The introduction of the Affiliate Delivery Licence (ADL) represents one of the most significant changes to Ontario's liquor delivery framework since grocery and convenience stores entered the retail alcohol marketplace. Effective July 1, 2026, the new licence creates a dedicated regulatory pathway for affiliated delivery businesses to deliver liquor on behalf of eligible grocery store and convenience store retailers while complying with the Liquor Licence and Control Act, 2019 (LLCA), Ontario Regulation 746/21, and the Registrar's Standards.
At Substance Law, we assist businesses throughout Ontario with obtaining, maintaining, and complying with Affiliate Delivery Licences issued by the Alcohol and Gaming Commission of Ontario (AGCO). Whether you are launching a delivery platform, expanding an existing grocery delivery operation, or restructuring a corporate group to qualify as an affiliate, we provide practical legal advice throughout the licensing process.
What is an Affiliate Delivery Licence?
The Affiliate Delivery Licence is a new class of AGCO delivery licence created effective July 1, 2026. Unlike the General Delivery Licence, which allows independent delivery companies to deliver liquor from various authorized sources, an Affiliate Delivery Licence is available only to delivery businesses that are affiliated with an eligible grocery store licensee or qualifying convenience store licensee.
The licence permits the holder to:
- deliver liquor purchased from its affiliated retailer;
- take and solicit orders for the sale of liquor for delivery;
- hold liquor inventory on behalf of affiliated retailers for later purchase once customer orders are placed; and
- operate as the customer's delivery agent within the limits established by Ontario law.
Who Can Apply?
Not every delivery company qualifies.
Applicants must be affiliated with:
- a Grocery Store Licensee; or
- an eligible Convenience Store Licensee.
Where the affiliated retailer is a convenience store, the convenience store licensee must hold at least 20 Convenience Store Licences, either directly or together with its affiliates.
Applicants must also operate a business consisting primarily of:
- delivery of products available from grocery stores; or
- the sale and delivery of products available from grocery stores or convenience stores,
depending upon the affiliated retailer.
What Does “Affiliate” Mean?
The concept of an affiliate is specifically defined for these purposes.
Generally, affiliation includes:
- corporations under common control;
- parent and subsidiary corporations;
- corporations controlled by the same persons;
- members of the same partnership; and
- participants in the same joint venture.
Whether two businesses qualify as affiliates should be reviewed carefully before an application is submitted, particularly where ownership structures involve holding companies, investment funds, franchise arrangements, or complex corporate groups.
How the Affiliate Delivery Model Works
The Affiliate Delivery Licence creates a different business model than the existing General Delivery Licence.
An Affiliate Delivery Licensee may:
- accept customer orders;
- purchase liquor only after the customer places an order;
- obtain liquor exclusively from the affiliated grocery or convenience store;
- deliver liquor from the affiliated retail location; or
- deliver liquor from inventory that the Affiliate Delivery Licensee is holding on behalf of affiliated retailers.
Importantly, liquor cannot be purchased before the customer places an order, preserving the legal retail sale structure established by the LLCA.
Holding Inventory on Behalf of Retailers
One of the most significant changes introduced with the Affiliate Delivery Licence is the ability for the delivery business to hold liquor inventory on behalf of affiliated retail stores.
This creates operational flexibility for larger grocery and convenience chains by allowing fulfillment from centralized locations while maintaining regulatory oversight.
Businesses using warehouse or distribution centre models should ensure that their inventory management, ownership structure, and order processing systems comply with both Ontario Regulation 746/21 and the Registrar's Standards.
Distribution Centres and Warehouses
The 2026 amendments also permit grocery stores—and qualifying convenience store groups—to fulfill liquor deliveries directly from distribution centres or warehouses storing liquor on behalf of licensed retailers.
These permissions are accompanied by new Registrar's Standards governing:
- eligibility;
- storage;
- ordering;
- inventory control; and
- delivery procedures.
Businesses implementing centralized fulfilment should ensure their operational systems comply before commencing deliveries.
Operational Compliance Requirements
Affiliate Delivery Licensees remain subject to Ontario's responsible liquor delivery requirements.
Among other things:
- liquor cannot be delivered to minors;
- liquor cannot be delivered to intoxicated persons;
- deliveries may only occur during legally permitted delivery hours;
- identification verification procedures must be maintained;
- staff must receive required training; and
- records must be maintained as required by the Registrar's Standards.
