Health Canada has proposed amendments to the Cannabis Tracking System Order that would reduce the monthly reporting burden on federal cannabis licence holders. Health Canada published the proposal in the Canada Gazette, Part I on September 26, 2026. It would also end federal reporting obligations for provincial and territorial bodies, distributors, and retailers. Comments are open until November 10, 2026.
For your company, this means fewer cannabis classes, fewer data fields, and simpler sales reporting. Health Canada estimates a net benefit of about $133.5 million over 10 years, largely from reduced administrative work. Below, we explain what is changing, who it affects, and how you can take part in the consultation.
Background: Why the Cannabis Tracking System Order Exists
The Cannabis Tracking System Order has been in place since 2018. It sets out what regulated parties must report to Health Canada under the Cannabis Act. Its purpose is to track cannabis through the legal supply chain. In turn, this helps keep legal cannabis out of the illegal market and illegal cannabis out of the legal supply. You can read the current Order on the Justice Laws website.
Today, holders of cultivation, processing, and medical sale licences submit monthly reports through the Cannabis Tracking and Licensing System (CTLS). These reports cover inventory additions and reductions, sales, and related data. Federal licence holders and public provincial and territorial bodies report by the 15th of the following month. Meanwhile, private distributors and retailers report to their provincial or territorial body by the 10th. Licence holders must also keep their records for at least two years.
What the Proposed Amendments Would Change
The proposal is formally titled the Order Amending the Cannabis Tracking System Order (Streamlining of Requirements). For federal licence holders, it would simplify reporting in the following ways:
- The 14 current cannabis classes would drop to 7. For example, the three cannabis extract classes would become one.
- Licence holders would no longer report book value information.
- Health Canada would remove all requirements to report capacity information.
- Certain inventory addition and reduction categories would merge.
- Intra-industry sales, medical sales, and direct-to-consumer shipments would no longer need a provincial or territorial location. However, wholesale sales to distributors and retailers would still report location.
- Licence holders would need to state a reason whenever they use the “any other reason that the holder specifies” category.
- Separate reporting of industrial hemp quantities would end.
In addition, the proposal would repeal the reporting requirements for public provincial and territorial bodies and for authorized private distributors and retailers. Provinces and territories would still oversee cannabis within their own jurisdictions. These changes build on earlier efforts to reduce regulatory burden, including the 2025 amendments to the Cannabis Regulations and the proposed changes to industrial hemp regulations.
Who Is Affected and How
The changes would affect about 846 federal licence holders, and Health Canada estimates that 86% of them are small businesses. If your company holds a cultivation, processing, or medical sale licence, your monthly CTLS reports would become shorter and simpler. However, Health Canada does expect some one-time costs as licence holders adjust their reporting systems.
The 13 public provincial and territorial bodies and about 3,465 authorized private distributors and retailers would see an even bigger change. Their reporting obligations under the Order would end entirely, although provincial and territorial rules would still apply. If you operate in retail, our provincial cannabis retail licensing team can help you understand how this fits with your provincial requirements.
The Consultation Process
The comment period runs for 45 days from the September 26 publication date and closes on November 10, 2026. Health Canada is seeking input from current and potential licence holders, industry associations, provinces, territories, and municipalities. It is also seeking input from First Nations, Inuit, and Métis organizations, as well as authorized distributors and retailers.
Health Canada strongly encourages stakeholders to use the online commenting feature on the Canada Gazette website. Each section of the proposed Order has its own comment field. Alternatively, you can send comments by email to cannabis.consultation@hc-sc.gc.ca. Comments submitted through the Canada Gazette are posted publicly after the consultation closes.
For background and contact details, visit Health Canada’s Cannabis Tracking System Order consultation page.
What This Means for Your Business
For most federal licence holders, this proposal is good news. Fewer classes and fewer data fields mean less time spent preparing monthly CTLS reports. Because the federal changes would not take effect until January 1, 2028, you also have time to plan the transition.
In the meantime, it helps to map your current reporting process against the proposed changes. For example, review how your inventory system assigns cannabis classes and where your book value and capacity data come from. Also check how often you use the “other reason” category. This review will show you where your templates, software, and standard operating procedures may need updates.
The consultation is also your chance to flag practical issues. If a proposed change would create problems for your operations, a specific comment with real examples gives Health Canada useful evidence to work with. For instance, you could explain how the merged classes fit your product mix.
Our team supports licence holders with ongoing reporting and compliance through our cannabis post-licensing compliance support. If you are still applying, our federal cannabis licensing team can help you build reporting processes around the proposed framework from the start.
Frequently Asked Questions
Do the proposed Cannabis Tracking System Order amendments change what data licence holders must submit to Health Canada?
Yes. Federal licence holders would report on 7 cannabis classes instead of 14. They would also stop reporting book value, capacity information, and separate industrial hemp quantities. In addition, some inventory categories would merge, and several sale types would no longer need a provincial or territorial location. If finalized, these changes would take effect on January 1, 2028.
Are cannabis analytical testing laboratories subject to the Cannabis Tracking System Order?
No. Analytical testing licence holders are not reporting parties under the Order, and neither are holders of industrial hemp or research licences. Testing labs do appear in the proposed text, but only as recipients of intra-industry sales that federal licence holders report. Labs have their own updates to follow, such as Health Canada's new guidance on validating analytical methods for cannabis testing.
How can a licence holder participate in the Health Canada consultation on the proposed Cannabis Tracking System Order amendments?
You can comment through the online feature on the Canada Gazette website, which Health Canada strongly encourages. You can also email cannabis.consultation@hc-sc.gc.ca. The deadline is November 10, 2026. Comments that reference specific sections of the proposed Order and explain the operational impact give Health Canada the clearest picture.
Key Takeaways
- Health Canada published proposed amendments to the Cannabis Tracking System Order in the Canada Gazette, Part I, on September 26, 2026.
- Federal licence holders would report on 7 cannabis classes instead of 14, with no book value, capacity, or separate industrial hemp reporting.
- Reporting obligations for public provincial and territorial bodies and for authorized private distributors and retailers would end.
- Changes for federal licence holders would take effect on January 1, 2028, with an estimated net benefit of about $133.5 million over 10 years.
- Comments are open until November 10, 2026, through the Canada Gazette website or by email.
Taking the Next Step
The proposed Cannabis Tracking System Order amendments would make monthly reporting simpler for federal licence holders and end it for distributors and retailers. Reviewing the proposal now helps you plan system updates and decide whether to comment before the consultation closes. If you would like support assessing how the changes affect your licence or preparing a consultation comment, reach out to our team.
