skip to content
Contact
Home
Search

Article

Canada’s Supply Chains Act (Bill S-211)

Requirements and considerations for 2026.

Updated: May 13, 2026

At a glance

  • May 31, 2026, is the deadline for Canada’s Supply Chains Act (Bill S-211) annual reporting
  • The Act applies to entities producing or importing goods
  • Mandatory disclosures on supply chain risks and due diligence
  • Increased focus on risk-based supply chain management
  • Penalties, enforcement, and reputational risks for non-compliance

Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act (Bill S-211), which came into force on Jan. 1, 2024, establishes annual reporting requirements for organizations to disclose how they assess and address risks of forced labour and child labour in their supply chains.

As organizations move into this third reporting cycle, the focus shifts from initial compliance to how supply chain risks are identified, prioritized, and managed in practice.

In this article, we outline the scope of the Act, reporting requirements, and key considerations to support a more structured approach to compliance.

Who the Act applies to

The Act applies to entities, including corporations, trusts, partnerships, and other unincorporated organizations, that:

  • Produce goods in Canada or elsewhere
  • Import goods into Canada
  • Control an entity engaged in either of the above activities

Entities must also meet one of the following thresholds:

  • Be listed on a Canadian stock exchange, or;
  • Have a place of business, assets, or operations in Canada and meet at least two of the following criteria (based on consolidated financial statements for at least one of the two most recent financial years):
    • At least $20 million in assets
    • At least $40 million in revenue
    • An average of at least 250 employees

What organizations are required to do

In-scope entities are required to prepare and submit an annual supply chain risk report on or before May 31, 2026.

The report must describe the steps taken during the previous financial year to prevent and reduce the risk of forced labour and child labour in operations and supply chains.

Organizations are also required to:

  • Complete the associated online questionnaire administered by Public Safety Canada.
  • Publish the report on their website in a prominent and accessible location.

What must be disclosed

The annual report must include information on:

Business structure, activities, and supply chains
Policies and due diligence processes related to forced labour and child labour
Areas of the business and supply chain that carry risk, and how those risks are assessed and managed
Measures taken to remediate forced labour or child labour
Measures taken to mitigate impacts on vulnerable families
Training provided to employees on forced labour and child labour risks
How the organization assesses the effectiveness of its approach

From disclosure to risk management

While the Act is structured as a reporting requirement, it is increasingly used by regulators, customers, and other stakeholders to assess how organizations manage supply chain risk in practice.

A common challenge is moving from qualitative disclosure to a defensible, risk-based approach.

This typically begins with supply chain mapping, which allows organizations to:

  • Identify where exposure is concentrated across suppliers, products, and jurisdictions.
  • Establish a clear risk hierarchy to prioritize due diligence.
  • Align procurement, compliance, and finance functions around a consistent view of risk.

This approach supports regulatory expectations while also informing broader business decisions related to cost, trade exposure, and supply chain resilience.

Risks of non-compliance

Failure to meet the requirements of the Act may result in:

  • Reputational risk, including increased scrutiny from customers, investors, and the public.
  • Regulatory enforcement, including inspections and compliance verification activities.
  • Financial penalties of up to $250,000.

How can BDO help?

BDO supports organizations in establishing practical and defensible approaches to supply chain risk management.

Our services include:

  1. Supply chain mapping and risk assessment
  2. Development of risk-based due diligence frameworks
  3. Preparation of annual supply chain risk reports
  4. Design and delivery of targeted training programs
  5. Integration with trade, customs, and procurement processes

We work with clients to align regulatory requirements with operational realities, helping organizations manage risk, support compliance, and make more informed supply chain decisions.

Contact our leaders

For more information on how your organization can meet the requirements of Bill S-211 and strengthen its approach to supply chain risk management.

Simon Hutton
National Sustainability Leader
Contact View bio
Charmaine Goddeeris
Director, Indirect Tax
Contact View bio

The information in this publication is current as of May 7, 2026.

This publication has been carefully prepared, but it has been written in general terms and should be seen as broad guidance only. The publication cannot be relied upon to cover specific situations and you should not act, or refrain from acting, upon the information contained therein without obtaining specific professional advice. Please contact BDO Canada LLP to discuss these matters in the context of your particular circumstances. BDO Canada LLP, its partners, employees and agents do not accept or assume any liability or duty of care for any loss arising from any action taken or not taken by anyone in reliance on the information in this publication or for any decision based on it.