Public consultation on potential due diligence and civil liability measures to fight labour exploitation in supply chains: What We Heard Report

On this page

• Executive Summary
• Context and Background
• Consultation Process and Discussion Paper
• What We Heard
  • Section 1 – Key elements of a due diligence regime
  • Section 2 – Civil liability
  • Section 3 – Ways to maximize effectiveness and ensure coherence with the forced labour import prohibition
• Conclusion and Next Steps

Executive Summary

The consultation on potential due diligence and civil liability measures to fight labour exploitation in supply chains revealed that, if due diligence measures are pursued, there is broad support for establishing a risk-based regime.

However, views diverged on both the desirability and design of a potential due diligence regime. While many stakeholders expressed support for the concept, others highlighted considerations regarding its scope, implementation, and timing.

Participants representing civil society and academia primarily advocated for a comprehensive due diligence regime aligned with international standards and that includes meaningful engagement with workers, effective remediation and access to remedy, and credible enforcement.

On the other hand, many participants representing industry, including associations, businesses, and legal firms stressed the importance of carefully designing any due diligence regime and considering the impacts on Canadian businesses. Many expressed support in principle but emphasized the need for a phased and proportionate approach, while some opposed the introduction of new regulatory requirements altogether, citing the current geopolitical and economic pressures already facing Canadian businesses.

Participants representing an array of stakeholder groups provided a wide range of comprehensive feedback as to the complexity and far-reaching nature of the matter, including expressions of interest in further opportunities to engage in the future. Several stakeholders also sought greater clarity on the rationale for advancing due diligence measures on a timeline similar to consultations related to Bill C-35, which is currently before Parliament. Nonetheless, there was broad agreement that if both regimes are pursued, they should be complementary and grounded in a common set of definitions and requirements to ensure coherence and consistency.

Feedback on Discussion Paper’s Proposed Options  

Labour organizations, civil society, academia, and human rights advocates generally favoured comprehensive coverage of fundamental labour rights and broad application across businesses and supply chains, while business and industry stakeholders more often supported a targeted and proportionate approach focused, at least initially, on forced and child labour, larger entities, and upstream supply chains.

Across these differences, there was strong support for risk-based proportionality, particularly in determining which entities and activities should be covered and how obligations should be fulfilled, with many recommending scaled requirements and phased implementation, especially if requirements apply to small and medium-sized enterprises (SMEs).

Respondents consistently called for clear, practical and internationally aligned government guidance, sector- and risk-specific tools, centralized risk intelligence, training and technical assistance, and recognition of existing due diligence systems to reduce duplication and facilitate compliance.

There was also broad support from civil society and academia for meaningful stakeholder engagement, accessible grievance mechanisms, and remediation proportionate to an entity’s involvement in an adverse impact. This included accessible complaint mechanisms, including protections for vulnerable complainants and the ability of representative organizations to bring forward concerns.

Stakeholders favoured a graduated compliance and enforcement framework, combining education and corrective measures with inspections, investigations, administrative penalties, public reporting, and stronger sanctions for serious or persistent non-compliance, supported by an adequately resourced and potentially independent competent authority.

Views on civil liability were more divided: labour and human rights stakeholders generally viewed a civil right of action as essential to meaningful access to remedy and corporate accountability, while business stakeholders raised concerns regarding legal uncertainty, litigation exposure, causation, and liability for harms beyond a company’s reasonable control; many respondents nevertheless supported a carefully designed, proportionate model incorporating clear standards and potential due diligence defences.

Finally, stakeholders strongly supported close alignment between the proposed due diligence regime and the strengthened forced labour import prohibition proposed under Bill C-35, including harmonized definitions and evidence standards, information sharing, interoperable reporting systems, and mechanisms to ensure the regimes reinforce rather than duplicate one another.

Overall, the feedback points toward a framework that is outcome-oriented, ambitious in its worker-protection objectives, proportionate in its application, practical for regulated entities, and supported by credible oversight, enforcement, and access to remedy.

Context and Background

On July 21, 2026, the Honourable Patty Hajdu, Minister of Jobs and Families and Minister responsible for the Federal Economic Development Agency for Northern Ontario, and the Honourable Anita Anand, Minister of Foreign Affairs, announced the launch of two joint public consultations to strengthen Canada’s response to forced labour in global supply chains.

The Government of Canada sought stakeholder views on how it should develop and maintain the list of goods contemplated under Bill C-35, An Act respecting the prohibition of the importation of goods produced by forced labour. This consultation was led by Global Affairs Canada.

Concurrently, the Government of Canada sought views on potential due diligence measures that would require Canadian businesses operating abroad to identify, prevent, address and remediate risks to fundamental labour rights across their operations and supply chains. The consultation focused on the main elements of a potential regime, including: the scope of the obligations; the organizations that would be subject to the obligations; possible due diligence and reporting obligations; and approaches to compliance and enforcement. Views were also sought on whether to include civil liability provisions in a future due diligence regime. This measure would allow victims of labour exploitation to seek damages in Canadian courts against a business that has failed to do its due diligence to prevent labour exploitation in its supply chains. This consultation was led by Employment and Social Development Canada’s Labour Program (ESDC-Labour Program).

Note: This report summarizes the feedback received during the consultation focused on potential due diligence and civil liability measures to fight labour exploitation in supply chains. For a summary of the feedback received related to the regulatory approach under Bill C-35, An Act respecting the prohibition of the importation of goods produced by forced labour, a separate report will be made publicly available by Global Affairs Canada.

Consultation Process and Discussion Paper 

Between July 27 and August 21, 2026, stakeholders provided feedback through written submissions and hybrid roundtables. Invited participants included members of the public, industry associations, Indigenous organizations, labour unions, businesses of all sizes, academia, civil society organizations, and other interested parties.

To support engagement during the consultation, a discussion paper was published outlining policy options and targeted questions for stakeholder consideration. As outlined in the discussion paper, the consultation focused on three key areas and presented a range of potential options for consideration. Accordingly, much of the feedback received was provided in response to specific options rather than a proposed final approach.

The three key areas included:

1. Key elements of a due diligence regime, including scope, coverage, due diligence and reporting requirements, and compliance and enforcement mechanisms
2. Civil liability
3. Ways to maximize effectiveness and ensure coherence with the forced labour import prohibition

This report summarizes feedback from 71 stakeholders who provided input during the hybrid roundtables and/or through written submissions within the consultation window.

Table 1 provides a breakdown of participants by stakeholder group.

