Over the past decade, governments worldwide have introduced legislation aimed at tackling forced labour and child labour in supply chains. These laws recognize that companies—whether knowingly or unknowingly—may be sourcing products and materials linked to labour exploitation.
Canada has now joined this international movement with its Fighting Against Forced Labour and Child Labour in Supply Chains Act, which came into effect in 2024. The law requires large companies operating in Canada to disclose how they are addressing the risks of forced labour and child labour within their supply chains.
But how does Canada’s approach compare to similar laws in the UK, Australia, the US (California), Germany, and France? Businesses that operate internationally may already be subject to modern slavery regulations in other jurisdictions. Understanding the similarities and differences can help companies navigate compliance more effectively and develop a coherent global strategy.
Transparency vs. Due Diligence: A Key Distinction
One of the biggest differences among modern slavery laws is whether they focus on transparency or due diligence.
The Canadian law, like the UK and Australian Modern Slavery Acts, follows a transparency model. This means companies are required to report publicly on the risks of forced labour in their supply chains and the steps they are taking to address those risks. However, they are not legally required to prevent or remedy human rights abuses.
In contrast, Germany’s Act on Corporate Due Diligence Obligations and France’s Duty of Vigilance Act impose stricter requirements. Companies subject to these laws must actively conduct due diligence, meaning they need to identify, prevent, and mitigate forced labour risks—or face penalties, including lawsuits.
For businesses operating in multiple jurisdictions, this difference is critical. A company that takes only a disclosure-focused approach to compliance (as required in Canada, the UK, and Australia) may still fall short of the legal expectations in Germany or France, where a proactive risk management strategy is required. Many experts also expect to see greater harmonization between the different compliance regimes in the future an an effort to level the playing field and facilitate greater trade between jurisdictions.
Who Must Comply? Canada’s Law Captures Mid-Sized Companies
Another key difference lies in which businesses are required to comply. The Canadian law applies to companies with at least CAD $40 million in revenue and 250 employees, or publicly listed companies. This threshold is lower than Australia’s law, which only applies to businesses with AUD $100 million in revenue, but it is more inclusive than Germany’s law, which initially applied only to very large corporations with 3,000+ employees (now being extended to companies with 1,000+ employees).
The UK’s and California’s laws take a different approach, applying to companies based on their total revenue, regardless of workforce size. The UK’s Modern Slavery Act covers companies with £36 million or more in turnover, while California’s law applies to retailers and manufacturers with $100 million+ in annual revenue.
France’s Duty of Vigilance Act, meanwhile, is the most restrictive in terms of which businesses it applies to, covering only companies with 5,000+ employees in France or 10,000+ globally.
For Canadian companies with moderate but significant operations, the new law represents a major shift—businesses that may have previously been exempt from global supply chain reporting may now find themselves subject to scrutiny.
📌 Key Global Modern Slavery Laws at a Glance
| Legislation | Who It Applies To | Main Requirements | Enforcement & Penalties |
| 🇨🇦 Canada’s Supply Chains Act (2024) | Companies with $40M+ in revenue and 250+ employees (or publicly listed) | Annual disclosure on forced labour risks, mitigation steps, and effectiveness | Public registry; potential financial penalties and reputational risk |
| 🇬🇧 UK Modern Slavery Act (2015) | Companies with £36M+ turnover operating in the UK | Publish an annual modern slavery statement | No direct penalties, but public enforcement pressure |
| 🇦🇺 Australia’s Modern Slavery Act (2018) | Companies with $100M AUD+ revenue | Detailed modern slavery statement covering risks, due diligence, and supplier engagement | Public registry; non-compliance flagged but no direct fines |
| 🇺🇸 California Transparency in Supply Chains Act (2010) | Retailers & manufacturers doing business in California with $100M+ revenue | Disclose efforts to eliminate forced labour in supply chains | No financial penalties, but legal exposure |
| 🇩🇪 Germany’s Due Diligence Act (2023) | Companies with 3,000+ employees (1,000+ by 2024) | Conduct supply chain due diligence, implement risk mitigation, report annually | Significant fines (up to 2% of revenue) |
Public Disclosure: Canada Introduces a Central Registry
One of the notable features of Canada’s law is its requirement for a public registry of company reports, similar to what exists in Australia. This contrasts with the UK and California, where there is no centralized repository for modern slavery statements—making enforcement and public scrutiny more difficult.
This name-and-shame model increases reputational risk for companies that fail to meet expectations. A weak or vague disclosure could invite negative media attention, activist scrutiny, or pressure from investors and customers.
In Germany and France, the stakes are even higher. If a company fails to effectively address forced labour risks under these laws, it may face financial penalties or lawsuits. French NGOs have already taken multinational corporations to court over failures in their vigilance plans, setting a precedent for legal action.
For Canadian businesses, this means that while there are no criminal penalties for non-compliance, the reputational risks associated with publicly available reports should not be underestimated.
Board-Level Oversight and Compliance Risks
Another key aspect of Canada’s law is that modern slavery disclosures must be approved by a company’s board of directors. This adds a higher level of accountability, ensuring that senior leadership is aware of and responsible for supply chain risks.
This is a notable difference from the UK and Australian laws, where reports must be signed by a director but do not necessarily require full board approval. It aligns more closely with Germany’s and France’s stricter frameworks, which hold senior leadership accountable for due diligence failures.
The requirement for board oversight increases the need for companies to take compliance seriously. A poorly prepared disclosure could result in boardroom scrutiny, investor concerns, and heightened regulatory attention.
How Should Canadian Companies Prepare?
With Canada’s Supply Chains Act now in effect, businesses need to take a proactive approach to compliance. While the law does not impose strict due diligence obligations, companies should still treat it as more than just a paperwork exercise.
To meet the requirements—and protect their reputation—companies should:
✅ Map their supply chains to identify high-risk regions and suppliers.
✅ Engage with suppliers to assess their labour policies and controls.
✅ Develop a strong disclosure statement that is clear, honest, and specific about risks and mitigation efforts.
✅ Ensure senior leadership is engaged and aware of compliance obligations.
✅ Align reporting efforts with other global regulations if the company operates in multiple jurisdictions.
For businesses that are unsure how to meet their obligations, InterPraxis provides expert guidance on modern slavery compliance.
We help companies:
🔹 Conduct risk assessments to identify forced labour risks in supply chains.
🔹 Develop clear, defensible disclosure statements aligned with global standards.
🔹 Implement supplier due diligence processes to strengthen compliance efforts.
Navigating these regulations requires more than just checking a box—it’s about ensuring your business is resilient, responsible, and prepared for scrutiny.
Canada’s new Supply Chains Act represents a significant step in the country’s efforts to combat forced labour and child labour. While it follows the transparency-based model of the UK and Australia rather than the stricter due diligence approach of Germany and France, it still carries serious implications for companies operating in Canada.
With a public disclosure registry, board oversight requirements, and potential penalties, businesses must take compliance seriously. By aligning with international best practices and adopting proactive risk management strategies, companies can not only meet legal requirements but also build trust with customers, investors, and stakeholders.
Is your company ready? Now is the time to act.
