Supply Chains Act reporting: Canada launches 2026 reporting cycle and updates guidance

Public Safety Canada has updated its guidance for businesses subject to the Supply Chains Act and launched the online portal for the 2026 reporting cycle, with reports due by May 31, 2026.

Updated guidance

The updated guidance does not change the substantive reporting requirements, but does provide clarification on reporting very minor dealings, the attestation requirements, using the international reporting template, and the exclusion of personal information. Reports prepared using the previous version of the guidance will continue to be accepted.

• Very minor dealings. The guidance clarifies how to assess “very minor dealings.” There is no threshold for the minimum value of goods that an entity must produce or import to be subject to the reporting obligation. "Very minor dealings", should be understood in accordance with generally accepted principles of de minimis and evaluated within the context of each entity's overall operations. The updated guidance explains that importing or producing activities that are incidental, low-volume, or not central to an entity’s core business may qualify as very minor dealings. The guidance underscores that entities should apply judgment informed by the scale, frequency, and relevance of the activity, as there is no bright-line test.


• Attestation and signatures. The updated guidance reinforced attestation and signature requirements. Submissions lacking an attestation and signature will not be published in the Public Safety Canada catalogue. The guidance confirms that wet-ink, typed, or digitally inserted signatures by a member of the governing body are acceptable, and that leaving a blank signature block is not sufficient.


• International reporting template. In July 2025, the Canadian, Australian, and United Kingdom governments jointly released an optional international reporting template and guidance to assist entities preparing a single report to satisfy certain requirements across all three jurisdictions. The updated guidance now references the international reporting template, which incorporates examples and suggested disclosures to support good practices and continual improvement.


• Protection of personal information. The updated guidance reiterates that reports must not include personal information. Reports containing personal information cannot be published and must be corrected and resubmitted.

Transparency update

Public Safety Canada has compiled a list of entities and government institutions with reports in its public catalogue as of December 4, 2025, with quarterly updates to follow.

It has also provided greater transparency on its pre-publication review process, noting that all reports undergo a high-level quality assurance review and that publication may lag submissions. Only reports that meet minimum standards and pass quality assurance are published; those that do not are excluded. Late submissions are accepted for up to one year after the deadline and are marked accordingly.