By Urshita Grover and Cameron A. Axford

Entities that may be subject to the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Supply Chains Act”) are reminded that their annual report must be submitted to Public Safety Canada by May 31, 2025. The Act, which came into force on January 1, 2024, requires reporting entities to publish annual reports detailing the steps taken in the previous financial year to prevent and reduce the risk of forced and child labour in their supply chains and operations.

As discussed in our November 2024 Charity & NFP Law Update, the Supply Chains Act applies to large Canadian organizations – which could include certain large charities and not-for-profits – if they meet specific thresholds related to revenue, assets, or number of employees. The November 2024 Charity & NFP Update reporting on the Guidance from Public Safety Canada clarified important aspects of the legislation, including how “assets” are defined, what constitutes “importing,” and how “employees” are counted. While few charities and not-for-profits will meet the threshold to qualify as reporting entities under the Supply Chains Act, those that do must ensure they are fully compliant.

Reporting entities required to report must submit a completed online questionnaire, a standalone report approved by their governing body, and appropriate attestation. While the Supply Chains Act emphasizes transparency rather than enforcement, failure to file a timely and accurate report could result in penalties. For more information on the background and applicability of the Act, reference can be made to our earlier coverage in the January 2024 and October 2024 Charity & NFP Law Update.

​Read the May 2025 Charity & NFP Law Update