The tracker · Canada
A reporting statute with personal officer liability, paired with an import ban on forced and child labour goods.
Third annual reporting cycle closed 31 May; Public Safety guidance continues to firm up expectations.
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.
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.
Changelog
Third cycle filing statistics and revised guidance incorporated.
Sources