Retail Store Pre-Authorization Inspection

Prior to a CRSA being issued and a cannabis retail store opening for business, the store location will be inspected by an AGCO Inspector to confirm that eligibility and store-specific requirements are met. The first inspection is called a Retail Store Pre-Authorization Inspection, which is conducted prior to a CRSA being issued. The Inspector will be contacting the owner/retail cannabis sales manager to review, in advance, the requirements to ensure the location is ready for this inspection. The following sections provide more information about the inspection process.

What is a Retail Store Pre-Authorization Inspection?

Before a CRSA will be issued, the store location will be inspected by an AGCO Inspector to confirm that eligibility and store-specific requirements are met. During the Pre-Authorization Inspection, AGCO Inspectors will provide you with information about your obligations and responsibilities under the Cannabis Licence Act, 2018, its regulation and the Registrar’s Standards for Cannabis Retail Stores and answer any operational questions and/or concerns you may have related to the retail sale of cannabis. Inspectors will be checking that the store is ready to order, receive and appropriately secure cannabis products as required by the Cannabis Licence Act, 2018, its regulation and the Registrar’s Standards for Cannabis Retail Stores.

Things to know before scheduling a Pre-Authorization Inspection

  • Ensure that you have applied for or hold a CROL and have the application file number or licence number ready.
  • Ensure the complete application, including supporting documents for a CRSA is submitted.
  •  Confirm that all required fees have been paid. Please refer to the AGCO’s Application Fee Schedule for the applicable fee.
  • Review information about your obligations and responsibilities under the Registrar’s Standards for Cannabis Retail Stores, as well as all applicable laws and regulations, including but not limited to,  the federal Cannabis Act and its regulations, the Cannabis Control Act, 2017, the Cannabis Licence Act, 2018, and Ontario Regulation 468/18.
  • Pre-Authorization Inspection criteria, listed below, must be completed before an inspection can be scheduled.

Pre-Authorization Inspection Criteria

An AGCO Inspector will be visiting the retail store to confirm that store specific requirements are met. Store-specific requirements include:

  • Public Notice Process (CLA subsection 4 (7))
    You must post the placard that has been issued via iAGCO email under the public notice process for 15 calendar days. The public notice period does not need to be completed before an inspection can be scheduled (i.e. an inspection can be scheduled as soon as the placard has been posted based your readiness for the store to be inspected).
  • Location (AGCO application requirement)  
    The address written on the CRSA application must match the physical address of the store.
  • Product Visibility (AGCO Registrar Standard 2.5
    Once cannabis products and accessories are on site, they cannot be seen from the outside of the store (i.e. some retail store operators may choose to use tinted glass or frosted windows to ensure products and accessories are not visible from outside of the store). During the pre-authorization inspection, you will be required to demonstrate how you meet this requirement.
  • Video Surveillance System (AGCO Registrar Standard 2.1)
    A secure, high-resolution surveillance system must be in working order at all times. During the pre-authorization inspection, you will be required to demonstrate that you have a video surveillance system in place that includes the following minimum requirements:
    1. Cameras and lighting must be positioned to clearly capture 24-hour coverage of the interior of the premises and immediately outside the premises, including the:
      1. Entrances and exits, including where IDs are checked
      2. Pick up area(s) for cannabis purchased online or by telephone
      3. Point of sale area(s)
      4. Receiving area(s)
      5. Sales floor area(s)
      6. Cannabis storage area(s).
    2. Video recordings must be made and retained for a minimum of 30 days and be made available to the AGCO upon request;
    3. The licensee must ensure that the surveillance system is functioning properly at all times.
  • Storage (AGCO Registrar Standard 2.2)
    Operators must be able to demonstrate and confirm that all cannabis products will be stored securely at all times and only be available to staff from the time the product arrives at the store to point of sale, destruction, or return to Ontario Cannabis Retail Corporation (OCRC) or Licensed Producer.
  • Other Businesses (Ontario Regulation 468/18, section 9)

    The store must be enclosed by walls and separated from any other commercial establishment or activity and from any outdoor area. The store cannot be entered from or passed through in order to access any other commercial establishment, other than a common area of an enclosed shopping mall (note: this does not apply to spaces shared with other commercial establishments that are only accessible to employees of either business or other non-customers permitted by either business, as long as the entryway to the cannabis store is secured to prevent unauthorized access).

