Forced Labor Reporting: Canada Deadline Imminent

Editor’s Note: This article has been updated for the 2026 reporting year. It includes information and guidance from the original 2025 post that is still relevant.

The 2026 reporting deadline for Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act (Bill S-211) is near, and companies in scope are expected to report with more transparency than ever. 

In year three of the reporting cycle, manufacturers must be prepared to submit their public reports to Public Safety Canada (PSC) by May 31, 2026, as in previous years. However, there are now additional expectations around sustainability goals tied to due diligence that companies need to be prepared to address. The training wheels are off and companies in scope must approach their due diligence seriously, as other jurisdictions are proving that forced labor compliance is the new expectation, not just a nice-to-have.

To demonstrate compliance, your company must disclose: 

• Actions taken in the previous year to prevent and reduce the risk of forced labor and child labor in your supply chain, including relevant policies and due diligence processes.
• Measures taken to remediate forced labor.
• Education provided to employees on forced and child labor.

One of the most understated expectations for this year, per PSC guidance, is that companies are expected to demonstrate progress year-over-year and set specific goals over the short- and long-term as part of their active due diligence frameworks. With over 84% of reporting entities maintaining formal due diligence processes, there is a clear trend in the market for companies to meet regulatory requirements head-on with mature sustainability programs. The bar has been set high, and in-scope companies are expected to comply. What has your organization done to increase transparency and decrease risks in the supply chain?

Companies will need to ensure visibility into their supply chains, and demonstrate that they have formal due diligence programs in place to protect their business and support adherence to reporting requirements moving forward. Without this level of transparency, businesses could lose market access if they are discovered to have ties to forced labor. Nearly 50 shipments were detained at the Canadian border in 2025 alone. Furthermore, the Canadian government has committed a substantial sum of over $617 million dollars CAD to enhanced border enforcement capacity over the next five years, signaling that companies cannot put their sustainability programs on the back burner without repercussions.

For a full list of reporting requirements, visit the Government of Canada’s website.

Insights From Assent’s 2025 Article

We’ve already seen companies being questioned by Canadian authorities and receiving inquiries at the Canadian border. In some cases, this has snowballed into additional requests for information to clear customs. Goods can be detained because importers lack demonstrable labor due diligence.

If your business is in scope and manufactures, distributes, or imports goods on the Canadian market, this is not just a regulatory checkbox. It’s a test of whether your supply chain meets today’s global standards, and tomorrow’s even tougher expectations.

Here’s what we learned in 2025 that is still relevant today:

Forced Labor Crackdown: The Era of Leniency Is Over

The first reporting cycle under Bill S-211 gave companies some breathing room. The government, recognizing this was new ground, focused more on benchmarking than penalizing. But all signs indicate that won’t be the case moving forward.

Canadian regulators are signaling a shift from education to enforcement. Regulatory requirements are tighter, and that means risks are higher:

• Penalties of up to $250,000 CAD for non-compliance or false statements are now more likely to be applied 
• Corporate officers, directors, and agents may also face personal liability 
• Human rights organizations and journalists are watching closely; public reporting opens companies up to reputational risk in addition to financial and legal consequences

Manufacturers are especially under the microscope for risks of child labor in the supply chain. According to Public Safety Canada’s first annual report, 38.3% of reporting entities were from the manufacturing sector — the largest share of any industry. 

As we’ve seen with other forced labor due diligence laws, there’s an uptick in scrutiny on shipments entering the country. Industry has yet to see if Canadian officials will go all in or implement lighter actions like putting companies on notice.

In 2024, Public Safety Canada released guidance for reporters clarifying a few points for 2025. It states that the Supply Chains Act does not cover companies producing only intangible goods, like software and insurance services. It also provides tips for avoiding common reporting errors, based on the challenges identified in the first year of human rights due diligence reporting. Assent recommends that all in-scope manufacturers review this guidance document for details on what to put in their report and advice on formatting. 

Because the 2025 report covers progress made over the past year, this report is where manufacturers will be expected to show measurable improvements in their human rights supply chain due diligence program. With 2024 reports serving as a baseline, it will be very evident which companies took real action to combat forced labor risks and which treated this new regulation like just another compliance checkbox. 

Part of a Global Trend in Supply Chain Human Rights

While S-211 is rooted in Canadian law, it’s aligned with a global movement toward supply chain transparency and sustainability. It’s a potential precursor to more stringent regulations like the EU Forced Labour Regulation. 

The Government of Canada has also recognized that Bill S2-11 overlaps with other global supply chain human rights reporting requirements, such as the UK Modern Slavery Act of 2015. Companies in scope of Canadian forced labor reporting plus at least one other supply chain sustainability regulation are allowed to submit a single report that fully covers the requirements of both (or more). 

Smart manufacturers will focus less on meeting the specific requirements of each supply chain sustainability regulation they’re in scope of, and more on creating a comprehensive supply chain sustainability management program that provides the foundation for proactive human rights management. 

How to Strengthen Your Program 

With the 2025 deadline fast approaching, now is the time to take action and move beyond checkbox compliance. The more you put into your program now, the better prepared you’ll be for the next wave of global sustainability requirements. So think of Bill S-211 as a strategic opportunity rather than just another hurdle in your reporting calendar. 

1. Codify your human rights policies. Add supplier requirements around labor practices, trafficking, and bribery and corruption into your code of conduct and have suppliers sign on.
2. Engage your suppliers for declarations on forced labor, but also dig deeper into risk factors like working conditions and recruitment practices.
3. Conduct indirect supplier screening on beneficial ownership, corporate relationships, and media mentions. Often, human rights risks can’t be detected by supplier self-declarations alone. 
4. Train your internal teams: From procurement to compliance, your employees need to understand what forced labor looks like and how to spot red flags. This is not only a best practice, it’s a requirement under Bill S-211.
5. Automate supplier engagement: Collecting forced and child labor data is difficult, and most manufacturers don’t have a dedicated professional to handle these processes. Assent’s platform automates supplier outreach and data rollup, making it easier to see your progress and current risks.

The Countdown Is On: Get Started With Assent

The first public report under S-211 offered a revealing snapshot of where Canadian companies stand:

• 38.2% of all filers acknowledged risks of forced or child labor in their supply chains
• 22.4% had not yet begun risk identification activities

This shows that many manufacturers are still in the early stages of supply chain sustainability management, and the risk of non-compliance is tangible. 

It’s not easy for manufacturers with complex supply chains to get a robust program up and running without help. Assent’s forced labor solution can help kickstart due diligence with automated surveys, supplier education, a reporting dashboard, and AI-enhanced supplier screening tools. And our dashboards and audit trails can provide traceable proof of due diligence to help meet the reporting requirements of Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act.

Don’t wait until you get pulled over to have proof of due diligence. Put a process in place today, with strong supply chain engagement, to ensure you’re not connected to high-risk entities and that you have proof of due diligence readily available if a challenge arises. If you don’t have a system in place, implementing Assent’s Forced Labor solution is a great first step to show concrete measures to remediate human rights risks. Talk to us to get started.