On January 1, 2024, the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act) officially came into force. On March 7, 2024, the Minister of Public Safety and Emergency Preparedness (the Minister) published updated guidance (the Updated Guidance) to revise the original guidance (the Guidance) issued in December 2023.
Entities with a reporting obligation must file their inaugural report with the Minister in the manner specified in the guidance by May 31, 2024, and then subsequently by May 31 in each year that follows. The same requirement applies to federal government institutions as well. Corporations that are federally incorporated (including corporations incorporated pursuant to the Canada Business Corporations Act) must provide the report or revised report to each shareholder, along with its annual financial statements, which may effectively accelerate the May 31 deadline to such an earlier date that such entity provides its annual financial statements to shareholders.
Please refer to our bulletin from September 2023 for specific recommendations on how you can prepare your entity to comply with the Act. For more information on the Guidance, please refer to our January 2024 bulletin. In addition, organizations may want to familiarize themselves with the questionnaire, which is available on the Minister’s website, and the report submission process in advance of the filing deadline.