Canada’s S-211 reporting deadline is May 31, 2024. Here’s what you need to know

In preparation for the May 31st reporting deadline for Canada’s S-211 Fighting Against Forced Labour and Child Labour in Supply Chains Act, the Government of Canada released guidance on preparing a report, the application of the Act and the report contents.

Companies are considered in scope for Canada’s S-211 if they meet the following criteria:

a) is listed on a stock exchange in Canada; or

b) has a place of business in Canada, does business in Canada or has assets in Canada and that, based on its consolidated financial statements, meets at least two of the following conditions for at least one of its two most recent financial years:

• it has at least $20 million CAD in assets,

• it has generated at least $40 million CAD in revenue, and

• it employs and average of at least 250 employees

In-scope companies must develop an annual report that meets all of the requirements of the Act, and submit said report by the May 31 deadline. Once a report is complete, it must receive approval from “the appropriate governing body or bodies who have the legal authority to bind the entity or entities,” and the signed attestation must be included in the final PDF version of the submitted report.

Companies must also complete an online questionnaire (found here), which includes a series of open and closed-ended questions that address each of the requirements of the Act. The answers submitted via the online questionnaire must be consistent with the contents of the report.

Canada S-211 Annual report requirements:

The report must include the following components:

• Reporting entity’s legal name

• Financial reporting year

• Identification of a revised report

• Business number(s), if applicable

• Identification of a joint report

• Identification of reporting obligations in other jurisdictions

• Entity categorization according to the Act

• Sector/industry

• Location

Entities must address each of the requirements included in section 11 of the Act in their annual report. This includes:

• A description of the steps taken to prevent and reduce risks of forced labor and child labor, as per subsection 11(1)

• Supplementary information addressing each of the seven requirements in subsection 11(3), which are listed below.

a) Its structure, activities and supply chains

b) Its policies and its due diligence processes in relation to forced labor and child labor

c) The parts of its business and supply chains that carry a risk of forced labor or child labor being used and the steps it has taken to assess and manage that risk

d) Any measures taken to remediate any forced labor or child labor

e) 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 labor or child labor in its activities and supply chains

f) The training provided to employees on forced labor and child labor

g) How the entity assesses its effectiveness in ensuring that forced labor and child labor are not being used in its business and supply chains

More information on the report components can be found here. To learn how Sourcemap can help you meet the reporting requirements under Canada’s S-211 Act, reach out to our team of experts.