Prepare your information for a sale for medical purposes without possession of cannabis licence application
Important: Effective March 12, 2025, Health Canada announced the coming into force of the Regulations Amending Certain Regulations Concerning Cannabis (Streamlining of Requirements). This web page will be updated in the coming months to reflect the amended regulations. You can refer to Summary of changes following the streamlining of regulations for how the changes may impact you.
On this page
- 1.0 For corporations, cooperatives or partnerships
- 2.0 Site details
- 3.0 Identified people
- 4.0 Organizational security plan
- 5.0 Site plan
- 6.0 Floor plan
- 7.0 Record keeping
- 8.0 Key investor reports
- 9.0 Form
This page describes the information you need to prepare before you can submit it in the Cannabis Tracking and Licensing System (CTLS). This page only applies to sale for medical purposes without possession of cannabis licences.
For information on applying for all other licences, refer to Prepare your information: Cultivation, processing and sale for medical purposes with possession licences.
Important: Sale for medical purposes without possession licences do not need to submit information in a site evidence package.
Note: Health Canada recommends using a document naming convention for all the information you have to submit. Following the document naming convention will help us process your application more efficiently.
1.0 For corporations, cooperatives or partnerships
You'll have to create a corporate profile in the CTLS, if you don't already have one, if you're applying for the licence as:
- a corporation
- a cooperative
- a partnership
This section provides the information you need to prepare when you're creating a new corporate profile.
1.1 Parent (owning) corporation
Any controlling corporation is required to create a corporate profile, and directors and officers of that corporation need to apply for security clearances.
You need to gather the CTLS Account IDs of any controlling corporation, if applicable.
Who needs a security clearance
1.2 Certificate of incorporation or business registration document
You need to prepare the following document depending on your organization.
- If you're a corporation: copy of your certificate of incorporation, amalgamation or amendment
- If you're a cooperative or a partnership: copy of your business registration or partnership agreement
- If you want to use another name besides your legal business name, you can request that the other name appear on the licence. For example, Legal corporation name d.b.a. Other name. Some provinces and territories may require that this other name be registered. It is your responsibility to consult the registry of the jurisdiction where you plan to do business on the requirements for registration
1.3 Directors, officers, partners
You need to gather the CTLS Account IDs of all your directors, officers and partners.
2.0 Site details
This section provides information you need to prepare about your site.
Important: If you'll be conducting Health Canada-regulated cannabis activities in First Nations, Inuit or Métis communities, email navigator-navigateur@hc-sc.gc.ca.
2.1 Health Canada licences or authorizations
You need to prepare information about licences, registrations and authorizations issued to the applicant from Health Canada for the same site. This can include information about any:
- cannabis licences, such as:
- research licence
- cannabis drug licence
- industrial hemp licence
- analytical testing licence
- personal or designated production of cannabis for medical purpose
- other specialized licences, such as a site licence for natural health products
For each licence, registration or authorization, submit:
- the name of the licence holder, holder of the authorization or applicant
- the site address
- your licence or registration number, if applicable
- the issuance and expiry date, if applicable
- a description of your activities under that licence or authorization
If the applicant doesn't have any licences, registrations and authorizations issued by Health Canada, indicate this in the document.
2.2 Aerial view
You need to prepare a clear and legible aerial view of the proposed site and surrounding area.
- The aerial view needs to show a 500 metre radius around the site. It needs to be accurate and up-to-date when you submit
- The photos can't have blind spots. You can avoid this by taking the photos straight down at the site
Note: A web mapping service, such as Google Maps, is enough for an aerial view. It needs to show an accurate and up to date proposed site and surrounding 500 metre radius.
2.3 For a site with multiple addresses
If your site has multiple addresses, such as an area that's exclusively used by the applicant with several buildings, prepare a document listing all addresses.
3.0 Identified people
This section provides information you need to prepare about the identified people that you'll need to submit.
3.1 Key site personnel
You need to gather the CTLS Account IDs of all your key site personnel. Include the following personnel.
- Responsible person and alternate
- Head of security and alternate
3.2 Associated individuals
You need to prepare information for the associated individuals, if applicable.
3.2.1 Consent to communicate, reporter and responsible for finance
You need to gather the CTLS Account IDs of the people who will:
- be authorized to communicate with Health Canada about your application (consent to communicate)
- be submitting reports to Health Canada on your activities once you are licensed (reporter)
- be submitting statements of cannabis revenue for the licence holder in the CTLS (responsible for finance)
For reporters and people responsible for finance, you'll need to include them in the list of all associated individuals requiring security clearances.
3.2.2 Associated individuals requiring security clearances, if applicable
You need to prepare a document containing a list of all associated individuals requiring security clearances (including reporters and people responsible for finance), if applicable. Include the following for each person:
- full name
- CTLS account ID
- security clearance application ID
- rationale explaining why they require a security clearance
4.0 Organizational security plan
You need to prepare a copy of your organizational security plan.
Important: The information submitted in the plan and the CTLS needs to be consistent. Discrepancies or inconsistencies can cause a delay in processing your application.
Cannabis organizational security plan
5.0 Site plan
You need to include the following information in your site plan.
- Site perimeter
- Perimeter clearly identified (for example, highlight the fence or building envelope)
- Label what the perimeter is (for example, a fence or a building envelope)
- Buildings
- Footprint of all buildings clearly identified and uniquely labelled
- Indicate if the building is a multi-unit building or a stand-alone site (only the applicant uses this building)
- If it's a multi-unit building, identify the site perimeter and label all units with their current use (such as the occupant's company name)
6.0 Floor plan
Prepare floor plans for each building where the sale of cannabis (without possession) activities will take place. Health Canada will review the floor plans to verify that these areas are exclusively used by the applicant. In each building's floor plan, clearly delineate the rooms (such as office space) where you'll be doing your sales of cannabis.
7.0 Record keeping
This section provides information you need to prepare about record keeping that will need to be submitted.
7.1 Record keeping attestation
You need to fill out a Record keeping attestation.
7.2 Proposed record keeping methods
You need to prepare the following.
- Record keeping methods
- A description of your record keeping methods, such as storing the records electronically in a cloud system or physically in an office
- Medical document verification process
- A description of the medical document verification process, including verification of the information
- Example of registration document
- An example of the registration document that you'll give to clients
- An example of documents used to fill a client's order and refuse to fill a client's order
- Process to limit quantities of 150 g to dried cannabis (or its equivalent amount) per order
- A description of how you'll ensure that the quantity of cannabis, other than plants or seeds, distributed or sold won't exceed 150 g of dried cannabis (or its equivalent amount) per order
Note: To be compliant with the Regulations, your process must verify that the medical document contains the following information:
- health care practitioner's name, business address and phone number
- province where the health care practitioner is authorized to practice and their licence number
- name and date of birth of the patient
- address of the location where the patient consulted with the health care practitioner
- daily quantity of dried cannabis (in grams), authorized by the health care practitioner
- period of use, up to 1 year (number of days, weeks or months)
- signature and date of the health care practitioner and a statement that the information in the medical document is correct and complete
8.0 Key investor reports
You need to prepare either a report or an attestation about key investors. Refer to Cannabis key investors for more information about the requirements for applicants:
- not listed on a published market
- listed on a published market
9.0 Form
You need to complete a Record keeping attestation to complete your licence application.
Page details
- Date modified: