In 2024, the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “FALC”) came into force, which imposed annual reporting obligations for certain entities. While the 2024 reports were due last year, this is a recurring obligation with significant penalties for non-compliance.
Recently, the Canadian government issued its Report to Parliament summarizing the submissions received for the 2024 reporting cycle. This Report serves as a reminder of the ongoing importance of timely compliance with the reporting obligations, with the next reporting deadline on May 31, 2025.
With May 31st deadline quickly approaching for Canada’s first mandatory Annual Reports on Forced Labour, many in the Oil, Gas & Petrochem sector may have missed these requirements completely!
While PSC’s update is aimed to provide clarity, it left many ambiguities, particularly regarding the definitions of “consolidated financial statements”, “asset” and “control”. These terms play a critical role in determining whether a foreign entity may fall within the reporting requirements of the FCLA.