Table 1: Participation by Stakeholder Group

Stakeholder Group	Participants
Government, Parliament, Media, Academia, and Private Citizens	20
Civil Society, Labour Associations, and Non-Government Organizations	22
Industry, Trade, and Business Associations	21
Private Sector and Legal Stakeholders	8
Total	71

What We Heard

The following sections reflect stakeholder feedback on the options and proposals presented in the discussion paper. As a result, references to stakeholder views are often framed in relation to specific options under consideration and should not be interpreted as support for any final policy or legislative approach. The consultation focused on the design of a potential due diligence regime, rather than on whether such a regime should be adopted.

While outside the scope of the specific options and questions presented in the discussion paper, stakeholders also provided feedback on aspects of the consultation process and broader policy context. Participants across stakeholder groups emphasized that the consultation period, which was four weeks and conducted during the summer, may not have provided sufficient opportunity for robust and meaningful engagement on a policy issue of this magnitude. Many noted that the proposed measures raise complex legal, operational, and economic considerations that require extensive analysis and consultation within and across organizations. Additionally, several stakeholders sought greater clarity on the rationale for conducting consultations on due diligence measures in parallel with consultations related to Bill C-35, noting that Bill C-35 is already before Parliament and builds on an existing measure, whereas due diligence requirements would introduce a new regulatory framework that may benefit from further analysis and consideration of its policy, legislative, and operational implications.

Section 1 – Key elements of a due diligence regime

Scope

Views on the proposed scope options

Views on the proposed scope options were divided. Many respondents supported a broader scope based on all fundamental principles and rights at work recognized in the International Labour Organization Declaration on Fundamental Principles and Rights at Work. These participants generally favoured Option 1, arguing that forced labour and child labour are often linked to other labour rights violations, including restrictions on freedom of association and collective bargaining, discrimination, and unsafe working conditions. They emphasized that these rights are interconnected and mutually reinforcing, and that addressing only the most severe forms of exploitation could overlook the conditions that enable them. Several respondents also suggested that Canada should ultimately move beyond labour rights toward a comprehensive framework covering internationally recognized human rights and, in some cases, environmental impacts.

Some indicated that if due diligence measures were to be introduced, they would support a more targeted approach focused initially on forced labour and child labour under Option 2. These respondents argued that a narrower scope would align with Canada's existing legislative framework, including the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Supply Chains Act), provide greater legal certainty, and enable regulated entities to focus resources on identifying and addressing the most severe forms of labour exploitation. Many expressed concerns that expanding immediately to all fundamental labour rights could increase complexity, create uncertainty, and impose significant compliance and administrative burdens, particularly for SMEs. Several recommended allowing businesses and governments to gain experience with a more limited regime before considering future expansion.

Several respondents proposed intermediate or phased approaches. While some supported an eventual scope covering all fundamental labour rights, they suggested prioritizing oversight, guidance, and enforcement efforts on forced labour and child labour during the initial implementation period. Others emphasized the need for clear definitions, practical guidance, proportionality, and alignment with international frameworks to support compliance and interoperability across jurisdictions. Several respondents also stressed the importance of reviewing the effectiveness of an initial regime before expanding its scope.

Across both options, respondents frequently highlighted the importance of a risk-based and proportionate approach. Many called for the scope of any future regime to be clearly defined, aligned with international standards, and focused on producing meaningful action to prevent and address labour exploitation rather than creating a compliance or reporting exercise.

Views on how the Government can support regulated parties in identifying and addressing adverse impacts to fundamental labour rights

Respondents consistently emphasized the importance of clear, practical, and internationally aligned guidance to help regulated entities identify and address adverse impacts to fundamental labour rights. Many participants called for the Government to establish clear definitions, due diligence expectations, and risk-based frameworks aligned with internationally recognized standards, including the UN Guiding Principles on Business and Human Rights, OECD Guidelines, and International Labour Organization guidance.

Stakeholders also highlighted the need for practical implementation support, including model policies, contractual clauses, reporting templates, risk assessment tools, case studies, and examples tailored to different sectors, supply chains, and business sizes. Particular emphasis was placed on providing scalable support for SMEs who may have fewer resources available than larger entities.

A common theme was the need for improved access to reliable risk information. Many respondents recommended that the Government develop and maintain centralized sources of intelligence on labour rights risks, including country, sector, commodity, and product risk profiles, as well as information on known high-risk actors and practices. Stakeholders encouraged greater information sharing between government and industry, leveraging government expertise, diplomatic networks, customs data, and international partnerships to provide businesses with credible and up-to-date risk information. Several submissions also recommended publicly accessible databases, registries, and digital tools to support supply chain mapping, traceability, and risk assessment activities.

Respondents further stressed the importance of education, training, and capacity-building measures. Suggestions included government-led training programs, awareness campaigns, technical assistance, help desks, workshops, and certification initiatives to improve organizations’ ability to identify, prevent, mitigate, and remediate labour rights risks. Many stakeholders suggested that support should be proportionate to organizational size and capacity, with additional assistance available for smaller businesses and those operating in complex or high-risk supply chains. Several submissions also recommended phased implementation approaches to allow organizations sufficient time to build capacity and adapt existing systems.

Many stakeholders, primarily representing civil society and academia, emphasized that effective due diligence depends on meaningful engagement with workers, trade unions, rights holders, affected communities, and civil society organizations. Participants called on the Government to provide guidance on stakeholder engagement, consultation, grievance mechanisms, and remediation processes, including safeguards to ensure confidentiality, accessibility, and protection against retaliation. Several submissions also recommended strengthening accountability and oversight mechanisms, including independent bodies, ombudsperson functions, complaint processes, and collaborative forums that would facilitate information sharing, identify emerging risks, and support continuous improvement in due diligence practices.

More broadly, stakeholders encouraged the Government to streamline requirements associated with frameworks, tools, certifications, and due diligence systems. Many respondents recommended recognizing credible third-party standards, industry initiatives, and international compliance systems, while promoting interoperability across jurisdictions and regulatory regimes.

Stakeholders generally supported a risk-based and proportionate approach that focuses efforts on the most severe and likely harms, while accounting for the practical limitations organizations may face in complex, multi-tier supply chains.

Coverage

Views on the proposed scope of application

Many respondents, primarily representing civil society and academia, supported a broad scope that would apply across a wide range of businesses operating in or through Canada, including foreign companies conducting business in Canada, federal government departments, and Crown corporations. Several stakeholders emphasized the importance of applying human rights and labour rights responsibilities broadly across businesses. Some raised questions regarding the use of revenue or employee thresholds and highlighted the need to ensure that the legislative framework remains responsive to risks across different sectors and business models. Some respondents also emphasized that coverage should extend across global operations, subsidiaries, business relationships, and supply chains, while others highlighted the importance of addressing labour exploitation occurring both abroad and within Canada.

