Complying With Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act – Updates from Public Safety Canada’s Winter 2026 Bulletin

Yesterday afternoon, Public Safety Canada published its Winter 2026 Supply Chains Act Bulletin. We discuss the Bulletin in this post. 

This cycle’s reports under the Supply Chains Act are due May 31, 2026. In late December, in preparation for reporting, Public Safety Canada opened up the reporting portal, which includes the updated 2026 online questionnaire. It also updated its guidance for reporting entities. In an earlier post, we discuss the updates to the guidance and questionnaire.

Optional Reporting Template Reminder

In the Winter Bulletin, Public Safety Canada reminded reporting entities about the optional international reporting template jointly developed by Canada, the UK and Australia. 

The optional template was published last July as a guide for responding to supply chain transparency requirements in the three countries. It is intended to reduce the administrative burden for organizations subject to supply chain reporting requirements in these jurisdictions by supporting the development of a single report for all three jurisdictions. The template also was designed as a guide for reporting entities to implement good practices and continually improve when preparing their statements and/or annual reports. 

The template is available here.

An Improved Process for Completing This Year’s Questionnaire

In addition to annually publishing a transparency report, reporting entities must submit a questionnaire to Public Safety Canada.

Public Safety Canada indicated in the Winter Bulletin that it will be distributing unique questionnaire links to each entity that previously reported under the Supply Chains Act. The link will enable reporters to return to a questionnaire in progress and to share the link or access the survey from different computers. Among other things, this will enable better internal collaboration by teams.

Reporting entities’ unique links will come via email shortly. The link will be sent to the contact information on file. Reporting entities will therefore want to check that information is current.

Companies that have not previously reported under the Act can obtain a link via email: [email protected].

Reporting entities also can continue to access the Supply Chains Act questionnaire on Public Safety Canada’s report submission webpage.

Reporting Tips

Finally, the Winter Bulletin offers four tips to improve reports: 

• Include a signed and dated attestation. Attestation is a mandatory requirement under the Supply Chains Act.

• Only provide information pertaining to the Act’s transparency requirements, i.e., do not include other documents in appendices, such as employee contracts or supplier codes of conduct.

• Do not include employee emails or other identifiable information. In the December update to its guidance, Public Safety Canada indicated that entities must not provide personal information in the questionnaire or annual report, since submissions including personal information cannot be published in the library catalogue and will need to be resubmitted.

• Remove any approval audit trails at the end of the report.

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