Data · First edition · July 2026
The S-211 Report Card: Canada's Forced-Labour Filings, Graded
Short answer: Canada's Bill S-211 filings have a grade now, and the national median is 50.5 out of 100. Public Safety Canada's registry holds 12,599 forced-labour reports. We pulled 100 and graded 92 of them line by line against the Act's own text and a published 5-Step due diligence methodology. 48.9% graded D or F. 32.6% graded C, compliant on paper. Two reports out of 92 earned an A, and both belong to US-headquartered multinationals. The next reports are due May 31, 2027.
Until this pilot, none of the 12,599 reports in the registry had been publicly graded. Companies filed into a void, and a void teaches nothing. This page is Canada's first Bill S-211 report card: the grade distribution, the honor roll, the five graded dimensions, and the exact method behind every score. It grows from 92 filings to the full registry in fall 2026.
The grade distribution
Across the 92 graded filings, the median grade is 50.5 out of 100, the mean is 48.8, and the range runs from 18 to 89. These are the first S-211 compliance grades ever issued, and they split like this.
A
2 reports
2.2%
B
15 reports
16.3%
C
30 reports
32.6%
D
23 reports
25.0%
F
22 reports
23.9%
The C band is the largest single block: 30 reports, 32.6% of the sample. In this rubric a C means compliant on paper. Every mandatory element is addressed, but it is addressed with claims instead of evidence. The single biggest scoring gap in the entire dataset sits between reports that show numbers and reports that show adjectives.
The S-211 Report Card · Pilot, July 2026
50.5
Median grade / 100
The national median across 92 graded filings. Compliant on paper is the Canadian average.
48.9%
Graded D or F
Nearly half of board-signed reports do not demonstrate the diligence the law asks them to describe.
29.3%
Skipped the income-loss element
s.11(3)(e) asks what you did for the vulnerable families your enforcement affects. Three in ten filers said nothing at all.
2 of 92
Earned an A
Both belong to US multinationals. The A band is open, and it is earned with evidence, not adjectives.
Source: the S-211 Report Card pilot, 92 filings graded line by line against the Act and XFACTOR's published 5-Step methodology, every score backed by the filing's own words.
The honor roll
The naming policy is praise-only. Strong filings are named, weak filings never are, because the grades exist to raise the standard, not to shame the people carrying it. These five reports earned the top of the pilot.
- 01HP Inc.89/100A
- 02Kellanova Canada80/100A
- 03Cargill Limited78/100B
- 04Bruce Power73/100B
- 05Ooni Limited73/100B
What set the top five apart was not polish or headcount. It was proof: completion rates, named documents, audits with findings, claims a reader can verify. And one finding travels further than the rest: both A grades belong to US-headquartered multinationals whose programs were built under American enforcement and file here. No Canadian-headquartered company earned an A in the pilot. The A band is open.
The five graded dimensions
Rubric v0.1 awards 100 points across five dimensions. The pilot medians land like this.
| Dimension | Points | Pilot median | What the sample showed |
|---|---|---|---|
| Statutory completeness | 30 | 19.5 | The seven mandatory elements of s.11(3). Filers can describe their structure, policies, and training. |
| Evidence | 25 | 14 | Claims outrun proof. Reports assert commitments far more often than they show numbers, dates, or named documents. |
| Supply-chain depth | 15 | 5 | 52.2% demonstrated tier-1 visibility or nothing at all. Only 7.6% showed real multi-tier work. |
| Remediation | 15 | 5 | 58.7% of filers show no real pathway beyond hoping nothing is found. |
| Effectiveness | 15 | 5 | Exactly 2 reports in 92 measured themselves against their own prior year. |
The pattern is precise. The dimensions that ask a company to describe itself score above half marks. The three dimensions that require a company to actually see, fix, or measure something all sit at exactly one third of the available marks. Reports go quiet precisely where the work would have to exist.
One element deserves its own line. Section 11(3)(e) asks what a company did to remediate the loss of income to the most vulnerable families affected by its own anti-forced-labour measures. 29.3% of filers skipped that element entirely or scored zero on it. The income-loss silence and the tier-2 silence are the same silence: you cannot protect workers you cannot see.
How the grades were built
Rubric v0.1 was built from two sources only: the text of the Fighting Against Forced Labour and Child Labour in Supply Chains Act, and the founder's published 5-Step due diligence methodology. Nothing else went in. No reputation signals, no vendor data, no interviews.
Every score on every dimension is backed by a verbatim quote from the filing it grades. A grade can be traced to the exact passage that earned it, which means every grade is checkable by anyone with registry access. The rubric also flags candor separately from boilerplate, on purpose: 13.0% of filers openly stated they have no program, while only 5.4% of the sample earned the boilerplate flag. People do not confess in writing when they are hiding something. They confess when they are overwhelmed.
And this is not a villain story. Most of these filings were written by capable people who were handed a legal deadline without a diligence system. The grades measure the reports, not the humans behind them. The data does not show a country of bad actors. It shows a country of unread homework, and the reading has now started.
What happens next
The pilot is the first read, and the schedule is public. The full registry grading, all 12,599 reports, runs in fall 2026. The public edition of the S-211 Report Card publishes in April 2027, ahead of the next filing deadline.
That deadline is May 31, 2027. Penalties under the Act run up to $250,000, and directors and officers can face personal liability. The sharper fact is simpler: every report is public forever, and reports are now being read. The next one your company files will be graded.
The full registry grading, first
All 12,599 reports get graded next.
The pilot read 92 filings. The full registry grading runs fall 2026, and the public edition lands April 2027. Leave your email and the full grading reaches you before it goes public. If your company filed under S-211, your report already has a grade coming.
The reading continues between editions in On the Hook, the bi-weekly intelligence briefing for the executive on the hook for their supply chain. One real failure per issue, and the regulation reality behind it.
The program this maps to: Bill S-211 · Report requirements · Forced-labour due diligence