April 15, 2026
The International Justice and Human Rights Clinic (IJHRC) has released new findings highlighting significant gaps in the implementation of Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act.
Drawing on an analysis of 119 corporate filings over the past two years, IJHRC researchers found that many reports lack meaningful detail on efforts to identify and address forced labour risks, with compliance often appearing formalistic rather than substantive.
McMaster University researcher Sima Fallah-Tafti, who conducted an artificial intelligence analysis of more than a thousand filings under the Act, found that reports scored an average of 36 per cent on specificity. “Most reports we analyzed were boilerplate — generic language, no specific suppliers named, no meaningful risk identification,” she said.
Hendry Zhang, a researcher with IJHRC, noted that companies are not providing sufficient detail in their reporting and that gaps in the regulatory framework mean many firms are not required to disclose key information. “Companies are not providing sufficient detail in their reporting, and many firms are not legally required to share any information,” he said.
The research also highlights structural gaps in the legislation, including the absence of reporting requirements for certain sectors such as services, mining, and real estate. It further notes limited enforcement to date, with no penalties issued for non-compliance.
Former Liberal MP John McKay warned that the current approach could have broader international implications, noting that weak enforcement risks becoming a “trade irritant” as the United States increases scrutiny of forced labour in global supply chains.
Members of the All-Party Parliamentary Group to End Modern Slavery and Human Trafficking called for stronger guidance, clearer oversight, and more robust enforcement mechanisms to ensure the Act achieves its intended purpose.
The IJHRC urges the Government of Canada to strengthen enforcement, close legislative gaps, and ensure that corporate reporting leads to meaningful due diligence and accountability in global supply chains.