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Clarity and Confusion: Updates to Canada s Guidance on Forced Labour Reporting Requirements

As businesses finalize their reports under the Fighting Against Forced Labour and Child Labour in Supply Chains Act the Act in advance of the May 31, 2024, statutory deadline, Public Safety Canada has updated its administrative guidance to clarify certain technical requirements, while also sowing confusion in respect of the basic question of which entities have reporting obligations under the Act. Public Safety Canada revised its guidance for Entities, originally issued in December 2023, on March 5, and March 20, 2024, and also added a page for answers to top questions and other amendments on March 5. A separate section was also added to the guidance website on March 13, 2024, to address the reporting obligations of government institutions.

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