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Public Safety Canada has published the 2025 Annual Report to Parliament on the Fighting Against Forced Labour and Child Labour in Supply Chains Act, colloquially referred to as Canada's modern slavery act.
The Annual Report summarizes the compliance activities taken by reporting entities. It is therefore useful for benchmarking modern slavery compliance against other companies' actions. In this post, we discuss some of the key datapoints from the Annual Report.
The Annual Report was developed using data collected through the online questionnaire companies are required to submit in connection with their annual reporting under the Act. Some questions in the online questionnaire allowed for multiple responses; therefore, in some cases the total responses indicated exceed the number of respondents.
Reporting Entities
Public Safety Canada received 4,178 private sector reports by the May 31, 2025 reporting deadline. Forty percent of these were joint reports (i.e., covering multiple in-scope entities). This was significantly less than the 5,650 submitted on time in 2024. The difference is likely in part due to scoping guidance published after the first reporting period.
There were an additional 863 late submissions, compared to 508 last year. The statistics that follow only include the timely reports.
More than 20% of reports were submitted on behalf of entities based outside Canada, with 642 from the United States and 216 from other countries. This compares to 1,020 reports for foreign- based companies in 2024, including 764 by US entities.
A total of 708 respondents reported being subject to other legislation. Of these, 499 were subject to the UK Modern Slavery Act, 433 to the California Transparency in Supply Chains Act, 280 to the Australian Modern Slavery Act and 208 to other unspecified legislation.
Activities Carrying a Risk of Forced and Child Labor
In 2025, 44% of entities indicated that they had identified parts of their activities and supply chains that carry a risk of forced or child labor, while 39% had started the process of identifying risks but still had gaps in their assessments. In descending order of frequency, the most commonly identified risk factor was the raw materials or commodities used in supply chains (34%). This was followed by (1) the sector or industry of operation, (2) tier one suppliers and (3) the locations of activities, operations or factories, each at 30%.
In the open comments, some respondents noted that their supply chains had unknown levels of risk due to a lack of visibility into indirect suppliers and subcontractors. Some respondents indicated heightened risks of forced and child labor when temporary or migrant workers are employed.
Assessment and Management of Forced and Child Labor Risks
Organizations that identified forced or child labor risks were asked in the questionnaire to describe the steps they took to assess and address the risks. Respondents also had to describe any preventative measures they have in place, including policies, due diligence processes, training and methods for assessing the effectiveness of the measures.
In order from the most to least frequent, embedding responsible business conduct into policies and management systems was reported by 97% of respondents, followed by identifying and assessing potential and actual adverse impacts in operations, supply chains and business relationships (50%), ceasing, preventing or mitigating those impacts (34%), tracking implementation and results (29%), providing for or cooperating in remediation when appropriate (26%) and communicating how impacts are addressed (23%).
In addition:
- 84% of entities reported having policies and due diligence processes in place related to forced and/or child labor. In the open comments, some entities reported that they require vendors and partners to comply with related policies and standards, including in contracts. Some entities also mentioned the use of working groups, committees, stakeholder engagements and engagements with unions to address forced and child labor issues.
- 62% of entities provide training to employees. It is mandatory for all or some employees at 93% of respondents.
- 51% have policies and procedures in place to assess the effectiveness of their actions. The most common steps taken are (1) regular reviews or audits of policies and procedures (76%), (2) tracking KPIs such as employee awareness, cases reported and addressed through grievance mechanisms and contracts with anti-forced and -child labor clauses (37%), (3) working with suppliers to measure the effectiveness of actions (37%) and (4) partnering with an external organization to conduct an independent review or audit (24%).
Efforts to Remediate Forced and Child Labor
Most respondents (91%) that submitted a report to Public Safety Canada indicated that they had not identified any forced or child labor in their activities and supply chains.
Five percent of organizations that submitted a report indicated they took measures to remediate instances of forced or child labor:
- 87% identified actions to prevent forced or child labor and associated harms from reoccurring;
- 65% identified grievance mechanisms;
- 16% paid compensation to victims of forced or child labor and/or their families;
- 11% took actions to support victims of forced or child labor and/or their families, such as workforce reintegration and psychosocial support; and
- 0.5% made formal apologies.
If applicable, the Act requires companies to report on any measures taken to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced or child labor. When asked about this in the questionnaire, 95% of respondents indicated the question was not applicable. One percent indicated they had taken remediation measures and will continue to identify and address any gaps, while the remainder had not taken any remediation measures.
Enforcement
The Annual Report indicates that, in the second year of reporting, Public Safety Canada prioritized raising awareness of the reporting requirements to encourage meaningful action. Accordingly, there were no orders issued to ensure compliance with the Act or fines levied.
To View the Annual Report
The Annual Report is available here. It contains additional data points not included in this post.
Interested in Additional 2024 Reporting Statistics?
If so, see this Ropes & Gray post discussing last year's Annual Report.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
