How to separate today’s reporting requirements from consultation findings and possible future due-diligence measures.
On October 8, 2026, the federal government released two “What We Heard” reports after consultations on forced labour. One addressed proposed Bill C-35 measures to strengthen the import ban. The other considered possible supply-chain due-diligence and civil-liability measures. These are consultation findings and proposals under consideration. They are not a new employer duty.
That distinction matters. Organizations should not tell staff, suppliers or customers that a new due-diligence regime is already in force. At the same time, the consultation results are a useful prompt to understand whether the organization is already within scope of the current Fighting Against Forced Labour and Child Labour in Supply Chains Act and where its supplier-risk information is incomplete.
What applies today
The current federal framework includes a reporting regime for entities that meet its scope and threshold tests. Whether an organization must report depends on its activities, financial and organizational facts, and statutory definitions. The October 8 release does not replace that analysis. If you have a current filing obligation, continue following the existing framework and seek advice on any scope question.
Smaller businesses and nonprofits that are not required to report may still have a business reason to understand their exposure. Customers, funders, insurers and larger supply-chain partners may ask where goods come from, how suppliers are screened and who would handle a concern. A proportionate process can make those questions easier to answer.
What Canada is considering
The consultation reports describe interest in stronger import controls and possible requirements to identify, prevent, mitigate and report forced-labour risks in international operations and supply chains. They also discuss possible civil-liability approaches. The scope, timing, thresholds and final legal duties remain unsettled. Do not build a compliance program around assumed final rules. Build a sensible record of your current operations instead.
Five readiness steps that do not overstate the law
- Map what you buy and where it comes from. Start with goods, materials and services that involve international sourcing or a multi-tier supply chain. Identify the business owner for each major category.
- Collect proportionate supplier information. Ask key suppliers about origin, subcontracting, audit practices, known concerns and their own escalation process. Keep the questions practical and appropriate to the relationship.
- Set an internal owner. Finance, procurement, operations, legal and HR may each have part of the information. Name one accountable person to collect the records and coordinate responses.
- Create an escalation path. Employees or suppliers need to know where to raise a concern. Decide who receives it, how it will be documented, when external advice is needed and how retaliation concerns will be handled.
- Keep a watch list. Track the progress of Bill C-35, any federal due-diligence proposal and changes to official guidance. Update your approach when a final rule, effective date or new scope requirement is actually confirmed.
Keep the message accurate
The right message is simple: the federal government has released consultation findings, and possible new measures are still being considered. The existing reporting framework remains the current reference point for organizations within its scope. A readiness exercise is good governance, but it is not proof that a new law already applies.
For small businesses and nonprofits, this is also an opportunity to make procurement records more useful. A clear supplier list, a responsible owner and a documented response process are practical foundations whether the organization later needs to report, responds to a partner questionnaire or simply wants to manage supply-chain risk responsibly.
Primary source: Government of Canada — What We Heard reports on fighting forced labour
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