Canada’s Supply Chain Act Is Now in Force: Is Your Business Ready?

Author: François Duquette

As of January 2024, in the effort to implement measures to increase accountability across global supply chains, Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”) is in force. If your business is expanding, generating significant revenue, or managing substantial assets, it’s time to understand your new responsibilities under the Act.

Could This Apply to Your Business?

The Act applies to some private-sector entities involved in producing, selling, distributing or importing goods into Canada, meeting at least two of the following criteria:

• $20 million or more in assets;
• $40 million or more in revenue;
• 250 or more employees.

What’s Required?

Entities subject to the Act must file an annual report by May 31^st outlining the steps they are taking to identify, prevent, and reduce risks of forced or child labour in their supply chains.

What Should the Report Include?

Your report must clearly cover the following areas:

• Business structure, activities, and supply chain: Report on your legal structure, main activities, and where your goods originate from, with a focus on transparency.
• Policies and due diligence: Explain your internal policies and processes for identifying and managing labour risks.
• Risk management: Explain how you assess and respond to forced or child labour risks in your operations and supply chains, without needing to prove you are risk-free.
• Remediation measures: Describe actions taken to remedy any use of forced or child labour and support vulnerable families otherwise affected.
• Employee training: Indicate who is trained, how often and what the training covers.
• Effectiveness assessment: Detail how you evaluate your prevention efforts, such as audits or progress tracking.

Larger Implications for Your Business

Compliance isn’t just about reporting — it touches core business operations. You may need to:

• Map out your supply chain
• Gather information on suppliers’ labour practices
• Update policies and contracts
• Provide regular employee training
• Maintain clear records for annual reporting

These efforts influence supplier selection, contract terms, procurement, and long-term risk management. Regular reviews will help ensure alignment with ethical and legal standards.

Why It Matters

Non-compliance can lead to financial penalties —and reputational risk. More broadly, the Act reflects growing expectations around corporate responsibility and ethical business practices. Demonstrating compliance shows your business is serious about responsible practices.

Need Help? Start Here

Understanding whether the Act applies and how to respond can be complex. If you’re unsure whether your business is affected, or if you require practical guidance and support, our team can help. We’ll guide you in assessing risk, developing reporting protocols, and aligning your practices with the new requirements.