, across the ten tracked origins · Figures come from UN Comtrade. For each country we use what its buyer markets reported importing, rather than what the country itself reported exporting, because several tracked countries report to Comtrade late or not at all. Every share is measured against that country's exports to the nine regulated markets this index tracks, not against its total exports to the world, because no reliable world total exists for countries that under-report. European Union figures add up all twenty seven member states. The European product breakdown by chapter is estimated from the four largest importers, Germany, France, the Netherlands and Italy, and scaled up to the full twenty seven member total, so it captures which products dominate without understating any single one. · methodology
Sources