A significant number of stakeholders, primarily but not limited to those representing industry and legal firms, indicated that if due diligence measures were to be pursued, they supported a more targeted, gradual and proportionate approach. These respondents generally favoured applying full due diligence obligations to larger entities with greater resources, leverage, and ability to influence supply chain practices, while establishing scaled or simplified obligations for SMEs. Many argued that compliance requirements should reflect factors such as organizational size, supply chain complexity, risk exposure, and practical capacity to identify and address labour rights risks. Some stakeholders expressed concern that broad application could impose disproportionate burdens on smaller businesses or organizations with limited visibility into complex supply chains.

Respondents frequently emphasized the importance of a risk-based approach. Many suggested that the regime should prioritize entities, sectors, supply chains, and geographic regions where labour exploitation risks are greatest. Several proposed that smaller businesses operating in high-risk sectors or regions should remain within scope, while others recommended focusing obligations on larger organizations with meaningful influence over supply chain outcomes. Stakeholders also highlighted the need for clear definitions and direction regarding which entities, activities, rights, and business relationships would be covered, as well as alignment with international due diligence frameworks to promote consistency and reduce regulatory fragmentation.

Many respondents also stressed the importance of ensuring a level playing field. Common suggestions included applying comparable requirements to foreign businesses with substantial operations in Canada, incorporating federal procurement activities, and assessing corporate groups on a consolidated basis where this reflects actual control and influence. Several stakeholders further noted that implementation should be proportionate and supported through guidance, phased timelines, or other measures to help organizations, particularly SMEs, build due diligence capacity over time.

Views on the alternative options to reduce administrative and operational impacts on businesses

Many respondents supported measures to reduce administrative and operational impacts through a phased, proportionate, and risk-based implementation approach.

Stakeholders from industry associations, businesses, and some individual respondents frequently recommended staggered implementation schedules that would initially apply more extensive requirements to larger entities or those operating in higher-risk sectors and supply chains. Several respondents emphasized that obligations should be calibrated according to a company's size, capacity, leverage and risk exposure, while maintaining a focus on addressing the most serious labour rights risks. Others supported flexibility for SMEs, particularly those operating in lower-risk contexts, provided that core due diligence expectations remain intact.

A common theme across submissions was the need to reduce duplication and leverage existing compliance activities. Many respondents called for alignment with international frameworks and recognition of equivalent due diligence systems, reports, certifications, and reporting requirements already developed for other jurisdictions. Stakeholders advocated for a “comply once, demonstrate many” approach, including harmonized reporting requirements, common reporting templates, consolidated reporting mechanisms, and acceptance of credible third-party audits, industry initiatives, and verification systems. Respondents argued that these measures would allow businesses to build on existing processes, avoid duplicative reporting, and focus resources on identifying and addressing risks rather than producing multiple sets of compliance documentation. Some respondents further noted that compliance costs are often borne by suppliers and producers in other countries and emphasized the importance of not requiring them to invest in traceability and information-sharing systems that differ from those already established to meet the requirements of other jurisdictions.

Many respondents also highlighted the importance of implementation supports. Frequently cited measures included clear regulatory guidance, standardized templates, technical assistance, education and training, sector-specific tools, digital filing systems, and shared compliance infrastructure. Several stakeholders suggested that governments provide common reporting portals or platforms that would enable suppliers to submit information once and share it across multiple customers or reporting obligations. Respondents emphasized that practical support measures would help reduce compliance costs and administrative burden, particularly for SMEs, while maintaining meaningful due diligence requirements.

At the same time, many labour organizations, civil society organizations, and some academic respondents cautioned against reducing administrative burden through broad exemptions, weakened obligations, or transparency-only approaches. These respondents argued that labour rights protections should apply broadly and that any flexibility should be carefully targeted, risk-based, and limited in scope. Several suggested that support measures, phased implementation, harmonization, and standardized tools were preferable to reducing substantive due diligence obligations.

Some acknowledged that limited exemptions for SMEs in low-risk sectors could be considered through regulation but stressed that proportionality should affect how obligations are fulfilled rather than diminish the level of protection afforded to workers and vulnerable populations.

Views on the types of businesses that could be included or excluded from due diligence obligations

Many respondents, particularly labour, human rights, and civil society organizations, argued that broad exclusions based on company size, revenue, sector, or legal structure should be avoided. These participants emphasized that labour exploitation and human rights harms can occur throughout supply chains and are not limited to large enterprises. Several submissions argued that all businesses should be subject to due diligence obligations, while others supported only narrow exemptions for small businesses operating in demonstrably low-risk sectors.

A common theme was support for a risk-based approach to determining coverage. Stakeholders frequently identified sector risk, geographic risk, commodity risk, supply chain complexity, and exposure to adverse labour rights impacts as relevant factors. Many respondents also pointed to indicators such as the use of migrant or temporary workers, reliance on subcontracting or labour intermediaries, sourcing from high-risk jurisdictions, weak labour protections, and documented histories of labour exploitation. Several stakeholders argued that businesses operating in high-risk sectors or regions should remain within scope regardless of their size, and that regulatory flexibility should be used primarily to extend coverage to smaller entities in high-risk contexts rather than create broad exemptions.

Business associations and industry stakeholders generally supported coverage criteria that account for organizational size, available resources, operational complexity, and a company's ability to influence supply chain practices. These respondents stressed that obligations should be proportionate to a business's capacity, leverage, and visibility within its supply chains. Many expressed concern that extending full obligations to smaller businesses could create disproportionate administrative and compliance burdens, particularly for SMEs, while delivering limited additional benefits. Some submissions also emphasized the need for objective, evidence-based, and transparent criteria, aligned where possible with international approaches and informed by consultation and periodic review.

Views were mixed regarding sector-specific inclusions and exclusions. Some respondents opposed automatic designation of particular sectors as high risk and cautioned against sector-based exemptions, arguing that risk can vary significantly within sectors. Others supported identifying high-risk sectors to guide coverage or prioritize enforcement activities. Examples of sectors frequently mentioned as presenting elevated risks included agriculture, construction, manufacturing, extractives, apparel, mining, and certain international supply chains. A small number of respondents suggested tailored treatment or potential exclusions for specific low-risk sectors or for activities where businesses have limited visibility or influence over supply chain impacts.

Views on whether the framework needs to be prescriptive about how a regulated entity should account for its worldwide revenue or employee count

Most participants supported providing at least some level of prescription or guidance on how worldwide revenue and employee counts should be determined. Respondents emphasized that clear, consistent methodologies would improve certainty, support compliance, reduce administrative burden, and help regulated entities determine whether they are captured by the framework. Several stakeholders recommended aligning requirements with existing accounting, financial reporting, and regulatory frameworks, including the Supply Chains Act, internationally recognized accounting standards, and international due diligence regimes, to avoid creating conflicting approaches and unnecessary complexity.

