Waiting For Your RSA? Here’s What You Can Do In The Meantime

Congratulations! You have submitted your Retail Store Authorization (RSA) and you are now one step closer to operating your cannabis retail store in Ontario. As applications are processed in the order they are received, and the duration of the review period depends on the complexity of your application, there will definitely be a waiting period. 

Here are five things you can do in the meantime:

• Apply for a Cannabis Retail Manager License

Every cannabis retail store in Ontario must have a licensed retail manager. If you intend to employ on-site cannabis retail managers other than the individuals listed in your RSA application, you must apply for a Cannabis Retail Manager License for these individuals.

The Retail Manager can manage up to five (5) stores and is responsible for the overall operations of the retail store which includes managing store employees, cannabis sales and related compliance issues, and purchasing cannabis for the store. 

As the Retail Manager has a very important role, it is important to only place individuals who meet the eligibility criteria defined by the AGCO. Some examples of these eligibility criteria are an age requirement of 19 years old and above, have not been charged with any offense in any jurisdiction, and completed tax return and tax assessments for the last fiscal year.

• Engage with OCS Client Services

This would be a good time to engage with the Client Services of the Ontario Cannabis Store (OCS) for high-level support for merchandising strategy, build-out of your business plan, and updates on regulatory requirements. The OCS is a crown agency of the Government of Ontario and is the only legal wholesale supplier of cannabis for private retail stores until the end of summer 2021. While you are not yet able to place an order for cannabis inventory, you can start the dialogue with the OCS on product availability. By the end of summer 2021, the “flow-through” program of the OCS will be rolled out which will allow you to order products not stocked in the OCS warehouse. See our blog here for more information on this:

Flow Through Process – Ontario Cannabis Store (OCS)

•  Notify the Public

As a retailer applicant, you are required to notify the public regarding the proposed retail store once you have taken possession of your store. Public Notice provides the municipality and its residents the opportunity to make written submissions to the Registrar as to whether the issuance of the RSA is in the public interest.

There are two steps to public notification.

Step 1 – Posting Period

You will be notified by the AGCO of the dates for the 15-day posting period. During this period, you are required to post the Public Notice placard at the store location in full public view. The Public Notice placard will be emailed by the AGCO in PDF format, and you will be responsible for its printing and posting. Your application will also be searchable on iAGCO, and the AGCO will Tweet about the application.  It is important to post the Public Notice for the required period of time, non-compliance will delay the processing of your application. 

Step 2 – Responding to Written Submissions

Within 10 business days after the last day of the posting period, the AGCO will provide you copies of any submissions from local residents and the municipality regarding your retail store that were received in response to your Public Notice. You have 5 calendar days to provide the Registrar with a response to submissions from local residents and from the municipality. The written submissions and your responses will be considered as your RSA is being processed.

• Participate in Retailer Education

Participation in education sessions will help you keep abreast of the latest information and requirements in operating a compliant and successful retail store, once you receive your RSA. There are two types of education requirements. The first is an education session through the AGCO. An AGCO Compliance Official will schedule an education session that will provide information regarding the cannabis regulatory framework, expectations in relation to the mandated inspections, and additional education requirements. The second is the successful completion of the Cannabis Retail Employee Training Program. This is an AGCO Board-approved training program required for all Licensed Retail Managers, License holders, and store employees. 

• Prepare for the Inspections

There are two inspections to be performed by an AGCO Compliance Official before your RSA is issued and your store is open for business. These are the Pre-Authorization Inspection and the Pre-Store Opening Inspection. 

The Pre-Authorization Inspection is conducted prior to the issuance of your RSA to ensure compliance of your store with AGCO regulations and standards. This inspection is to confirm that all eligibility and store-specific requirements are met. The inspection can be virtual or physical and takes approximately one (1) hour to complete. It is important you understand the Cannabis Licence Act, 2018, its regulations, and the Registrar’s Standards for Cannabis Retail Stores. Compliance Officials will verify that the store is ready to order, receive and appropriately secure cannabis products as required by the regulations, and you have met all the Pre-Authorization Inspection criteria.

The Pre-Store Opening Inspection will be scheduled once your RSA has been issued to confirm that the store is ready for a licensed Retail Operator to open for business and sell cannabis products to the public. Although this inspection will be scheduled when you have your RSA, it is important you have already made the necessary preparations to ensure you have met all the requirements. These requirements include signage, cannabis storage methods, display of authorized seal of authorization, staff, record keeping, sensory display methods, and unauthorized access. Having Standard Operating Procedures available to the AGCO on these requirements would be useful and can ensure the success of your Pre-Store Opening Inspection.

How We Can Help

Cannabis License Experts (CLE) is your solution to preparing, reviewing, and submitting your cannabis retail license application. We offer support from day one of starting your cannabis business, including strategic planning, floor plan preparation, inspections, SOPs, and more. 

Resources

Alcohol and Gaming Commission of Ontario – Cannabis (agco.ca)

Ontario Cannabis Store website (ocs.ca)