Federal Employers: Your Annual Safety Reports Are Due March 1
If you're federally regulated, you have reporting obligations most provincial employers don't. And the deadline is coming up fast.
Who This Applies To
You're federally regulated if your business falls under the Canada Labour Code. This includes:
- Banking
- Telecommunications
- Broadcasting
- Inter-provincial transportation (trucking, rail, marine, air)
- Pipelines
- First Nations band councils
- Grain elevators
- Uranium mining
- Federal Crown corporations
If you're not sure, check your jurisdiction. The rules are different at the federal level.
The Two Reports
Federally regulated employers must submit two annual reports to the Labour Program by March 1 each year:
1. Hazardous Occurrence Report
Covers all work-related:
- Fatalities
- Disabling injuries
- Near misses with serious injury potential
- Structural failures
- Fires, explosions, electrical contact
- Dangerous substance releases
2. Harassment and Violence Report
Covers all workplace harassment and violence occurrences, including those resolved through negotiated resolution or conciliation.
The Part Everyone Misses
You must submit these reports even if you had zero incidents.
This catches a lot of employers. No incidents doesn't mean no report. You still need to file a "nil" report confirming you had nothing to report.
Failure to submit is a compliance violation.
No incidents doesn't mean no report. You still need to file a "nil" report — and failure to submit is a compliance violation.
What's Coming
The Labour Program has announced they're reviewing administrative monetary penalties to ensure they effectively deter violations. Penalty amounts are being evaluated for both labour standards and occupational health and safety violations.
Translation: fines are likely going up, and enforcement is likely increasing.
Other Federal Changes to Watch
- Right to Disconnect: New requirements under the Canada Labour Code amendments for policies on disconnecting from work-related communications after hours
- Replacement Workers: Bill C-58 bans use of replacement workers during strikes or lockouts (in force June 2025)
- Wage Theft Penalties: Increased penalties for wage violations under review
Federal Compliance Support for Canada Labour Code Employers
We help federally regulated employers meet their Part II obligations — from annual reporting to WPHSC requirements and harassment prevention programs.
Book a Consultation →How to Submit Your Annual Reports
Both annual reports are submitted through the Government of Canada's Labour Program online portal at labour-travail.canada.ca. You will need a My Service Canada Account (MSCA) or a GCKey to log in. If your organization has never submitted before, allow extra time to set up access — the account creation process can take several days to complete, especially if identity verification is required.
The Hazardous Occurrence Report requires you to report aggregate numbers for each category of occurrence (fatalities, disabling injuries, near misses, etc.) for the previous calendar year. You are not required to attach individual investigation reports, but those must be maintained internally and available for inspection upon request. Keep investigation records for at least ten years.
The Harassment and Violence Report similarly requires aggregate data — the number of occurrences that occurred during the year and how they were resolved (through the early resolution process, negotiated resolution, conciliation, or investigation). Individual complainant information is not submitted to the Labour Programme, but your internal records must be sufficient to support the aggregate figures you report.
Canada Labour Code Part II Compliance: The Bigger Picture
The annual reports are just one element of a federally regulated employer's obligations under Canada Labour Code Part II. If an inspection is triggered — either by complaint or as part of a proactive Labour Program blitz — inspectors will look well beyond the reports themselves.
Key elements they assess include: whether you have a functioning Work Place Health and Safety Committee (WPHSC) with equal employer and worker representation, whether the committee meets at least quarterly, and whether meeting minutes are maintained. For workplaces with fewer than 20 employees, a health and safety representative is required instead of a committee.
Inspectors also assess whether your Workplace Harassment and Violence Prevention Policy has been reviewed and updated within the past three years and whether you have completed a Workplace Assessment to identify risk factors for harassment and violence. The assessment must be done jointly with the WPHSC or representative and must be documented. Many federally regulated employers, particularly smaller ones in trucking or First Nations governance, miss this requirement entirely.
Many federally regulated employers in trucking and First Nations governance miss the Workplace Assessment requirement entirely — and it's one of the first things inspectors check.
Consequence of Non-Compliance
Missing the March 1 reporting deadline or submitting incomplete reports is not a minor administrative matter. Under Canada Labour Code Part II, the Labour Program can issue compliance orders and, under recently expanded administrative monetary penalty authority, financial penalties for reporting failures.
More significantly, late or missed reports create a paper trail of non-compliance that can be used against you in any subsequent enforcement action. If an incident occurs after you missed a reporting deadline, regulators will have documented evidence that your compliance systems were not functioning — which directly undermines any due diligence defence.
The federal government has also signalled through 2024 and 2025 budget announcements that Labour Program enforcement resources are increasing. The days of treating federal OHS compliance as low-risk are behind us. Treat the March 1 deadline with the same urgency you would apply to a CRA tax filing.
Building Year-Round Reporting Readiness
The employers who submit their March 1 reports without scrambling are the ones who track incidents and harassment occurrences in real time throughout the year, not the ones who try to reconstruct the year's events in February. Build a simple tracking system — even a spreadsheet is adequate for most employers — that captures every hazardous occurrence as it happens, including the outcome and any subsequent investigation.
For harassment and violence, maintain a confidential log of every occurrence reported, even those resolved informally. Workers who report harassment informally to a supervisor must have those discussions documented, the resolution tracked, and the outcome recorded. This protects both parties and makes end-of-year reporting straightforward. Review this log with your WPHSC each quarter so there are no surprises when you file.
The employers who submit without scrambling track incidents in real time throughout the year — not those who reconstruct February in a panic.
Action Items
- Confirm your jurisdiction. If you're federally regulated, these requirements apply.
- Compile your 2025 incident data. Even if it's zero, you need documentation.
- Submit by March 1. Don't miss the deadline.
- Review your harassment and violence policy. Ensure it meets current Part II requirements. Our safety consulting team can assist with compliance reviews.