A common theme was the need for clarity on how thresholds would apply across complex corporate structures. Stakeholders frequently identified the treatment of corporate groups, subsidiaries, parent companies, joint ventures, franchises, and foreign entities operating in Canada as areas requiring guidance. Many respondents favoured using consolidated financial and employee data, arguing that a consolidated approach would better reflect economic reality, prevent artificial fragmentation of corporate structures, and reduce opportunities for entities to avoid obligations through corporate restructuring. Several also recommended aligning calculations with information already collected for financial, tax, securities, or employment reporting purposes.

Respondents also identified a number of practical implementation challenges. These included determining whether calculations should be made at the entity or group level, accounting for different fiscal years, currency conversion, and addressing the treatment of seasonal, temporary, agency, contract, and subcontracted workers. Stakeholders noted that multinational corporate structures, franchise arrangements, and cross-border operations could create additional complexity. Several submissions urged the inclusion of anti-avoidance measures and clear rules to prevent entities from circumventing obligations through worker misclassification, corporate fragmentation, or other technical arrangements.

At the same time, a significant number of participants questioned the use of revenue and employee thresholds altogether. These respondents argued that size-based thresholds may fail to capture entities that pose significant labour rights risks, create incentives for regulatory arbitrage, and allow companies to avoid obligations through restructuring or other avoidance strategies. They generally favoured broader or risk-based coverage approaches that focus on a company’s exposure to supply chain risks rather than its size alone.

Due diligence and reporting obligations

Views on the proposed due diligence obligations

Respondents, primarily representing civil society and academia, expressed broad support for introducing mandatory due diligence obligations to address forced labour, labour exploitation, and other adverse human rights impacts in global supply chains. Many stakeholders viewed the proposed framework as consistent with established international standards, particularly the UN Guiding Principles on Business and Human Rights, the OECD Due Diligence Guidance for Responsible Business Conduct, and related international labour standards. A significant number of submissions favoured the more comprehensive approach reflected in Option 1, emphasizing that due diligence should go beyond transparency and reporting requirements and focus on identifying, preventing, mitigating, and remediating harms.

Respondents frequently highlighted core due diligence elements that should apply across business operations and supply chains. These included integrating due diligence into governance and policies, assessing actual and potential adverse impacts, prioritizing risks according to severity, taking action to prevent, mitigate, cease, and remediate harms, monitoring effectiveness over time, establishing communication or grievance mechanisms, and publicly reporting on due diligence activities. Many participants also emphasized the importance of meaningful stakeholder engagement, consultation with affected rights holders and workers, and continuous improvement rather than one-time compliance exercises. Academia specifically raised concerns regarding the level of detail available in publicly reported labour outcome metrics. They underscored the need for data that provides meaningful insights into supply chain worker outcomes and human rights conditions. Views differed, however, on the scope of due diligence obligations. Labour organizations, civil society groups, academia, and several individual respondents generally supported obligations that would apply throughout companies’ operations, supply chains, and value chains, including both upstream and downstream business relationships and multiple tiers of suppliers. These stakeholders often argued that significant risks can arise beyond direct suppliers and that comprehensive coverage is necessary to effectively address labour exploitation.

By contrast, many industry and business stakeholders advocated for a risk-based and proportionate approach focused primarily on upstream activities, where companies generally have greater visibility, leverage, and ability to influence outcomes. These respondents cautioned against requirements for exhaustive supply-chain mapping, complete traceability across all supply-chain tiers, or obligations that could effectively impose liability for circumstances beyond a company’s control. Many emphasized that due diligence should be assessed based on the reasonableness and effectiveness of efforts undertaken rather than guaranteed outcomes, and that requirements should reflect factors such as a company’s size, resources, level of involvement, access to information, and practical ability to act.

Respondents also stressed the importance of clarity and practicality in implementation. Suggestions included providing clear guidance on what constitutes reasonable due diligence, establishing standardized evidence and auditing expectations, ensuring alignment with existing reporting and compliance frameworks, and allowing companies to prioritize the most severe risks where resources are limited. Several submissions called for enhanced due diligence measures in high-risk contexts and emphasized the need for credible evidence, effective grievance mechanisms, independent oversight, and meaningful remediation when harms occur.

Views on the alternative options presented and whether there are other flexibilities with respect to due diligence obligations or reporting obligations that could lessen their operational or administrative impact

Many industry associations and business stakeholders supported measures that would reduce administrative burden, including limiting mandatory due diligence obligations primarily to upstream activities, adopting a risk-based and proportionate approach, and reducing reporting frequency through biennial reporting. These respondents emphasized the practical challenges of obtaining complete visibility across complex global supply chains and argued that obligations should reflect an organization’s size, sector, level of influence, access to information, and risk profile. Several respondents also called for phased implementation and tailored approaches for SMEs.

Many respondents proposed additional flexibilities aimed at reducing duplication rather than weakening substantive due diligence obligations. Common suggestions included recognizing existing due diligence systems, supplier information, certifications, third-party audits, industry assurance mechanisms, and equivalent foreign or international compliance frameworks. Stakeholders frequently recommended allowing organizations to build on reporting already completed under other Canadian or international regimes, incorporate previously disclosed information by reference, submit consolidated reports across corporate groups, and align reporting cycles and requirements across jurisdictions. Respondents also called for standardized reporting templates, common reporting portals, and interoperable data systems to streamline compliance processes.

Other respondents opposed reducing reporting frequency or restricting due diligence to upstream activities. These participants argued that annual reporting is necessary to maintain transparency and accountability and that labour and human rights risks can also arise in downstream activities. They contended that administrative burdens should be addressed through clearer guidance, standardized tools, centralized support mechanisms, and stronger alignment with international standards rather than by narrowing the scope of due diligence obligations. Several emphasized that flexibility should focus on proportionality, risk prioritization, and implementation support while preserving comprehensive and binding due diligence requirements.

Across submissions, there was broad support for practical implementation measures such as phased entry into force, guidance and technical assistance, simplified requirements for lower-risk or smaller entities, recognition of good-faith compliance efforts, and government-provided tools to support supply-chain mapping and risk assessment. Respondents generally viewed these measures as effective ways to reduce operational and administrative impacts while maintaining the overall objectives of the due diligence regime.

Views on the preferred type of guidance

Participants consistently emphasized the need for clear, practical, and accessible guidance to support implementation of due diligence obligations. Many respondents called for unambiguous compliance expectations, including clear definitions of key concepts, explanations of what constitutes reasonable or sufficient due diligence, and guidance on evidentiary, documentation, record-keeping, reporting, and enforcement standards. Stakeholders also requested practical implementation tools such as templates, model policies, questionnaires, reporting formats, risk assessment tools, case studies, and examples of acceptable practices and documentation. Several respondents highlighted the importance of guidance being issued well in advance of regulatory requirements and presented in plain language, particularly for SMEs.

A common theme was the desire for guidance grounded in internationally recognized frameworks and standards. Respondents frequently pointed to the UN Guiding Principles on Business and Human Rights, OECD Guidelines and OECD Due Diligence Guidance, ILO instruments, and broader international human rights standards as important reference points. Many stressed that any Canadian approach should align with existing international frameworks and foreign regulatory regimes, including through guidance on interoperability, equivalencies, and the interaction between Canadian requirements and other domestic and international obligations.

Stakeholders also expressed a strong interest in sector-specific and risk-based guidance. Respondents noted that due diligence challenges differ significantly across industries, commodities, and supply chains, and requested tailored guidance for sectors such as pharmaceuticals, manufacturing, mining, transportation, seafood, agriculture, renewable energy, and automotive production. Many sought government-provided information on high-risk sectors, commodities, goods, regions, and jurisdictions, as well as country and sector risk profiles, databases, and indicators. There were also calls for guidance addressing complex supply chains, traceability expectations, supply chain mapping, and operations in high-risk or opaque environments.

Respondents further requested detailed guidance on core due diligence processes. Frequently identified topics included risk identification and prioritization, severity and likelihood assessments, stakeholder and rights-holder engagement, supply chain mapping, leverage, grievance mechanisms, remediation, responsible disengagement, and monitoring effectiveness. Several submissions also stressed the need for practical examples demonstrating how businesses should respond to different types of risks and impacts, including guidance on supplier engagement, verification methods, and remediation pathways. Some participants emphasized that guidance should recognize existing due diligence, certification, and assurance frameworks while clarifying the role and limitations of audits and certifications.

Finally, many stakeholders highlighted the need for education, training, technical support, and ongoing engagement. Suggestions included training programs, workshops, compliance resources, digital tools, FAQ, technical assistance, and guidance developed in consultation with businesses, workers, Indigenous peoples, civil society organizations, rights holders, and subject matter experts. Some respondents also recommended ongoing advisory mechanisms and opportunities for regulator feedback to help organizations continuously improve their due diligence practices and better understand evolving expectations.

Views on what extent Canadian businesses should be responsible for remediating adverse impacts

There is broad support, primarily from civil society and academia, for requiring Canadian businesses to play a meaningful role in remediating adverse impacts linked to their operations and supply chains. Many respondents emphasized that remediation should be a core component of any due diligence regime and not merely an optional or secondary consideration. Several stakeholders argued that businesses should be responsible for addressing harms they cause or contribute to, while ensuring that affected workers and rights holders have access to effective remedies, including compensation and corrective measures.

A common theme was that remediation responsibilities should be proportionate to a company’s level of involvement in the adverse impact. Many respondents referenced a distinction between situations where a company has caused harm, contributed to harm, or is directly linked to harm through a business relationship. Under this approach, businesses that cause harm would be expected to provide or enable remedy directly, while those that contribute to harm should participate in remediation efforts proportionate to their involvement. Where companies are linked to harm through suppliers or other business relationships, many respondents suggested they should use their leverage to support remediation and improve conditions rather than automatically bear full responsibility for remedy.

Many also highlighted the importance of continued engagement with suppliers and business partners when adverse impacts are identified. Respondents frequently cautioned against immediate disengagement, arguing that ending business relationships can reduce a company’s ability to influence outcomes and may worsen conditions for affected workers. Instead, stakeholders often supported corrective action plans, supplier engagement, capacity-building, and other remediation efforts as preferred first responses, with disengagement reserved for situations where remediation is not feasible, suppliers refuse to act, or serious harms persist.

Respondents identified a range of potential remedies, including compensation, reimbursement of unpaid wages or recruitment fees, reinstatement, improved working conditions, rehabilitation, and guarantees of non-repetition. Several stakeholders emphasized that remediation processes should be centred on the needs and rights of affected workers and communities, developed in consultation with those affected, and supported by accessible grievance and accountability mechanisms. Some respondents also stressed the importance of civil liability, access to justice, and independent oversight to ensure that remedies are effective and that businesses remain accountable for adverse impacts linked to their activities.

While there was broad support for the inclusion of remediation measures from civil society and academia, some industry stakeholders emphasized that any associated obligations should be clearly defined, proportionate to the level of risk and influence exercised by a business, and aligned with emerging international standards and best practices. These stakeholders stressed the importance of providing businesses with sufficient clarity and certainty regarding the circumstances in which remediation would be expected and the actions required to demonstrate compliance. Several respondents cautioned against creating open-ended or overly broad liability, noting concerns that such an approach could generate legal uncertainty, discourage investment, and impose disproportionate burdens on businesses operating in complex global supply chains. They further argued that compliance and remediation expectations should take into account the efforts undertaken by businesses to identify, prevent, mitigate, and address risks. In particular, stakeholders emphasized that organizations acting in good faith and implementing reasonable and effective due diligence processes should receive appropriate consideration when assessing liability, enforcement actions, and remediation outcomes.

Views on whether regulated parties should be required to carry out meaningful engagement with stakeholders at every step of the due diligence process, similar to Article 13 of the European Union’s Corporate Sustainability Due Diligence Directive

Many labour organizations, civil society groups, academia, and human rights advocates supported requiring meaningful stakeholder engagement as a core element of the due diligence process. They argued that engagement should occur throughout all stages of due diligence, including risk identification, assessment, prevention, mitigation, monitoring, remediation, and public reporting. Respondents emphasized that effective engagement should be ongoing, accessible, safe, inclusive, and responsive, and should involve workers, trade unions, affected communities, Indigenous Peoples where relevant, civil society organizations, and other rights holders. Several submissions stressed that stakeholder participation improves the identification of risks and adverse impacts, strengthens accountability, and contributes to more effective prevention and remediation measures.

Many who supported mandatory engagement also called for safeguards to ensure participation is meaningful in practice. Suggestions included accessible and confidential grievance mechanisms, protections against retaliation, special measures for vulnerable groups and whistleblowers, gender-responsive and intersectional approaches, and the use of trusted intermediaries where direct engagement may not be safe or feasible. Several respondents noted that engagement should be evaluated based on whether stakeholder input influences decision-making, rather than on the number of consultations conducted. Others emphasized the importance of worker voice, freedom of association, collective bargaining, and institutional mechanisms that enable workers and their representatives to participate effectively in due diligence processes.

Others supported stakeholder engagement in principle but opposed a prescriptive requirement to engage stakeholders at every step of the due diligence process. These respondents generally advocated for a flexible, risk-based, and proportionate approach that focuses engagement on situations where it can meaningfully inform risk identification, mitigation, corrective action, remediation, or disengagement decisions. Several industry and business stakeholders argued that mandatory engagement at every stage could be impractical for complex or geographically dispersed supply chains and could create unnecessary administrative burdens. They recommended allowing organizations to tailor engagement approaches according to the severity of risks, the nature of their operations, and supply chain circumstances, while recognizing a range of engagement mechanisms, including collective initiatives, grievance systems, audits, certification programs, and third-party assessments.

Views were also mixed on the suitability of Article 13 of the European Union’s Corporate Sustainability Due Diligence Directive as a model. Some respondents explicitly endorsed an approach consistent with Article 13. Others supported stronger stakeholder engagement requirements than those currently reflected in the Directive, arguing that its stakeholder engagement provisions had been weakened during the legislative process and should not be treated as the benchmark for Canadian requirements. A number of submissions did not take a direct position on Article 13 but highlighted the broader importance of stakeholder input and consultation in the development and implementation of a due diligence framework.

Compliance and Enforcement

Views on the role government should play to support entities in complying with potential due diligence obligations

Most stakeholders emphasized that, if due diligence measures include an enforcement regime, the government should play a strong enabling role to help entities comply. A common recommendation was for government to provide clear, practical, and accessible guidance, including sector-specific tools, templates, reporting formats, FAQs, training, webinars, advisory services, and dedicated points of contact. Many respondents stressed the importance of supporting businesses, particularly SMEs, through education, technical assistance, capacity-building initiatives, and phased implementation periods that prioritize compliance and continuous improvement over punitive enforcement.

Many also called for government to serve as a central source of risk intelligence and compliance information. Stakeholders recommended that government develop centralized databases, supply chain risk resources, sector and regional risk assessments, standardized due diligence tools, and mechanisms to share relevant information gathered through diplomatic networks, customs activities, enforcement agencies, and international partners. Many highlighted the need for a “one-stop shop” where businesses could access guidance, risk information, best practices, reporting tools, and compliance resources.

A significant number supported the establishment of an independent competent authority, commissioner, or supervisory body responsible for administering and enforcing the regime. Respondents indicated that such a body should combine educational, advisory, oversight, investigative, and enforcement functions. Suggested responsibilities included reviewing reports, maintaining public registries, conducting compliance reviews and inspections, issuing guidance and advisory opinions, investigating complaints, facilitating remediation, and publicly reporting on enforcement outcomes. Many also emphasized the need for adequate resourcing, specialized expertise, and transparent processes to ensure effective implementation.

Many further stressed the importance of coordination and collaboration. Recommendations included harmonizing due diligence requirements with existing domestic and international frameworks, recognizing equivalent foreign standards, reducing duplication across regulatory regimes, and facilitating information-sharing among government departments, businesses, civil society organizations, workers, and international partners. Several respondents also called for government support for stakeholder engagement, knowledge-sharing networks, independent research, and initiatives that strengthen labour protections and remediation efforts both domestically and abroad.

Finally, while most generally supported strong compliance assistance measures, many emphasized that government support should be complemented by credible oversight and accountability mechanisms. Stakeholders highlighted the importance of monitoring compliance, investigating alleged violations, maintaining effective enforcement powers, providing access to remedy for affected individuals, and ensuring that due diligence obligations result in meaningful action to prevent and address labour exploitation in supply chains.

Views on the kind of tools the government (or competent authority) should have at its disposal to ensure that regulated entities comply with their obligations under a due diligence regime

Most stakeholders generally supported a graduated, risk-based compliance and enforcement regime that combines guidance and compliance support with stronger enforcement measures for serious or persistent violations. Many emphasized that the competent authority should have powers to conduct inspections, audits, investigations, and information requests, particularly where there are credible indicators of risk. Stakeholders also frequently called for the authority to compel documents and records, assess due diligence systems and reports, receive complaints, and undertake proactive compliance reviews. Several submissions stressed that enforcement should focus on the adequacy of a company's due diligence efforts and risk-management processes, rather than solely on whether harm occurred.

A common theme was the need for a graduated enforcement toolkit. Many supported the use of warning letters, guidance, recommendations, corrective-action plans, compliance notices, and compliance orders as initial responses to non-compliance. Industry associations and businesses in particular emphasized the importance of providing companies with reasonable opportunities to remedy deficiencies and demonstrate good-faith compliance efforts before more punitive measures are imposed. Several submissions also highlighted the importance of education, technical assistance, sector-specific guidance, information-sharing mechanisms, and digital compliance tools to support implementation.

There was support for administrative monetary penalties and other meaningful sanctions for serious, repeated, intentional, or persistent non-compliance. Many recommended that penalties be proportionate to factors such as company size, severity of the violation, degree of fault, cooperation with authorities, remediation efforts, and any benefits derived from the misconduct. Some stakeholders also supported stronger consequences, including restrictions on access to government procurement, financing, or support programs, import controls, procurement exclusions, and, in some cases, civil or criminal sanctions for the most serious violations.

Transparency and public accountability were also recurring themes. Numerous respondents supported public registries of reports and non-compliant entities, publication of enforcement decisions and compliance findings, and regular reporting on enforcement activities. Several stakeholders advocated for “naming and shaming” persistent violators, while others emphasized that any public disclosure regime should include procedural fairness and protections for confidential commercial information.

Finally, many civil society organizations, labour groups, academia, and advocacy organizations recommended establishing an independent oversight or enforcement body with robust investigative powers, including authority to receive complaints, conduct investigations, compel testimony and documents, and order corrective measures. Some specifically called for powers comparable to those available under the Inquiries Act or for strengthening independent ombudsperson functions. Several respondents also stressed the importance of coordination across government departments, customs authorities, and international partners to support effective monitoring and enforcement.

Industry representatives primarily supported compliance and enforcement mechanisms that are risk-based, proportionate, and focused on promoting continuous improvement rather than punitive outcomes. Many favoured a graduated approach that emphasizes guidance, education, information-sharing, corrective action plans, and opportunities to remedy deficiencies before penalties are imposed. Many also stressed the importance of clear evidentiary standards, regulatory certainty, protection of commercially sensitive information, and recognition of good-faith efforts to identify, prevent, and mitigate risks. Several industry respondents cautioned against open-ended liability and expanded private litigation, arguing that enforcement should prioritize administrative oversight and assess whether companies have taken reasonable due diligence measures, rather than holding businesses liable solely because adverse impacts persist within complex global supply chains.

Views on whether the competent authority should be required to receive and investigate complaints of non-compliance under a due diligence regime, and who should be entitled to file a complaint

Stakeholders from labour organizations, civil society, academia, faith-based organizations, and many industry groups generally viewed complaints as an important source of information for identifying risks, supporting enforcement, and improving accountability. Most supported establishing a mechanism through which the competent authority would receive and investigate complaints of non-compliance under a due diligence regime. Several respondents also recommended that the authority have the ability to initiate investigations on its own motion, rather than relying solely on complaints. A smaller number of organizations raised concerns about administrative capacity, questioned whether all complaints should trigger formal investigations, or suggested that investigations should be limited to credible or substantiated allegations.

There was broad support for allowing a wide range of parties to submit complaints. Frequently identified complainants included affected workers, former workers, affected individuals and communities, trade unions, worker representatives, and civil society organizations. Many also supported standing for non-governmental organizations (NGOs), labour and human rights organizations, community groups, whistleblowers, and other parties with credible information. Some proposed even broader eligibility, extending access to academia, journalists, investors, businesses, competitors, industry associations, public bodies, Indigenous communities, diaspora communities, and members of the public. Some emphasized that vulnerable workers may face barriers to reporting directly and that representative organizations should be able to file complaints on their behalf.

A recurring theme was the need for safeguards to ensure complaint mechanisms are effective, accessible, and fair. Many called for strong confidentiality protections, anti-retaliation measures, anonymous reporting options, and accessible channels for workers and affected communities, including those located outside Canada. At the same time, several business and industry respondents stressed the importance of screening mechanisms to assess jurisdiction, credibility, and evidentiary thresholds, and to prevent frivolous, duplicative, vexatious, or bad-faith complaints. Some also highlighted the importance of procedural fairness, including opportunities for companies to respond to allegations and risk-based approaches to assessment and investigation

Several noted that complaint mechanisms should complement, rather than replace, other accountability and remedy mechanisms. They highlighted the continued importance of access to courts, independent oversight bodies, company-level grievance mechanisms, and proactive monitoring by regulators. Some stakeholders also pointed to the value of dedicated investigative bodies with sufficient powers and resources, while others emphasized the need for international cooperation where allegations involve global supply chains.

Section 2 – Civil liability

Views on enshrining a civil right of action in a due diligence supply chain regime

Views were divided, with a substantial number of respondents supporting its inclusion as a key accountability and remedy mechanism, while others urged caution or opposed its introduction given that existing approaches provide limited evidence of delivering meaningful outcomes for victims and emphasized the need for a comprehensive remedy framework.

Respondents argued that a civil right of action is essential to ensure meaningful access to justice for victims of forced labour, child labour, and labour exploitation. They emphasized that the ability to seek redress through Canadian courts would strengthen corporate accountability, create incentives for robust due diligence, and complement administrative enforcement measures. Many also argued that, without civil liability, due diligence requirements risk becoming primarily reporting or compliance exercises rather than effective tools for preventing and remedying harm.

Several stressed that civil liability should not operate in isolation but as part of a broader enforcement framework that includes regulatory oversight, investigations, administrative penalties, grievance mechanisms, and remediation measures. Some noted that judicial remedies are an important component of international standards on business and human rights, while others highlighted the need to address common barriers to justice, such as litigation costs, evidentiary burdens, standing requirements, jurisdictional challenges, lengthy proceedings, and fear of retaliation. A number also supported liability models based on fault or failure to meet due diligence obligations rather than strict liability, and some proposed safe-harbour protections for companies that demonstrate genuine and proactive compliance efforts.

Those expressing concerns about a statutory civil right of action generally favoured prioritizing administrative enforcement and regulatory oversight. Business associations, industry groups, and some legal practitioners cautioned that broad civil liability could create legal uncertainty, increase costs, expose companies to unpredictable litigation risks, and impose liability for harms occurring deep within complex global supply chains that may be beyond a company's reasonable knowledge or control. Several suggested that governments should first implement and assess the effectiveness of a due diligence framework before introducing new private causes of action, while others warned that liability provisions could encourage defensive compliance or supplier disengagement from higher-risk regions rather than fostering remediation and continuous improvement.

A number adopted a middle-ground position, supporting access to remedy in principle while calling for a carefully designed and proportionate approach. They emphasized the importance of aligning any civil liability regime with international norms, clearly defining the basis for liability, distinguishing between intentional, negligent and good-faith conduct, and ensuring that civil remedies complement rather than replace public enforcement. Some also pointed to alternative models that prioritize strong administrative enforcement while expanding access to remedy through existing legal mechanisms.

Views on what an enshrined civil right of action should look like and its potential parameters

Labour organizations, civil society groups, academia, and human rights advocates generally supported the creation of a civil cause of action. Respondents viewed civil liability as an important accountability mechanism that would complement mandatory due diligence obligations, regulatory enforcement, and non-judicial grievance mechanisms. They emphasized the need for affected workers, communities, and, in some cases, representative organizations such as unions, NGOs, and civil society groups to have standing to bring claims.

Supporters of a civil right of action commonly recommended a range of remedies, including compensation for damages, injunctions to stop harmful practices, rehabilitation measures, litigation costs, and other court-ordered remedies. Several stressed that the framework should improve access to justice by addressing practical barriers faced by foreign plaintiffs and vulnerable workers, including challenges related to evidence gathering, litigation costs, retaliation, limitation periods, and cross-border proceedings. Some also proposed representative or class-action mechanisms, litigation-support funding, whistleblower protections, and measures to facilitate access to evidence.

Business associations, industry groups, and some companies generally argued that any civil liability regime should be carefully defined, proportionate, and linked to specific failures to meet statutory due diligence obligations. Common themes included the need for clear standards of care, causation requirements, evidentiary thresholds, and distinctions between situations where a company caused, contributed to, or was merely linked to harm. Many opposed strict or automatic liability and emphasized that liability should be fault-based and tied to a demonstrable connection between a company’s conduct and the alleged harm.

A frequently raised issue across stakeholder groups was the role of due diligence as a defence. Many supported safe-harbour protections or a due diligence defence for organizations that could demonstrate reasonable, good-faith, risk-based efforts to identify, prevent, mitigate, and remediate harms. Others cautioned that conducting due diligence should not automatically shield companies from liability where harms resulted from inadequate action.

Overall, respondents stressed the importance of ensuring meaningful access to remedy and accountability while maintaining legal certainty and proportionate safeguards for businesses and avoiding measures that could discourage businesses from bringing issues forward.

Section 3 – Ways to maximize effectiveness and ensure coherence with the forced labour import prohibition

Views on how a potential due diligence regime and the forced labour import prohibition, including measures proposed in Bill C-35 (i.e. public list of goods at risk), could potentially ‘interact’

A clear theme was that a potential due diligence regime and the forced labour import prohibition under Bill C-35 should function as complementary and mutually reinforcing tools rather than as separate or competing regimes. Many argued that due diligence obligations would operate upstream by helping businesses identify, prevent, mitigate, and remediate forced labour risks throughout their supply chains, while import prohibitions would serve as a downstream enforcement mechanism focused on preventing goods linked to forced labour from entering the Canadian market. Several emphasized that the two measures address different points in the supply chain and are most effective when implemented as part of a coherent framework. Many highlighted the value of information-sharing and interoperability between the two regimes. Submissions suggested that due diligence reports, risk assessments, traceability information, and other documentation could support import compliance reviews and enforcement activities, while information generated through import enforcement, including findings related to goods at risk, could inform corporate risk assessments and enhanced due diligence efforts. Several also proposed that annual due diligence reporting could help government authorities identify high-risk sectors, suppliers, and goods, including informing the development and updating of a public list of goods at risk under Bill C-35.

A recurring recommendation was to align definitions, reporting requirements, evidence standards, and documentation across both frameworks to reduce duplication and improve regulatory efficiency. Businesses and industry associations frequently noted that information and records prepared for one regime should, where appropriate, be reusable for compliance with the other. Respondents also called for coordination among responsible authorities and, in some cases, for credible due diligence efforts to be recognized as relevant evidence in import-related assessments. At the same time, some submissions cautioned that compliance with one regime should not automatically satisfy the requirements of the other and that enforcement decisions should continue to be based on independent assessments of available evidence. Relatedly, respondents highlighted the need to consider the risk of duplicate penalties for entities subject to both Bill C-35 and due diligence requirements, suggesting that where both regimes apply, enforcement through a single penalty mechanism may be more appropriate.

Several specifically suggested linking due diligence requirements to Bill C-35's proposed public list of goods at risk. Suggestions included triggering enhanced due diligence obligations for listed goods, using due diligence findings to support listing and delisting decisions, and incorporating information from customs enforcement, complaints, civil society reporting, and corporate due diligence processes into shared risk assessment mechanisms. Overall, some viewed stronger coordination between the two regimes as an opportunity to improve transparency, strengthen accountability, enhance risk identification, and increase the effectiveness of Canada's efforts to prevent forced labour in global supply chains.

Views on how to avoid any unintended consequences, if applicable, between the two legislative regimes

Most overwhelmingly emphasized the need for strong alignment and coordination between the two legislative regimes. Many called for harmonized definitions, evidentiary standards, reporting requirements, timelines, data standards, and compliance expectations. There was broad support for interoperable systems, shared reporting templates, and the ability to reuse information, reports, and evidence across regimes in order to reduce duplication, improve clarity, and minimize administrative burden for regulated entities. Several also highlighted the importance of aligning Canada's approach with international frameworks and recognizing equivalent due diligence measures undertaken under credible foreign regimes.

They also stressed that the two regimes should be coordinated and mutually reinforcing while maintaining their distinct purposes. Many recommended stronger information sharing, integrated enforcement approaches, cross-referencing of reports and enforcement findings, and clear referral mechanisms between responsible authorities. Some generally supported a coherent framework in which due diligence obligations, import controls, enforcement activities, remediation, and access to remedy work together to strengthen accountability and improve outcomes. Several cautioned, however, that compliance with one regime should not automatically demonstrate compliance with the other, nor should due diligence obligations create an automatic safe harbour from import restrictions where credible evidence of forced labour exists.

A recurring theme was the need to avoid creating incentives for unintended business responses, particularly supplier disengagement or the concealment of risks. Many argued that the regimes should encourage prevention, continuous improvement, remediation, and the responsible use of leverage rather than prompting companies to terminate relationships with suppliers or withdraw from higher-risk regions. Some emphasized that organizations should not be penalized simply for identifying or disclosing risks through due diligence processes, and that enforcement and review mechanisms should take into account good-faith remediation efforts. Several also highlighted the importance of protecting confidential business information, worker identities, and commercially sensitive data, while ensuring procedural fairness and opportunities to challenge enforcement decisions or pursue corrective action.

Finally, many identified the importance of proportionality, clear guidance, and coordinated implementation. Recommendations included risk-based approaches, practical compliance tools, adequate transition periods, ongoing consultation with stakeholders, and centralized guidance to support compliance. Some noted the need to consider sector-specific impacts and broader public-interest considerations, including effects on critical supply chains, healthcare products, transportation networks, and SMEs. Overall, most favoured a coherent, coordinated, and proportionate framework that strengthens worker protections and enforcement outcomes while avoiding unnecessary duplication, uncertainty, and unintended economic or social consequences.

Conclusion and Next Steps

The consultation feedback offers valuable insights for the development of a Canadian due diligence regime that moves beyond transparency toward meaningful action to prevent and address labour exploitation. While there was a wide range of views from stakeholders on the appropriate scope, coverage, supply-chain reach, reporting requirements, and role of civil liability, there was substantial agreement on the main principles that could underpin the framework: a risk-based and proportionate approach; alignment with international standards; clear and practical government guidance and tools; credible and graduated enforcement; and coordination with existing domestic and international requirements.

The findings suggest that administrative burden should be addressed primarily through phased implementation, scalable obligations, harmonization, recognition of equivalent systems, standardized tools, and government support, rather than through broad exemptions that could weaken worker protections.

In terms of civil liability, there was support for ensuring that affected individuals have meaningful avenues for redress, although views differed on the extent to which a statutory civil right of action should form part of that framework and on the safeguards that would be required to ensure a fair and proportionate approach.

Beyond the question of civil liability, the consultation feedback also highlighted the importance of ensuring, the proposed due diligence regime and the strengthened forced labour import prohibition proposed under Bill C-35 should be designed as complementary components of a coherent Canadian framework, with appropriate information sharing and interoperability, while preserving the distinct purpose and decision-making requirements of each regime.

As the Government moves toward possible policy and legislative development, the central challenge will be to balance strong protections and accountability for workers with legal certainty, proportionality, and practical implementation for regulated entities, ensuring that due diligence becomes an effective mechanism for preventing, addressing, and remedying labour exploitation rather than simply another reporting obligation. This, in turn, will support a level playing field for responsible businesses, help Canadian companies identify and mitigate risks more effectively, and strengthen Canada’s competitiveness.

Any actions resulting from this consultation will be subject to the appropriate Government of Canada approval processes and, where required, parliamentary consideration.

The Government of Canada sincerely thanks all stakeholders that took part in the consultation process and provided their views, concerns, and recommendations. The feedback received will play an important role in informing future policy decisions.