In preparation for 2026 reporting under Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act, Public Safety Canada has opened up the reporting portal, which includes an updated online questionnaire. Public Safety Canada also has updated its guidance for reporting entities. This cycle’s reports are due May 31, 2026. In this post, we discuss the updates to the guidance and questionnaire.
Updated Guidance
The substance of the guidance largely remains the same. However, there are some updates that expand upon and/or clarify the prior guidance. The items addressed below were noted by Public Safety Canada in its announcement of the updated guidance.
Public Safety Canada has indicated that reports prepared using previous versions of the guidance will continue to be accepted.
Prior guidance is discussed in our posts here and here. The Act is further discussed here.
Very Minor Dealings
The guidance indicates that, while there is no prescribed threshold for the minimum value of goods that an entity must produce or import to be subject to reporting, the Act should be understood as excluding "very minor dealings." This phrase is to be interpreted in accordance with generally accepted principles of de minimis and evaluated within the context of each entity's overall operations.
In the updated guidance, “overall operations” replaces “business.” Additional parameters for determining whether dealings are very minor also have been provided, although judgment is still required since the guidance does not contain a brightline test. The updated guidance indicates that, if an entity's importing or producing activities are incidental, low-volume or not central to its core business, they may qualify as very minor dealings. According to the updated guidance, entities should apply judgment based on the scale, frequency and relevance of the activity within their broader operations.
International Reporting Template; Disclosure Topics
In July, the Canadian, Australian and UK governments jointly released an optional template to serve as a guide for responding to the largely similar transparency requirements across the three jurisdictions. The updated Public Safety Canada guidance now refers to the template, citing it as a guide for implementing good practices and continually improving when preparing annual forced and child labor transparency reports.
The updated guidance also includes additional suggested disclosures and programmatic initiatives from the international reporting template for some of the mandatory disclosure topics.
Attestation
Reports require attestation. Reports submitted without an attestation and signature will not be published in Public Safety Canada's catalogue.
The updated guidance clarifies the acceptable signature formats, noting that a proper signature includes a wet, typed or digitally inserted signature of a member of the governing body. Leaving a blank space in the signature block does not constitute a signature.
Personal Information
The updated guidance stresses that entities are not to provide personal information in reports. Submissions including personal information cannot be published in the Public Safety Canada catalogue and will need to be resubmitted.
The updated guidance indicates that, among other things, personal information can include addresses, phone numbers, e-mail addresses, IP addresses, Social Insurance Numbers and other personal identifiers.
The 2026 Questionnaire
The updates to the questionnaire are largely stylistic. The most significant addition is the inclusion alongside some questions of notes to assist users in completing the questionnaire.
The questionnaire’s questions can be previewed in advance here.
The questionnaire must be completed to submit the annual report, which is uploaded via the questionnaire.
