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Cannabis key investors record keeping: Cultivation, processing and sale for medical purposes licences

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Important: Make sure you need to keep records on your key investors before reading this page. Record-keeping is not required for organizations if either:

  • their equity securities are listed on a published market
  • they're fully owned by an organization (or that organization's subsidiaries) whose equity securities, or class of them, are listed on a published market

For applicants

Even though you're not required to keep records, as an applicant, you should get familiar with what the records need to include if you become a licence holder. Setting up your records according to the requirements for licence holders will make it easier to fill out your Key investor report when you're applying for your licence.

For licence holders

You're required to keep records on your key investors as set out by section 241 of the Cannabis Regulations.

Your records need to be:

  • kept up to date
  • available at the specified site on your licence
  • kept for at least 2 years after you're no longer required to maintain them, for example when:
    • your licence is revoked
    • your licence expires
    • your equity securities become listed on a published market

Health Canada can ask to see your records at any time and during inspections.

What to include

Important: Never delete any information from your records. When you update it, simply indicate the date beside the new information. For example, if a previous key investor is no longer a key investor, keep them in your record; the information can't be deleted.

The information you're required to keep will be used in your Key investor report. Refer to the Key investor reporting form for the information you need to keep and report.

Consider the information you'll require in the key investor report when creating your records.

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2025-05-15

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