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Thursday, October 1, 2026

Canada's Proposed Modern Slavery Act Would Impose Significant Annual Reporting Obligations on Certain Private-Sector Entities - Littler Mendelson PC

  • Bill S-211 would enact the Modern Slavery Act, which would require covered employers to report annually on efforts to combat forced and child labour.
  • If the Modern Slavery Act receives Royal Assent in 2022, it will take effect January 1, 2023, and employer reporting requirements will commence May 31, 2023.
  • Non-Canadian entities that do business in Canada and meet the size and activity requirements might be subject to this law.

The purpose of Canada’s proposed Bill S-211, Fighting Against Forced Labour and Child Labour in Supply Chains Act and to amend the Customs Tariff (Bill S-211) is, in part, to enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act, i.e., the Modern Slavery Act (MSA). Canada’s desire to enact this legislation reflects its commitment to participate in the international fight against forced labour and child labour. If passed, the MSA would require certain government institutions and private-sector entities to report annually on measures they have taken to prevent and reduce the risk that they or their supply chains are using forced labour or child labour.

As of the date of publication, Bill S-211 had passed through the Senate, and on June 1, 2022, second reading in the House of Commons was completed. Currently, the Act is under consideration by the House of Commons Standing Committee on Foreign Affairs and International Development.

The MSA has not been enacted at this time; however, it will come into force on January 1 of...



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