Contact us: Supply Chains Act Implementation

In keeping with the spirit of the Act to enhance transparency, Public Safety Canada will continue to post reports, including those submitted past the May 31 legislated deadline. However, they will not be prioritized for publication. This will allow the public to have a central repository of all reports submitted to Public Safety Canada, via the library catalogue, regardless of when they were submitted.

The publication of annual reports submitted by reporting entities and government institutions is determined by the date it was submitted. Entities and government institutions should not expect their reports to be published immediately following submission. Reports will continue to be posted to Public Safety Canada’s library catalogue on an ongoing basis.

Subsidiaries must determine if they have reporting obligations independently from their parent company. If a subsidiary does not meet the definition of entity they do not have reporting obligations. The subsidiary should evaluate its own financial statement (not the consolidated financial statement of the parent company that controls it) to determine if it falls within the size-related thresholds outlined in the definition of “entity.”

When determining if they are an “entity” for the purposes of the Act, corporations, trusts, partnerships, and other unincorporated organizations should use consolidated financial statements to assess revenue, assets and employees and include the revenue, assets and employees of any entity it controls (i.e., its subsidiaries).

If both a parent company and its subsidiary are captured by the definition of entity and they are subject to reporting obligations, they may submit a joint report. Please refer to the guidance for more information about joint reports.

An entity is considered to be importing goods into Canada if the entity is responsible for accounting for those goods under the Customs Act. An entity buying a good in a domestic transaction, who is not causing the importation is not, generally, an importer. Purchasing goods produced outside Canada from a third party, where that third party is considered to be the importer for the purposes of the Customs Act, does not count as importing goods.

To determine if they are “doing business in Canada”, entities may use the factors considered by the Canada Revenue Agency when determining if a non-resident person is “carrying on business in Canada” for GST/HST purposes. Refer to the guidance for more information.

Provincial and municipal governmental institutions are not subject to the reporting requirements as per the definition of “government institutions” in the Act. However, some provincial agent Crown corporations may be subject to the reporting requirements by falling under the definition of “entity." It is their responsibility to determine whether they are a reporting entity under the Act.