What is the Canada Supply Chains Act (S-211)?
Covered entities report by 31 May on previous-year steps to prevent and reduce forced and child labour risks. The Canada reporting guide explains the wider obligation.
Why does S-211 matter to you?
Obtain governing-body approval and a member's signed attestation, then publish the report prominently on your website. Section 19 allows fines up to CAD 250,000 for non-compliance or knowingly false or misleading information.
How does S-211 work?
Test each entity on consolidated figures. A Canadian exchange listing is one route. The other requires a Canadian place of business, business activity, or assets plus two thresholds in either of the last two financial years: CAD 20 million assets, CAD 40 million revenue, or 250 average employees. Public Safety's activity test then requires goods production, import into Canada, or control of an entity that does.
What mistakes should you avoid?
- Testing only the group parent, not each legal entity.
- Listing policies without describing previous-year actions.
- Leaving the questionnaire and PDF inconsistent, unsigned, unapproved, or unpublished online.
Can an agricultural cooperative outside Canada be covered?
A Swedish agricultural cooperative produces grain, does business in Canada, has CAD 45 million revenue, and averages 300 employees. It meets two thresholds and can be covered despite its foreign base; Canadian presence alone is not enough.
What must the report cover?
Section 11(3) asks for seven areas: structure, activities and supply chains; policies and due diligence; risk areas and management steps; remediation; income-loss remediation; employee training; and effectiveness assessment.