# Annual Reports & Disclosure Obligations

The legal requirements for annual reports, revision mechanics, offence provisions, and the quality-control points that matter before publication.

## Mandatory Content, Revisions, and Publication Mechanics

A defensible S-211 report has to satisfy the content rules in section 11, be corrected properly if revised under section 12, and be submitted and posted in the required manner.

The report content requirements are set by section 11 of the Act, and they are not optional. The report has to cover the seven mandatory categories and also include the approval and attestation required by section 11(4) and (5). Public Safety Canada's guidance adds the practical filing rules: the report must be uploaded as a PDF through the federal portal and then posted prominently on the reporting entity's own website.

Section 12 matters because it creates an express mechanism for revised reports. A revised report must repeat the required content, state the date of revision, describe the changes made to the original report, and go through the same approval and attestation process. That makes revision control a legal issue rather than an informal editing choice. If facts change or an error is discovered, the correction process should be documented and routed back through the governing body.

For report assembly, the safest approach is to treat the questionnaire, PDF, website posting, and internal evidence pack as one integrated disclosure package. Inconsistencies across those layers create avoidable exposure. The law and guidance do not require perfection, but they do require a coherent, approved, and supportable account of what the entity actually did during the reporting year.

### Citations

- Supply Chains Act, s 11: Fighting Against Forced Labour and Child Labour in Supply Chains Act, s 11 (https://laws-lois.justice.gc.ca/eng/acts/F-10.6/section-11.html)
- Supply Chains Act, s 12: Fighting Against Forced Labour and Child Labour in Supply Chains Act, s 12 (revised reports) (https://laws-lois.justice.gc.ca/eng/acts/F-10.6/section-12.html)
- PSC Entity Guidance: Public Safety Canada, Guidance for entities (https://www.publicsafety.gc.ca/cnt/cntrng-crm/frcd-lbr-cndn-spply-chns/prpr-rprt-en.aspx)

## Offences, False Statements, and the Limited Role of Due Diligence

Sections 19 and 21 create the offence framework. They should be read carefully, because the due-diligence protection is narrower than many teams assume.

Section 19(1) makes it an offence to fail to comply with section 11 or other listed provisions, with exposure on summary conviction to a fine of up to $250,000. Section 19(2) separately creates an offence for knowingly making false or misleading statements or knowingly providing false or misleading information to the Minister or a designated person. That knowledge requirement is important: teams should not casually describe every reporting error as criminal, but they also should not overlook the specific risk created by knowing inaccuracies.

Section 21 should be read closely because it is where the Act expressly addresses due diligence. It says that, in a prosecution for an offence under subsection 19(1), proof that the offence was committed by an employee or agent is sufficient unless the accused establishes that they exercised due diligence to prevent its commission. In other words, the statutory due-diligence protection is tied to that employee-or-agent context for section 19(1) offences; it is not a blanket cure-all for every reporting problem or every knowingly false statement under section 19(2).

Public Safety Canada's 2025 report to Parliament is useful here because it shows that the federal system is tracking corrective measures, offences, and punishments as part of the Act's implementation. For reporting teams, the practical lesson is to maintain a real verification trail: source tables, review notes, sign-off history, and records showing what steps were taken to prevent filing or publication errors before the report went public.

### Citations

- Supply Chains Act, s 19: Fighting Against Forced Labour and Child Labour in Supply Chains Act, s 19 (offences and punishment) (https://laws-lois.justice.gc.ca/eng/acts/F-10.6/section-19.html)
- Supply Chains Act, s 21: Fighting Against Forced Labour and Child Labour in Supply Chains Act, s 21 (offence by employee or agent; due diligence) (https://laws-lois.justice.gc.ca/eng/acts/F-10.6/section-21.html)
- 2025 Parliament Report: Public Safety Canada, 2025 Annual Report to Parliament on the Fighting Against Forced Labour and Child Labour in Supply Chains Act (https://www.publicsafety.gc.ca/cnt/rsrcs/pblctns/2025-frcd-lbr-chld-lbr-spply-chns-ct-scnd-rprt/index-en.aspx)