Supply Chains Act Reporting Deadline: May 31 and What Canadian Importers Actually Need to File
Public Safety Canada's annual Supply Chains Act reporting deadline is May 31. If your entity imported goods produced in whole or in part by forced labour, here's what the filing obligation looks like, who it captures, and how it intersects with CBSA declarations.
The May 31 Deadline
Public Safety Canada reminded reporting entities that the annual filing deadline under the Fighting Against Forced Labour and Child Labour in Supply Chains Act is May 31, 2026. The report covers measures taken during your previous financial year. If you’re subject to the Act, the clock is running.
The Act came into force in January 2024. This is the second full reporting cycle. Most importers who missed the first round or filed something minimal are now on CBSA’s radar. The enforcement posture has shifted from education to compliance verification.
Who Files
You’re a reporting entity if you meet two tests: you produce, sell, or distribute goods in Canada or elsewhere, and you meet at least two of three size thresholds—CAD 20 million in assets, CAD 40 million in revenue, or an average of 250 employees. The thresholds aggregate across controlled entities. If your parent is foreign and you’re the Canadian importer of record, you still file separately for the Canadian operation.
Government institutions also file, but that’s a different administrative track.
The obligation is disclosure, not certification. You don’t certify your supply chain is clean. You report what steps you took during the year to prevent and reduce the risk that forced labour or child labour was used at any step in the production of goods you imported or sold. If you took no steps, you report that, too. The Act requires the report be published on your website and submitted to Public Safety Canada.
What Goes in the Report
The questionnaire asks for your structure, business activities, supply chain mapping, policies on forced labour, due diligence processes, remediation measures, training programs, and effectiveness assessment. Most of it is qualitative. You describe what you did, not what you found.
The trap is treating it like a press release. Public Safety publishes every report in a searchable registry. If your 2025 report says you conducted supplier audits and your 2026 report says you’re still developing a policy, the regression is visible. Consistency matters more than perfection.
If you import textiles, electronics, seafood, or agricultural products from jurisdictions flagged by the U.S. CBP UFLPA Entity List or the ILO’s forced labour indicators, expect your report to get more scrutiny. CBSA shares data with Public Safety. A pattern of RFI (Requests for Information) on specific FIRMS codes will show up in cross-agency reviews.
The CBSA Intersection
The Supply Chains Act runs parallel to CBSA’s existing prohibition on importing goods manufactured in whole or in part by forced labour under Customs Tariff section 136. That provision has been on the books since 2020. CBSA has the authority to detain shipments, demand proof of origin and labour practices, and issue seizures.
In practice, CBSA’s forced labour enforcement has been complaint-driven and reactive. The Supply Chains Act changes the information asymmetry. Your annual report is a public record. If you disclosed that you source from a specific region or supplier category and CBSA later flags a shipment, your report becomes part of the examination record.
We’ve seen this play out in AD/CVD cases under SIMA. CBSA pulls your CARM transaction history, cross-references your CAD filings, and compares declared suppliers to your corporate disclosure. If there’s a gap, you’re explaining it under oath during verification. The same logic applies to forced labour inquiries.
What Happens If You Don’t File
The Act allows Public Safety to demand compliance. Failure to file or filing false information can result in fines. The penalty schedule isn’t published yet, but the compliance model mirrors CRA and CBSA AMPS. Expect administrative monetary penalties in the low five figures for late filing, higher for substantive misrepresentation.
The bigger risk is reputational. The registry is public and searchable by company name. If you’re selling to a Canadian retailer or institutional buyer with procurement ESG requirements, a missing or weak report is disqualifying.
Filing Mechanics
The report is submitted electronically through Public Safety’s portal. There’s no customs broker intermediary; this isn’t a CAD or an origin certificate. You file directly as the entity. The form is a structured questionnaire, not a free-text narrative. Budget two to four hours if you have documentation ready, longer if you’re assembling records for the first time.
Public Safety doesn’t pre-clear or validate the substance before publication. You submit, they post. Corrections require a formal amendment and a public notation that the report was revised.
How This Affects Your Customs Program
If you’re claiming CUSMA preference on apparel imported from Mexico, your Supply Chains Act report and your CUSMA origin work file need to tell the same story. CBSA origin verifications under D11-4-2 include labour compliance questions now. If your report says you don’t know where yarn originates and your CUSMA certificate declares it’s wholly obtained in a CUSMA territory, the contradiction will surface during a CBSA verification.
Same logic applies to NRI arrangements. If you’re the non-resident importer and your Canadian customs representative is filing CADs on your behalf, you’re still the reporting entity for Supply Chains Act purposes if you meet the size thresholds. The NRI structure doesn’t move the filing obligation offshore.
What We’re Seeing
Most mid-market importers are filing minimal first-year reports: a policy statement, a supplier code of conduct, and a promise to do more next year. That approach worked in 2024. It won’t work in 2026. Public Safety is building the baseline. The enforcement focus will be on entities that regress or contradict themselves across reporting periods.
If you haven’t mapped your import supply chain past the first-tier supplier, start now. CBSA’s CARM transaction data gives you a clean list of every FIRMS code you’ve declared in the past twelve months. Pull your K84 statements, filter by country of origin and supplier, and work backward. That’s the minimum due diligence Public Safety expects to see in a credible report.
We work through these reconciliations regularly as part of compliance reviews. If your CAD filings, origin certificates, and Supply Chains Act disclosure don’t line up, fix it before CBSA does it for you during a verification. Get in touch.
Source: CSCB