Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act ("Supply Chains Act), formerly known as Bill S-211, is the country’s new legislation aimed at fighting modern slavery. It requires annual reporting on the steps taken to prevent and reduce the risk of forced and child labour being used in goods imported into Canada, as well as in the production of goods, whether here or elsewhere.
On May 11, 2023, the Fighting Against Forced Labour and Child Labour in Supply Chains Act received Royal Assent and became law coming into force on Jan. 1, 2024. It requires that annual reports to the federal government on forced and child labour are be submitted by business entities by May 31 of each year. However, the government has publicly signalled that it may delay some or all of the new requirements of Bill S-211. Currently, it remains unclear whether the government intends to delay the new reporting requirements, changes to the import ban, or both.
This new annual reporting obligation applies to corporations, trusts, partnerships and other unincorporated organizations (generally, “businesses”) that produce, sell or distribute goods in Canada or elsewhere, import foreign goods into Canada or control an entity that is engaged in such activities, provided that such businesses fit into one of the following categories:
