Canada weighs forced-labor due diligence and civil liability alongside import controls

On October 8, 2026, Employment and Social Development Canada released two consultation reports covering Bill C-35's proposed forced-labor import regime and possible corporate due-diligence and civil-liability measures. Stakeholders broadly supported requiring certain entities to identify, prevent, mitigate and report forced-labor risks, but were divided on allowing victims to sue companies in Canadian courts for due-diligence failures. Importers should prepare for a control model that may require proof that listed goods are not linked to forced labor, while multinational groups may also face entity-level process obligations. Law firms should align customs evidence, supplier contracting, grievance systems and litigation exposure now, because separate workstreams could otherwise produce inconsistent representations to regulators, boards and courts.