ARTICLE
8 October 2025

New Joint Reporting Template Released For Modern Slavery Disclosures In Canada, Australia And The UK

D
Dentons Canada LLP

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In July 2025, the Canadian, Australian and United Kingdom governments jointly released an optional international reporting template and guidance related to modern slavery, forced labour and child labour.
Canada Government, Public Sector

Introduction

In July 2025, the Canadian, Australian and United Kingdom governments jointly released an optional international reporting template and guidance related to modern slavery, forced labour and child labour. Notably, this template allows entities to prepare a single report to satisfy certain requirements across all three jurisdictions. The template is intended to guide and streamline disclosure for entities subject to supply chain reporting obligations under Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act (Act), Australia's Modern Slavery Act 2018 and/or the UK's Modern Slavery Act 2015. Even for entities who choose not to adopt the template, it provides a strong indication of the Canadian government's expectations and the criteria to be considered in assessing compliance. The template may be revised on an ad hoc basis and any revisions will be made available here.

Key reporting sections

Currently, the template is broken down into seven sections, which correspond to key reporting themes in all three jurisdictions:

  1. Organizational and supply chain structure
  2. Policies
  3. Risk identification and management processes
  4. Due diligence and remediation measures
  5. Employee training
  6. Assessment of effectiveness
  7. Other relevant information

For certainty, only items 1 through 6 are currently required under the Act.

Levels of disclosure

For each section, the template splits reporting into two levels of disclosure:

  • Level 1 (Mandatory): Information that should be disclosed in statements and reports in accordance with legislative requirements in Canada, Australia and the UK.
  • Level 2 (Recommended): Information that entities are encouraged to disclose to demonstrate progress, leadership and a commitment to eradicating modern slavery, forced labour and child labour.

While the two disclosure levels are provided to encourage progress and improve reporting year-to-year, modern slavery reporting legislation in the three jurisdictions does not require year-over-year improvements in entities' actions, policies and practices.

Practical considerations

The template provides guidance to entities with supply chain reporting obligations in Canada, Australia and the UK for preparing a compliant joint report. That said, entities must exercise careful judgment in determining the appropriate scope of their reporting. Entities that have already adopted a compliant report do not need to change their reporting structure or substance on a go forward basis as a result of this template. Although the joint report can reduce duplication of efforts across the various jurisdictions, the additional level of recommended disclosures opens the door for additional obligations and supplemental disclosure that an entity may not wish to make.

The template provides a structured and detailed framework that clearly signals the type of information expected in disclosures. It is notably extensive, with numerous elements embedded in each section. In fact, the template notes that certain Level 1 disclosures may exceed the minimum requirements in one or more jurisdictions. Accordingly, where uncertainty arises, we recommend that entities review the governing legislation to ensure compliance with each jurisdiction's specific legal requirements.

Looking ahead and conclusion

The importance of a forward-looking approach is further underscored by the evolving regulatory landscape and the Government of Canada's stated intention to strengthen its approach to eradicating forced labour. The Act came into force in January 2024 and the government has issued guidance on three occasions: in December 2023, March 2024 and July 2025. In its 2024 Fall Economic Statement, the government laid out plans to introduce legislation establishing a new supply chain due diligence regime, create an oversight agency and bolster the ban on importing goods produced with forced labour. The federal government remains committed to introducing and strengthening measures relating to forced and child labour, with Global Affairs Canada now the key department moving these measures forward.

For guidance on whether an entity must report in Canada, see our previous publication here. We have also outlined Canada's modern slavery reporting obligations under the Act in earlier articles, available here and here. For an overview of the Act, see our analysis here. As a reminder, reports in Canada are due by May 31 of each year.1

The authors wish to thank articling student, Alison Balcom, for her assistance in the research and drafting of this article.

Footnotes

1. Under s. 13(2) of the Act, CBCA corporations must provide their report to shareholders alongside their annual financial statements, which may result in an earlier deadline.

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances. Specific Questions relating to this article should be addressed directly to the author.

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