The passage of Canada’s Bill C-69 in June 2019 marked a profound change in how resource projects, notably pipelines and mines, would be evaluated and monitored from both environmental and social perspectives. The introduction of the Impact Assessment Act under this bill signaled a shift—not merely in procedural requirements, but in the expectations placed on project developers concerning transparency across entire supply chains. What this means in practical terms is still unfolding. Nonetheless, developers have had to reassess their strategies and reporting practices in ways that, frankly, were not imagined when the bill was first debated.
At its core, the new framework brings supply-chain visibility to the forefront, making it inseparable from broader impact assessments. This presents both logistical and political complexities. Developers are no longer able to isolate environmental impact statements from supplier mapping or from the broader socio-economic considerations that accompany large-scale projects. The need to disclose supplier networks, sourcing plans, and logistical routes with greater precision has become intertwined with consultations, especially with Indigenous communities whose lands and interests are directly or indirectly affected. For some firms, this is familiar territory, but for many others, particularly mid-tier operators and new entrants, the depth of disclosure now expected can feel, in all honesty, overwhelming.
The use of open data, especially from platforms like GeoBase, offers at least part of the solution. GeoBase provides reliable, up-to-date spatial data that allows developers to map both existing and proposed supply routes in relation to Indigenous lands. It’s a tool that, while not new, has taken on heightened significance under the new legislation. A well-constructed map that accurately overlays proposed supply chains with territorial boundaries and culturally significant sites can serve as both a planning aid and a transparency mechanism. But the technical work involved is rarely trivial. Aligning internal logistics data—often held in disparate systems—with standardized geographic datasets requires a level of precision that leaves little room for error. And when errors do occur, as they inevitably will in complex projects, the consequences can range from community distrust to regulatory delays that ripple across entire investment timelines.
Project developers are finding themselves in unfamiliar discussions, not just about where and how goods will be sourced and transported, but about how those choices intersect with commitments to reconciliation and community partnership. The act’s emphasis on cumulative effects and socio-economic considerations ensures that supply chain decisions—down to the selection of subcontractors and material suppliers—are now subject to a degree of scrutiny that some might argue is both overdue and challenging. There is no single playbook for navigating this new environment. Much depends on the specific project context, the regions involved, and the histories of engagement with affected communities.
In this setting, firms are increasingly adopting annual Indigenous consultation and supply-chain logs as part of their standard reporting suite. These documents, typically published on corporate websites or filed directly with regulators, aim to provide a consolidated account of engagement activities, supply route planning, and measures taken to mitigate adverse impacts. A functional template for such a log might include a record of consultation meetings, feedback received from Indigenous representatives, adjustments made to supply-chain plans in response to that feedback, and status updates on outstanding concerns or commitments. To be clear, the process of compiling and maintaining such logs is rarely straightforward. Information often comes from multiple departments, external consultants, and community liaisons. The risk of inconsistencies or omissions, therefore, looms large, underscoring the importance of establishing clear internal protocols for data gathering and validation.
There’s an emerging view among developers and policymakers alike that supply chain transparency under Bill C-69 is as much about trust-building as it is about regulatory compliance. The act provides a formal framework, certainly, but the substance of that framework is shaped in no small part by the quality of relationships forged on the ground. Some firms have responded with innovative approaches, using digital platforms to share mapping data directly with Indigenous communities and inviting collaborative input on route selection and risk mitigation measures. Others have taken a more cautious stance, perhaps wary of overpromising or of exposing proprietary information. The tension between openness and commercial sensitivity is real, and it is unlikely to dissipate entirely.
What has become clear is that the demands of Bill C-69 require sustained attention to supply chain governance well beyond the initial project approval phase. Supply routes change, suppliers shift, and community priorities evolve. An annual log, then, is not merely an administrative exercise; it is part of an ongoing dialogue that must adapt over time. How well firms navigate this reality may, ultimately, determine both their regulatory success and their social license to operate.
Against this backdrop, many project developers are beginning to invest in internal capabilities that were previously seen as ancillary—GIS specialists, community engagement officers with supply-chain expertise, and legal advisors versed in both Indigenous law and procurement strategy. These shifts, while perhaps incremental at first, suggest a broader recalibration of how supply chains are conceived and managed in the context of Canada’s resource economy. The Impact Assessment Act, in that sense, has done more than reshape regulatory procedures. It has forced a reconsideration of what responsible supply-chain management looks like in the 21st century.