Canada’s Bill S-211: Late Submissions Accepted

Important news with regard to Canada’s new legislation S-211—the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”). Under the Act, a large portion of businesses operating in Canada had new reporting obligations which were due May 31, 2024. However, there was significant uncertainty about these obligations. Many companies may have missed this deadline or mistakenly believed the Act did not apply to them.

Initially, government guidance suggested that submissions made after May 31 would not be accepted. However, Public Safety Canada has now reversed course and announced that it will accept late submissions.

Any businesses operating in Canada that have not already made submissions would be wise to take this opportunity to confirm whether they do have reporting obligations under the Act and to complete their reporting if required. The federal government is expected to treat this first year of the Act as a learning opportunity for Canadian businesses so it will likely be more receptive toward businesses that file late or imperfect submissions than those that do not file at all.

For greater detail on who is required to file and what reporting is required, see our earlier post.

If you have further questions about the Act or require support to take advantage of the late filing opportunity, please contact Boughton’s Matthew E. McCarthy.