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FORCED LABOUR REPORTING MADE EASIER

CANADA ADOPTS NEW GLOBAL TEMPLATE FOR ANNUAL FORCED LABOUR REPORTING REQUIREMENTS

Canada has in place now, for the last two years, a comprehensive set of legal reporting requirements for companies with supply chains that may be susceptible to products made through forced labour or child labour.

We have previously written on the reporting requirements and the reporting entity conditions here and here.

This report reviews the new global template that Canada has adopted to make this reporting process easier.

The New Global Template

In July 2025, Canada joined the United Kingdom and Australia in adopting a joint global reporting template for forced labour and child labour disclosures.

The goal of the new global template is to simplify reporting for organizations operating across multiple jurisdictions, as organizations previously had to prepare separate reports in each country to meet different disclosure requirements.

The template brings together the legislative reporting requirements of all three countries under seven core categories of disclosure:

1. Structure and Supply Chains: A description of the organization's structure, operations, activities, and supply chains;
2. Policies: A description of the organization's policies in relation to forced labour and child labour;
3. Risk Management: A description of the organization’s risk management processes to assess risks of forced labour and child labour;
4. Due Diligence: A description of the organization's due diligence processes and any measures taken to remediate any instances of forced labour and child labour;
5. Training: A description of the training provided to employees on forced labour and child labour;
6. Effectiveness of Preventive Actions: A description of the effectiveness of the actions it has taken to prevent and respond to forced labour and child labour; and
7. Other Relevant Information.

Notably, the template sorts each reporting category into two levels.  Level 1 sets out the information that organizations should disclose, while Level 2 identifies optional information, allowing reporting entities discretion over whether, and to what extent, to include it.  That said, the Canadian government expects reporting organizations to take a “continuous improvement” approach to compliance, progressively working toward Level 2 reporting where possible.

What Does This Mean for Businesses?

For Canadian reporting entities, the new template helps streamline compliance and makes the reporting process easier to manage.  However, because the template combines requirements from three countries, some disclosures may exceed the minimum requirements under Canadian law.  Businesses should therefore use caution when preparing their reports.

Takeaways

Canada employs detailed reporting requirements for businesses with supply chains that could be susceptible to forced and child labour concerns. A new global template for reporting will make things easier for international businesses facing similar reporting requirements in other jurisdictions.

For help with the Forced Labour Reporting, please click here.

Download a PDF copy of this Blog here.