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This article was prepared with the assistance of summer student Jeana Myers.
As discussed in our previous insights on Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act, including our overview of the initial reporting guidance, Public Safety Canada has issued guidance for entities to provide clarification and direction on reporting under the Act. On December 18, 2025, Public Safety Canada released updates to the guidance to further clarify the reporting requirements under the Act.
Key updates
1. Clarification of reporting exemptions
Reporting under the Act is required for entities whose main business activities include producing goods, importing goods produced outside Canada and/or controlling another entity that produces or imports goods. The guidance provides additional direction regarding the types of entities that may fall outside the reporting requirement.
The guidance clarifies that entities whose importing or producing activities are “de minimis” – meaning producing or importing activities that are incidental, low-volume or not central to the entity’s core business – may fall outside the reporting requirement. Entities should assess the scale, frequency and relevance of these activities within their broader operations, as no prescribed quantitative threshold applies.
Public Safety Canada has also clarified that entities engaged solely in distribution and sales are not required to report under the Act. However, the updated guidance removes prior language expressly confirming that Public Safety Canada would not pursue enforcement action in these circumstances.
2. Acceptable forms of signature
An attestation, in the form of a signature confirming approval by the entity’s governing body, is a required component of the report. The attestation must be provided by an individual with the authority to bind the entity.
The guidance clarifies acceptable signature formats, including wet (ink), typed and digitally inserted signatures. A blank signature field will not be accepted. Entities should ensure that an acceptable signature format is included to avoid rejection and resubmission.
3. Personal information exclusions
Public Safety Canada discourages the inclusion of personally identifying information in the report or questionnaire. This includes names, addresses, phone numbers, email addresses, internet protocol (IP) addresses, Social Insurance Numbers (SINs) and other personal identifiers.
Reports containing personal information will not be published and must be resubmitted. To avoid delays, entities should ensure that all such information is removed prior to submission.
The questionnaire requires the reporting individual’s name, title and email address. However, this information is collected for internal purposes only and does not affect publication.
4. Clarification of the review process
Following submission of a report and questionnaire, Public Safety Canada conducts a high-level quality assurance review. This review is administrative in nature and does not assess the substantive content of the report. Instead, it focuses on compliance with requirements relating to formatting, attestation and the exclusion of personal information.
Where deficiencies are identified, entities will be required to resubmit their report prior to publication. Once this review is completed, the report will be published on the Public Safety Canada website.
Ensuring compliance with the prescribed reporting structure and content requirements will help avoid delays and resubmissions.
5. International reporting template
Entities operating in multiple jurisdictions may be subject to reporting requirements in those jurisdictions, including the United Kingdom and Australia. Canada, the United Kingdom and Australia have developed an international reporting template to assist with multi-jurisdictional reporting.
Entities using this template must still ensure compliance with the specific legal requirements applicable in each jurisdiction by reviewing the relevant legislation and guidance prior to submission.
Key takeaways
Although Public Safety Canada has indicated that it will continue to accept reports prepared based on earlier versions of the Guidance, entities preparing for the May 31, 2026, reporting deadline should review the Act and the updated guidance to ensure compliance with current expectations.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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