  • Store Management (CLA 5(1), CLA 25 (1), AGCO Registrar Standard 1.2 and 1.3)
    Each store must have a CROL holder or a CRML holder managing the store. CROL holders or CRML holders may be responsible for up to five (5) stores at a time. You may be asked to provide your licence upon request.
  • Preventing Unauthorized Access (AGCO Registrar Standard 2.4)
    All entry points to the store, including doors and windows, must be secure and protected against unauthorized access.
  • Preventing Entry of Minors (Ontario Regulation 468/18 s. 20)
    A description of the measures the CROL holder will undertake to ensure that patrons who look under 25 years of age are not permitted to enter the cannabis retail store unless they provide a valid piece of identification proving that they are at least 19 years of age.
  • Record Keeping Requirements (AGCO Registrar Standard 8.1)
    Licensees must ensure that the following records are maintained, retained a minimum of three (3) years, or longer as may be required by other laws and regulations, and made available to the AGCO in accordance with the Notification Requirements or upon request:
    1. employee records, including names, addresses, primary job responsibilities, shift schedules, training records, CPIC records check results, and dates of employment
      1. records for all cannabis in the authorized store, including cannabis purchased directly from the OCRC and cannabis transferred from another authorized retail store operated by the Licensed Operator. At a minimum, these records must contain information regarding:
        a.    [Removed: May 2023]
        b.    [Removed: May 2023]
        c.    each sale transaction at the authorized store, online or by telephone, traceable to the employee level
        d.    any cannabis that has been destroyed. Records of any cannabis destroyed must include, at a minimum:
        i.    [Removed: May 2023]
        ii.    [Removed: May 2023]
        iii.    [Removed: May 2023]
        iv.    a certificate of destruction, if destruction is carried out by a third party
        v.    [Removed: May 2023]
        vi.    [Removed: May 2023]
        vii.    the reason for the destruction of the cannabis product
        viii.    the method of destruction.

       3.    [Removed: May 2023] 

       4. records that may be required to support a cannabis product recall

      5.  records demonstrating that the Licensee is complying with sections 7 and 8 of the Cannabis Control Act, 2017, which prohibit sales to persons under             19 years of age and persons who are or appear to be intoxicated.

     6.    [Removed: May 2023]
     7.    [Removed: May 2023]
    8.    Records of the name and address of purchaser and residential address where any cannabis is delivered. [Amended: March 2022]

    9.    Records of the specific authorized store(s) a licensed Retail Manager is accountable for. [New: March 2021]

    10.    When entering into any agreement or accepting any item, benefit or service pursuant to Standard 6.5, a licensee shall maintain the following records               [New: June 2022]:
            a.    Copy of the complete agreement
            b.    Description of the item, benefit or service
            c.    Date of receipt of item, benefit or service
            d.    Name of licensed producer and representative and 
           e.    Fair market value of the item, benefit or service

How to schedule a Pre-Authorization Inspection

Once the complete CRSA application has been submitted, notify the AGCO that the retail store has met all of the store specific requirements and is ready for an inspection. The AGCO Inspector will contact you to set up an appointment. As the applicant, you must be present at the retail store during the inspection.

Once all eligibility and store specific requirements are met, a CRSA will be issued which may include certain terms and conditions, which the licensed Retail Operator must comply with before the store is open to the public.

Retail Store Ongoing Inspection

AGCO Inspectors may visit the retail store location at any time to confirm compliance with the Cannabis Licence Act, 2018 and regulation and Registrar’s Standards for Cannabis Retail Stores. You must allow the inspection, and you must not interfere with the AGCO Inspector, refuse to answer questions related to the inspection, or provide false information. 

When conducting an inspection, an AGCO Inspector may:

  • ask you for and look at records that are relevant to the inspection
  • take records away from the store to review, examine, test or copy. In this case, the Inspector will give you a receipt confirming which records have been taken.
  • After the Inspector has taken the records, you can request that the records be made available to you
  • The records will be returned to you in a reasonable time, unless the records cannot be returned because of the testing done.
  • take photographs or other recordings
  • ask about financial transactions, records or other matters relevant to the inspection.

If an Inspector asks you for a record, you must provide it. You must also help the Inspector understand the record or provide it in a readable form.

AGCO Inspectors will also confirm the following:

  • Outdoor Store Signage (CA s. 18, Registrar's Standard 6.1 and Standard 6.2)
    Signage must identify the business on the outside of the authorized store. Advertising may not:
    • appeal to or target persons under 19 years of age
    • promote cannabis or cannabis accessories in a way that is false, misleading, or deceptive
    • suggest or imply, directly, indirectly, or by use of endorsements of testimonials, that consumption of cannabis is associated with success, enjoyment of an activity, fulfillment of a goal, or the resolution of a problem
    • be associated with medicine, health, or pharmaceuticals
    • depict or suggest the illegal sale of cannabis
    • associate consumption of cannabis with driving a motorized vehicle, or with any activity that requires care and skill or has elements of danger
  • Provincial Cannabis Retail Seal  (Ontario Regulation 468/18, section 19)
    You must display the provincial cannabis retail seal in a place that is visible from the exterior of the public entrance to the cannabis retail store. The retail seal must be least 17 centimetres in width at its widest point by 20 centimetres in height. Either the French version, the English version or both versions of the cannabis retail seal may be displayed. You will be provided access to download the seal once your CRSA application is approved.
  • Interior Store Signage (CA s. 17)
    You may promote cannabis and cannabis accessories at the point of sale only if:
    • The promotion is limited to factual information about:
      1. Cannabis or a cannabis accessory and its characteristics
      2. A service related to cannabis
      3. The availability or price of cannabis, cannabis accessories, or a service related to cannabis.
    • The promotion focuses on brand characteristics of cannabis or cannabis accessories
  • Storage (AGCO Registrar Standard 2.2)
    All products must be stored securely at all times and only be available to staff from the time the product arrives at the store to point of sale, destruction, or return to OCRC or Licensed Producer.
  • Authorized Products (CLA s. 18, Ontario Regulation 468/18 s. 18)
    You may only sell cannabis products purchased from the OCRC in the packaging which it was purchased from the OCRC. Cannabis accessories and shopping bags do not need to be purchased from the OCRC.
  • Staff (CLA s. 23, CLA s. 5(4), Ontario Regulation 468/18 s. 21)
    All staff employed to work before the cannabis retail store is open as well as after the store is open to the public, must be 19 years of age or older. Licensees must obtain criminal background checks from employees as part of the hiring process, as well as ensure that all employees:
    • act in accordance with the law and demonstrate honesty and integrity
    • have completed any required training, including AGCO Board-approved training, prior to their first scheduled shift.
  • AGCO Authorization (Ontario Regulation 468/18, s. 13)
    You must display the AGCO Cannabis Retail Store Authorization in a visible place to patrons in the retail store.
  • Sensory Display Containers (Standard 2.6)
    You may use sensory display containers to allow patrons to see and smell cannabis products. Display containers must be locked and tamper-proof to prevent patrons from touching the products, and must not be able to be removed from the premises.
    This requirement can be met during the pre-opening inspection or during the on-going inspection phase once you decide to use sensory display containers.
  • Responsible Use (AGCO Registrar Standard 7.1)
    Information related to the responsible use of cannabis must be made available to patrons. At a minimum, you must make the Health Canada Consumer Information – Cannabis document available to patrons. 
  • Retail Store Staff Education (Ontario Regulation 468/18, s.21)
    Retail store staff including holders of CRSA, cannabis retail manager licensees and staff employed at the retail store (including those completing deliveries and individuals providing security services) must complete an AGCO Board-approved training program prior to their first day of work to support the safe sale, and consumption of cannabis. 

•    Point-of-Sale System (Standard 8.6)
      Retailers must have a POS system that is configured and integrated with the automated POS Data Reporting Platform.