On December 18, 2025, Public Safety Canada (“PSC”) published updates on its guidance on the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”). These updates provide clarifications on who must report, and how reports should be prepared and filed. These clarifications are especially important for non-governmental entities planning ahead for the May 31st annual reporting deadline.

This post highlights five practical takeaways for in‑scope entities.

1. “Minor dealings”: what does it mean?

The Act applies only to “entities” that are:

  • producing goods in Canada or elsewhere;
  • importing goods produced outside Canada; or
  • controlling another “entity” that produces or imports goods.

For a definition of what constitutes an “entity” under the Act, please refer to our previous published article.  The Act does not prescribe a threshold for the minimum value of goods that an “entity” must produce or import to be subject to its reporting obligation.

However, earlier PSC guidance has indicated that the terms as they are use in the Act should be understood as excluding “very minor dealings” without providing a real explanation of what this expression meant, except to mention that it had to be interpreted in accordance with generally accepted principles of de minimis, and evaluated within the context of each entity’s overall operations.

Understanding that entities subject to the Act needed better guidance, PSC has now included some thresholds in its guidance to clarify the concept of “minor dealings.”  Pursuant to the latest PSC guidance, an entity’s importing or producing activities will be considered minor dealings if such activities are incidental, low-volume, or not central to its core business. PSC reminds entities that they should apply judgment based on the scale, frequency, and relevance of the activity within their broader operations.

2. How PSC reviews and publishes reports

PSC has also clarified its internal review process. According to the latest guidance, reports that will be published on the PSC public catalogue on its website must be:

  • submitted in a PDF format; and
  • filed through the online questionnaire.

A high-level quality assurance review must also be performed by PSC before reports will be published.

A key point that continues to challenge reporting entities is that completing the questionnaire alone is not enough. Both the questionnaire and the PDF report must be completed and submitted together. Finally, PSC does not commit to any specific timelines for publication. Reports are reviewed and posted on an ongoing basis.

3. Attestation is mandatory, and formalities matter

PSC reminds entities that the attestation is not optional. Report submitted without an attestation statement and signature will not be published on PSC’s online public catalogue.

Boards and other governing bodies should be given sufficient time before the May 31st deadline to review and approve the report. The filed report should also contain proper signature from a member of the governing body approving the report, and the signature can be in the form of a wet, typed, or digitally inserted signature. Leaving a blank space in the signature block will not constitute a proper signature.

4. Do not include personal information in your report

To protect privacy, PSC expects entities to avoid including personal information of employees or individuals connected to organizations discussed in the report. Addresses, phone numbers, e‑mail addresses, IP addresses, Social Insurance Numbers, or other types of personal information that could allow a person to be identified should never be used in a report under the Act. Submissions containing personal information will not be accepted by PSC and will result in a rejection of the report and non-publication in the PSC online public catalogue.

5. New international modern slavery reporting template for multijurisdictional filers

For organizations that report in multiple jurisdictions, PSC has now endorsed an optional international reporting template developed jointly by the governments of Canada, the United Kingdom, and Australia. The template is intended to help entities streamline disclosures and align modern slavery reporting across the regime adopted in each jurisdiction while still respecting local administrative requirements.

Entities reporting under the Act may use this optional template as a guide to implement good supply chain transparency practices. As part of this latest update guidance, PSC has added examples to help entities meet legislative requirements and improve their reporting. The template and examples can be found on the PSC website.  We note that at the time of writing this newsletter, the template available was still dated July 2025 and PSC had not responded to our query whether an updated version of the template would be posted on its website.

How reporting entities can prepare now

In light of this latest update to PSC’s guidance, in‑scope entities may wish to:

  • Reassess whether any importing or producing activities could be characterized as “minor dealings,” and document the rationale for arriving at such conclusion.
  • Map an internal timeline that allows for data collection, drafting, governing‑body approval, and signature well before May 31.
  • Review draft reports to check for personal information and replace it with anonymized, aggregate descriptions where appropriate.
  • If your organization is a subject to the Act as well as modern slavery legislation in the United Kingdom or Australia, it should consider using the multijurisdictional template developed by PSC as a global baseline, adapting it to reflect the organization’s specific risk profile and governance structures.

If you would like clarification on any of the above or would like assistance with compliance under the Act, please don’t hesitate to reach out to Miller Thomson’s ESG and Carbon Finance Group.