[Home](/)/[Resources](/resources)/Canada Forced Labour Act (S-211) CanadaSupply Chain # Canada Fighting Against Forced Labour Act: Annual Report Obligations for Hardware Companies Bill S-211 puts board-level accountability behind supply chain transparency in Canada. For hardware companies importing electronics, the obligation is clear — and the May 31 deadline is firm. Here is what you need to disclose and how to get it filed. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Fcanada-modern-slavery-supply-chain) At a glance Law S-211 / Bill S-211 (in force January 2024) Administrator Public Safety Canada Threshold Exchange-listed OR meets size criteria Annual report Filed by May 31 ## What S-211 requires and who it affects ### Who must report Entities listed on a Canadian stock exchange, or those that meet two of three size thresholds — CAD 20 million in assets, CAD 40 million in revenue, and 250 or more employees — are subject to reporting obligations if they produce, sell, distribute, import, or contract for the production of goods in Canada or for import into Canada. For hardware companies importing electronic products or components, the import activity alone can trigger the obligation regardless of where the company is headquartered. ### Annual report content The report must address eight specific areas: the entity's structure, activities, and supply chains; policies and due diligence processes related to forced and child labour; parts of the business and supply chains at risk; steps taken to assess and manage risk; remediation measures taken for forced or child labour identified; training provided to employees; how effectiveness is assessed; and any losses to workers whose forced labour has been remediated. Public Safety Canada has published guidance on expected depth for each element. ### Filing and publication Reports are filed with Public Safety Canada via the online reporting portal by May 31 each year, covering the previous calendar year. The same report must be published prominently on the entity's public website — not buried in a footnote or investor relations page. The Canadian Border Services Agency (CBSA) can use reports as a factor in import risk assessment. A report that exists only on the portal but is not publicly accessible on the company website is non-compliant. ### Board approval and attestation The annual report must be approved by the entity's board of directors (or equivalent governing body) and attested as accurate by a senior officer. This board-level sign-off requirement makes forced labour due diligence a governance obligation, not just a supply chain function. Directors who approve a materially false report face personal liability under the Act. ## How to prepare and file your annual S-211 report 01 Confirm whether your company meets the threshold for reporting. Check whether your company is listed on a Canadian stock exchange, or assess the three financial and employee size criteria against your most recent financial year. Companies meeting two of three criteria and engaged in any of the specified activities — producing, selling, distributing, importing, or contracting for production — must report. 02 Map your supply chain to identify goods produced in or imported into Canada. For hardware companies, this means tracing PCB assembly, component sourcing, sub-assembly manufacturing, and final goods — particularly where production occurs in jurisdictions identified as high-risk for forced or child labour. 03 Cross-reference supply chain locations against the Global Slavery Index (Walk Free Foundation), the US Department of Labor's List of Goods Produced by Child Labor or Forced Labor (ILAB), and ILO forced labour country indicators. Document risk assessments for each supply chain tier with identified risk. 04 Draft the annual report covering all eight mandatory elements. Public Safety Canada has published annotated guidance on what each element is expected to contain. The report should be specific to your actual supply chain and operations — generic statements about commitment to human rights without supply chain specifics do not satisfy the Act. 05 File via the Public Safety Canada reporting portal before May 31 and simultaneously publish the signed, board-approved report on your company website with a prominent and accessible link from the homepage or CSR/sustainability section. Retain the filing confirmation for your records. ## Frequently asked questions ### Which companies must file under the Canadian forced labour act? Companies must file if they are listed on a Canadian stock exchange, or if they meet at least two of three size criteria (CAD 20M assets, CAD 40M revenue, 250+ employees) AND are engaged in producing, selling, distributing, importing, or contracting for production of goods in Canada or for import into Canada. Foreign companies without a Canadian incorporation but that import goods into Canada can meet this test. Subsidiary reporting: a subsidiary that itself meets the criteria must file separately, even if its parent also files. ### What is the filing deadline and where do reports go? Reports must be filed with Public Safety Canada via the government's online reporting portal by May 31 each year, covering activities in the previous calendar year. The first reports covering the 2023 calendar year were due May 31, 2024. The same report must be published on the company's public website. Public Safety Canada publishes a list of companies that have filed — companies that should have filed but did not appear on this list face enforcement scrutiny. ### How detailed must the supply chain mapping be? The Act requires disclosure of supply chains at risk, not exhaustive mapping of every tier. In practice, companies should map to tier 2 (direct suppliers' key suppliers) for high-risk categories, and at least to tier 1 for all categories. For electronics hardware, high-risk areas typically include mineral extraction (cobalt, tungsten, tin, tantalum from DRC and surrounding region), PCB assembly in low-cost manufacturing jurisdictions, and certain plastics and packaging supply chains. The depth of mapping should be proportionate to identified risk — a company sourcing only from OECD countries with verified labour standards has a different disclosure burden than one sourcing from high-risk jurisdictions. ### How does the Canadian act compare to the UK Modern Slavery Act? Both acts require annual transparency reports on forced and child labour risks in supply chains. However, Canada's S-211 applies a lower revenue threshold than the UK act (which applies to entities with £36M annual turnover) and requires board approval and attestation of the report. Canada's act also explicitly covers child labour alongside forced labour, while the UK act focuses on modern slavery and human trafficking. The UK act has been in force since 2015 and has established enforcement precedent; Canada's act is newer (in force January 2024) and enforcement patterns are still developing. Companies operating in both markets should align their reports where possible. **Disclaimer:** Educational resource only. Regulatory requirements change and vary by product category. Consult an accredited test laboratory or qualified compliance engineer before making certification decisions. 🇨🇦 Canada roadmap for your product Every standard, document, and test that applies — free, no account required. See your free roadmap[ Want an expert to take your product through 🇨🇦 Canada compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. See compliance services](/services) Learn this properly In-depth course that teaches the full process, not just this one answer. [Start the course — $149](/courses/47-canada-ised-ic-certification-radio-equipment)[Prefer to read? Get the book — $24.99](/books/47-canada-ised-ic-certification-radio-equipment) Related guides * [UK Modern Slavery Act Supply ChainUK Modern Slavery Act 2015 Section 54 transparency statements: six reporting areas, the government registry, electronics supply chain risk areas, and CSDDD comparison.](/guides/uk-modern-slavery-act-supply-chain) * [Australia Modern Slavery ActAustralia Modern Slavery Act 2018: AUD 100M revenue threshold, seven mandatory reporting criteria, hardware supply chain risk areas (cobalt, 3TG minerals, PCB assembly), and the public statements register.](/guides/australia-modern-slavery-act) * [EU Forced Labour RegulationRegulation (EU) 2024/3015 bans products made with forced labour from the EU market: risk-based investigation, rebuttable presumption, remediation obligations, and CSDDD alignment.](/guides/eu-forced-labour-regulation) * [Canada Transportation of Dangerous GoodsCanada Transportation of Dangerous Goods Act: lithium battery UN numbers (3480/3481/3090/3091), TDGR packing instructions, dangerous goods declarations, and TDG training obligations.](/guides/canada-transportation-dangerous-goods)