Key takeaways from Public Safety Canada’s 2025 report to Parliament on Canada’s Supply Chains Act

Public Safety Canada has tabled its second annual report to Parliament on the implementation of the Fighting Against Forced Labour in Supply Chains Act (Supply Chains Act). The report analyzes 4,313 reports submitted over the course of the reporting period ended on May 31, 2025, and provides a snapshot of how market practices are evolving and how the regulator is administering the reporting regime.

What the 2025 data shows about market practice

The 2025 report indicates businesses are moving towards supply chain transparency and compliance maturity relative to year one. Across reporting entities:

• The overwhelming majority are actively mapping risk: 83 percent reported that they had either identified risks of modern slavery in their operations or supply chains, or begun a risk assessment process, up from 77 percent in 2024.


• Modern slavery policies and due diligence processes are the norm: 84 percent of all entities reported having policies and due diligence processes in place related to forced labour and child labour, up from 71 percent last year.


• Training efforts have expanded significantly: 61 percent of entities reported providing employee training on forced labour and/or child labour, up from 44 percent last year.


• Measuring effectiveness is gaining traction: 51 percent reported having practices in place to assess their effectiveness in preventing forced labour and child labour, up from 43 percent last year.


• Remediation remains rare: five percent of organizations (includes 4,178 reporting entities and 135 government institutions) indicated that they have taken measures to remediate instances of forced labour or child labour, while 91 percent of organizations said remediation questions were not applicable because they had not identified any instances of modern slavery in their activities or supply chains.

Enforcement and guidance

For a second consecutive year, Public Safety Canada did not take any formal enforcement actions under the Supply Chains Act. The regulator’s 2025 report emphasizes continued focus on awareness and transparency, but reporting entities should expect increased scrutiny in the next reporting cycle.

To support compliance, Public Safety Canada issued updated guidance in November 2024, clarifying the scope of the Supply Chains Act’s application. These clarifications likely contributed to the significant drop in reports received by Public Safety Canada (4,313 reports were received on or before May 31, 2025, as compared to 5,795 last year).

In addition, in July 2025, the Australian, Canadian and United Kingdom governments jointly released an optional international reporting template – International Reporting on Modern Slavery, Forced Labour and Child Labour – to help streamline cross-jurisdictional reporting for multinational filers responding to supply chain transparency requirements. While this is a useful resource, multinationals still face the practical challenges of coordinating staggered filing deadlines and divergent reporting and due diligence requirements across jurisdictions.

Practical implications for reporting entities