By Urshita Grover and Cameron A. Axford

Public Safety Canada Releases Second Supply Chains Act Report

Public Safety Canada published its second annual report (the “Report”) for the 2025 reporting cycle under the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Supply Chains Act” or “Act”) on October 17, 2025. The Act, which came into force on January 1, 2024, requires annual reporting by certain government institutions and large Canadian-based organizations, referred to in the Act as “entities”, with the aim of increasing transparency regarding the use of forced and child labour by these entities. As reported in our May 2023 Charity and NFP Law Update, the high threshold for what constitutes an “entity” under the Act means that only a limited number of charitable or not-for-profit organizations that meet certain criteria – including two of the three following thresholds: having at least $20 million in assets, at least $40 million in revenue, and an average of at least 250 employees – are subject to its reporting obligations.

As mentioned in our November 2024 Charity and NFP Law Update, Public Safety Canada released guidance to help organizations understand and meet their obligations under the Act, later updating it on November 15, 2024, to clarify the requirements and scope of the Act. Required reports include disclosures of an organization’s structure, supply chains, policies, risk-management processes, employee training, remediation efforts and effectiveness assessments, all of which are made publicly available through Public Safety Canada’s online catalogue.

The Report indicated that Public Safety Canada had received over 4,313 reports under the Act by the May 31, 2025 deadline. These included 135 reports from government institutions and 4,178 reports from entities, with 708 of these entities also bound by international supply chain laws. A significant majority (82.3%) of all reporting organizations had identified parts of their activities and supply chains that carry a risk of forced labour or child labour being used, particularly in raw materials, direct suppliers and operations in high-risk locations or sectors for reporting entities. Encouragingly, 84.1% of entities have policies and due diligence processes in place, and 61.7% provide training on these issues. However, only 5% of the entities and government institutions reported implementing remediation measures, such as grievance procedures and workforce integration, while the majority of reporting organizations (91%) reported that such steps did not apply as they had not identified any forced labour or child labour in their activities and supply chains.

The Act provides for penalties for non-compliance, including fines up to $250,000 for obstructing officials, failing to submit a report, or ignoring a ministerial order. Nonetheless, in this reporting cycle, enforcement was still largely focused on raising awareness of the reporting requirements to encourage meaningful action rather than punitive action. 

Canada, UK and Australia Release Joint Modern Slavery, Forced Labour and Child Labour Reporting Template

The Governments of Canada, the UK and Australia, have collaboratively introduced an optional International Reporting Template to reduce administrative burdens and help organizations streamline their compliance with modern slavery, forced labour, and child labour reporting obligations across all three jurisdictions by supporting the preparation of a single report meeting each country’s disclosure objectives.

The new template aims to simplify the reporting process for multinational organizations that are subject to the legislative requirements under Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act, the UK’s Modern Slavery Act 2015 and Australia’s Modern Slavery Act 2018 (Cth). While there are differences in the legislative requirements, scope, and definitions in the three legislations, they all share the common goal: “to promote transparency and encourage responsible business practices by compelling businesses to report on their efforts to address modern slavery risks in their operations and global supply chains.”

The UK and Australian legislation use the term “modern slavery” while the Canadian legislation uses the terms “forced labour” and “child labour”. References to risks in the optional template should be understood as risks of modern slavery, forced labour and child labour.

Structured around seven key reporting areas, the template guides organizations to report on their structure and supply chains, relevant policies, risk management practices, due diligence and remediation efforts, employee training, and methods for measuring effectiveness. It also allows space for additional information organizations may wish to disclose to demonstrate leadership or continuous improvement.

The framework distinguishes between Level 1 (mandatory) and Level 2 (recommended) disclosures. This tiered approach enables entities to tailor their reporting based on risk level and capacity, encouraging a proportionate, risk-based approach rather than a one-size-fits-all model.

For organizations under the jurisdiction of the Supply Chains Act operating in multiple jurisdictions, adopting this template can reduce duplication, enhance efficiency, and strengthen credibility in ethical sourcing and human rights governance. However, Public Safety Canada emphasizes that the tool is a voluntary aid, not a substitute for meeting the distinct legal requirements of each jurisdiction. As such, the few charitable or not-for-profit organizations caught under the definition of “entities” must still comply with the mandatory legal and reporting requirements of the Supply Chains Act, and Public Safety Canada places the responsibility on the entity itself to do so.

​Read the November 2025 Charity & NFP Law Update