Record Keeping Requirements
The Registrar's Standards impose detailed record keeping obligations on delivery licensees.
Depending upon the delivery model used, businesses may be required to maintain records regarding:
- customer orders;
- delivery confirmations;
- delivery personnel;
- addresses;
- dates and times of delivery;
- liquor purchased;
- inventory movement;
- retailer instructions; and
- confirmations demonstrating compliance with delivery requirements.
Businesses should ensure their delivery software captures all required information and retains records for the prescribed periods.
Storage Requirements
Where liquor is stored away from affiliated retail locations, the Registrar's Standards require liquor to be securely stored and handled in accordance with applicable regulatory requirements.
Businesses using warehouses, dark stores, or distribution centres should ensure that their storage arrangements comply before commencing operations.
Financial Relationship Restrictions
Affiliate Delivery Licensees are also subject to restrictions respecting financial relationships with liquor manufacturers.
These rules are intended to preserve marketplace fairness and prevent anti-competitive arrangements within Ontario's liquor distribution system.
Businesses should obtain legal advice before entering into marketing agreements, exclusive arrangements, or other commercial relationships involving manufacturers.
Our Affiliate Delivery Licence Services
Our firm assists clients with:
- Affiliate Delivery Licence applications
- Corporate affiliation analysis
- Corporate restructuring to satisfy affiliate requirements
- Grocery and convenience store licensing
- Distribution centre compliance
- Registrar's Standards compliance
- Liquor delivery policies and procedures
- Record keeping compliance
- Staff training policies
- Regulatory audits
- AGCO investigations
- Enforcement defence
- Licence transfers and corporate transactions
- Ongoing regulatory compliance advice
Why Work With Substance Law?
Ontario's liquor marketplace continues to evolve rapidly.
The Affiliate Delivery Licence introduces an entirely new operational framework involving affiliated entities, centralized inventory, warehouse fulfilment, and new Registrar's Standards. Businesses should ensure their ownership structures, contracts, logistics systems, and compliance programs are designed before launching operations.
Substance Law assists retailers, delivery companies, technology platforms, and corporate groups throughout Ontario in navigating the evolving liquor regulatory framework.
Frequently Asked Questions about Affiliate Delivery Licences
What is an Affiliate Delivery Licence?
An Affiliate Delivery Licence is an AGCO licence that permits certain businesses affiliated with eligible grocery store or convenience store licensees to deliver liquor and take orders for liquor delivery.
Who can apply for an Affiliate Delivery Licence?
Applicants must be affiliated with a licensed grocery store or an eligible convenience store licensee. Where the affiliation is with a convenience store, the retailer generally must hold at least 20 Convenience Store Licences, directly or together with affiliates.
What is the difference between an Affiliate Delivery Licence and a General Delivery Licence?
A General Delivery Licence allows independent delivery businesses to deliver liquor from various authorized sources. An Affiliate Delivery Licence is limited to affiliated grocery or qualifying convenience store operations and permits inventory to be held on behalf of affiliated retailers.
Can an Affiliate Delivery Licensee hold liquor inventory?
Yes. The new framework permits Affiliate Delivery Licensees to hold liquor inventory on behalf of affiliated retailers, subject to the applicable legislation and Registrar's Standards.
Can liquor be purchased before a customer places an order?
No. The liquor must not be purchased before a customer places an order.
Can deliveries be made from a warehouse?
Yes. Subject to the regulatory requirements, eligible grocery stores and qualifying convenience store groups may fulfil deliveries from approved distribution centres or warehouses.
What records must an Affiliate Delivery Licensee keep?
Businesses must maintain records required under the Registrar's Standards, including customer orders, delivery information, inventory records, and other prescribed documentation.
How long is an Affiliate Delivery Licence valid?
Unlike the General Delivery Licence, which may be issued for two or four years, an Affiliate Delivery Licence is generally valid for one year and must be renewed.
Can Substance Law assist with Affiliate Delivery Licence applications?
Yes. We assist clients with applications, compliance programs, corporate structuring, operational reviews, AGCO regulatory matters, and ongoing liquor law compliance throughout Ontario.
