When the AGCO Takes Action Against Your Cannabis Licence
The Cannabis Licence Act, 2018 (CLA) creates three related authorizations: a retail operator licence for the business, a retail store authorization for each store, and a cannabis retail manager licence for individuals who manage stores (CLA, ss. 3–5, 25). Action against one can affect the others.
Illustrative example, not an actual AGCO notice
“Take notice that the Registrar proposes to revoke the retail store authorization for the store named below, for the reasons set out in this notice. You may request a hearing by the Licence Appeal Tribunal by mailing or delivering a written request to the Tribunal and the Registrar no later than 15 days after being served with this notice.”
Who Investigates and Who Decides
- Regulator
- The Registrar of the AGCO, under the CLA, the Alcohol and Gaming Commission of Ontario Act, 2019, and the Registrar’s standards and requirements on premises, security, advertising, training and asset protection (CLA, s. 26).
- Who investigates
- AGCO inspectors (ss. 27–28).
- Who decides
- The Registrar proposes or takes action. On a hearing, the Licence Appeal Tribunal may confirm or set aside the Registrar’s proposal or decision, substitute its own opinion, direct the Registrar to act, and attach terms or conditions (s. 15).
- Further appeal
- An appeal from the LAT to the Divisional Court on cannabis licensing matters is available on a question of law only (Licence Appeal Tribunal Act, 1999, s. 11(2)–(3)).
Common Issues in Cannabis Retail Enforcement
Sales to minors and ID checks
Failures in age verification and admitting minors.
Unlawful product
Selling cannabis not purchased from the Ontario Cannabis Retail Corporation. Certain convictions trigger mandatory revocation (s. 11(3)).
Security and inventory
Surveillance, record keeping, and inventory discrepancies under the Registrar’s standards.
Advertising and promotion
Promotional activity that breaches the standards and requirements.
Managers and ownership
Using unlicensed managers (s. 25), and ownership or eligibility concerns about the people behind the licence.
What Can Happen Next
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Monetary penalty
The Registrar can impose a monetary penalty from the AGCO’s schedule. You can appeal by serving a written request on the Tribunal and the Registrar within 15 days after the notice is served (AGCO Act, 2019, s. 14(7)).
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Notice of Proposal
The Registrar may propose to revoke or suspend a licence or authorization on reasonable grounds of non-compliance, or on an eligibility ground (CLA, s. 11(1)), and must serve notice with written reasons (s. 14(1)).
Deadline
You may request a LAT hearing by mailing or delivering a written request to the Tribunal and the Registrar no later than 15 days after being served (CLA, s. 14(2)). If you do not, the Registrar may carry out the proposal (s. 14(4)).
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Suspension or revocation without a proposal
The Registrar may suspend a licence or authorization without a proposal if necessary in the public interest. The Registrar must revoke it without a proposal if the holder or another prescribed person is convicted of specified offences under the Cannabis Control Act, 2017 or the federal Cannabis Act (CLA, s. 11(2)–(3)). Either takes effect on service, and you may request a LAT hearing within 15 days after service (s. 11(4)–(5)).
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Knock-on effects
If the retail operator licence is revoked or suspended, all of that operator’s store authorizations are revoked or suspended too. If one store authorization is revoked or suspended, the Registrar may, without a proposal, act against the operator’s other stores or its operator licence (CLA, s. 12).
Checklist: Responding to the AGCO
Documents to gather
- The notice, proposal, suspension or penalty, and proof of service date
- Purchase records showing product came from the Ontario Cannabis Retail Corporation
- Inventory reconciliation, surveillance footage and incident logs
- ID-check procedures and staff training records
- Licences for all managers working at the store
- Corporate and ownership records for the operator
Details to check in the notice
- Which licence or authorization is affected, and whether others are at risk under s. 12
- Whether action was taken with or without a proposal
- The service date and your 15-day window
- Both recipients of your request: the Tribunal and the Registrar
Rules and resources to consult
- Cannabis Licence Act, 2018, ss. 3–5, 11–15 and 25–28
- Alcohol and Gaming Commission of Ontario Act, 2019, s. 14
- Registrar’s Standards for Cannabis Retail Stores and the monetary penalty schedule
- Licence Appeal Tribunal – General Service forms, rules and practice directions
Frequently Asked Questions
If one store has a problem, can the AGCO act against all our stores?
Yes. Under s. 12, revoking or suspending one store authorization allows the Registrar, without a proposal, to act against the operator’s other stores or its operator licence. Revoking or suspending the operator licence automatically affects every store.
Is revocation automatic after a conviction?
For the offences listed in s. 11(3), the Registrar must revoke without a proposal. You can still request a LAT hearing within 15 days after service (s. 11(5)).
Can we appeal the Tribunal’s decision?
Only on a question of law, to the Divisional Court (LAT Act, s. 11(3)).
Sources
Statutory references are to the provisions listed below, as consolidated on e-Laws when this page was prepared.
- Cannabis Licence Act, 2018, S.O. 2018, c. 12, Sched. 2, ss. 3–5, 11–16, 25–28 — e-Laws consolidation period beginning May 12, 2025; checked November 10, 2026.
- Alcohol and Gaming Commission of Ontario Act, 2019, s. 14 — Checked November 10, 2026.
- Licence Appeal Tribunal Act, 1999, s. 11(2)–(3) — Checked November 10, 2026.