Buying or selling a pharmacy: the narcotic handover count
Count every narcotic and controlled drug on the handover day, and sign the count. It is the line between the outgoing owner’s records and the new owner’s.
The checklist
- Count on the handover day: every narcotic, controlled drug, benzodiazepine and other targeted substance on hand.
- Write down each drug’s full packages, part packages and total units. The free periodic inventory form has those columns.
- Sign and date the count.
- File it with the pharmacy’s controlled-substance records.
- Check whether your province names this count, below.
The provinces that name it
Alberta and Saskatchewan name a change of owner:
- Alberta: the Alberta College of Pharmacy’s standard asks for an audit of the perpetual inventory each time the proprietor or licensee changes (s. 4.4.1(b)(ii)(B)).
- Saskatchewan: when a pharmacy changes owner, the Saskatchewan College of Pharmacy Professionals’ guidelines ask for an inventory of narcotic and controlled drugs, benzodiazepines and targeted substances included, signed and dated by a pharmacist.
These name a change of the person in charge of the pharmacy instead. If the sale brings a new one, their rule asks for a count too:
- British Columbia: after a change in the pharmacy’s manager.
- Manitoba: after a change in pharmacy manager.
- Newfoundland and Labrador: when the pharmacist-in-charge changes.
- Nova Scotia: right away when the pharmacy manager changes.
- Prince Edward Island: whenever the pharmacy manager changes.
The records stay with the pharmacy
Federally, controlled-substance records must be accessible at the pharmacy where they were recorded (Controlled Substances Regulations s. 124).
Our suggestion: file the handover count with them, so the first count after the sale has a checked opening number.
NarcCount
NarcCount dates and locks every signed count, and in the provinces above it asks for this count when you record the change in Settings.
This guide is general information, not legal or professional advice. For the authoritative requirements, refer to your province’s pharmacy regulator and Health Canada.
Sources
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- Alberta College of Pharmacy, Standards for the Operation of Licensed Pharmacies s. 4.4.1 — in force February 1, 2025 — Alberta: a licensee must “ensure adequate procedures are in place to identify theft, loss, or diversion of controlled substances, including … (ii) a documented audit of the perpetual inventories to verify accuracy (A) at least every three months, and (B) each time there is a change in proprietor or licensee”. The same list ends with “(v) reporting any loss or theft of controlled substances to Health Canada within 10 days of discovery”.
- Saskatchewan College of Pharmacy Professionals, Pharmacy Ownership (Proprietor Name Change) Guidelines (March 2026) — The Saskatchewan College of Pharmacy Professionals, on a change of owner: “Record inventory of Narcotic and Controlled Drugs (includes Benzodiazepines and Targeted Substances)”, with the “Inventory list to be signed and dated by a pharmacist”.
- College of Pharmacists of British Columbia, PODSA Bylaws s. 23.8 and s. 18(2)(t) — version 2026.1, April 1, 2026 — In British Columbia, the PODSA Bylaws require physical inventory counts and reconciliations for each narcotic drug “(a) at a minimum of every three months, (b) after a change in the pharmacy's manager, (c) after a break and enter or robbery, (d) after an identified drug diversion, (e) when a pharmacy closes and ceases to operate its business” (s. 23.8(6)); the count “must not be conducted by the same person who enters narcotic purchases into the records” (s. 23.8(7)(c)); and the completion of each count and reconciliation “must be verified and signed by the pharmacy's manager” (s. 23.8(9)). On a loss or theft of a narcotic, the PODSA Bylaws have the manager notify the College under s. 18(2)(t), report it to Health Canada, and “submit to the College a copy of the report sent to Health Canada” (s. 23.8(12)).
- College of Pharmacists of Manitoba — Loss, Theft, or Forgery of Controlled Substances — Manitoba: pharmacists “must perform an inventory and reconciliation of narcotics, controlled and targeted drugs every three months and after a change in pharmacy manager”. The College asks pharmacists to send it their Health Canada loss or theft report by fax or email.
- College of Pharmacy of Newfoundland and Labrador — Standards of Pharmacy Operation, Community Pharmacy (last revised October 2026) — Newfoundland and Labrador: “A physical inventory count of all controlled substances must be performed and documented at least once every three months”. An additional count is required “when the pharmacist-in-charge of the pharmacy changes”. Losses and thefts go to Health Canada's Office of Controlled Substances “within 10 days in accordance with section 109” of the Controlled Substances Regulations.
- Nova Scotia Pharmacy Regulator — Policy: Inventory Management of Controlled Substances and Z-Drugs — Nova Scotia: the physical count and reconciliation are “completed and documented monthly”, and pharmacy managers “must be able to demonstrate that they have reviewed this documentation monthly”. “A reconciliation must also take place immediately upon a change in pharmacy manager”. The policy covers narcotics, controlled drugs and benzodiazepines, and Z-drugs (zopiclone and eszopiclone); low dose codeine products are exempt. A copy of the Health Canada loss or theft report “must be forwarded to the NSPR”, Z-drug losses included.
- Prince Edward Island College of Pharmacy — Narcotic, Controlled and Targeted Drug Reconciliation Practice Directive (updated February 2020) — Prince Edward Island College of Pharmacy: a physical count of narcotic and controlled drugs “must be completed on a monthly basis”, and of targeted drugs “at least once every six months” (s. 1.1). The Prince Edward Island College of Pharmacy also requires a count whenever there is a change in pharmacy manager, after any break and enter or theft from the pharmacy, and after any recent change in pharmacy staff (s. 1.2). A copy of the report sent to Health Canada's Office of Controlled Substances “must be forwarded to the PEICP” (s. 4.5).
- Controlled Substances Regulations (SOR/2025-242) s. 124 — in force October 1, 2026 — Federal, and verbatim: “The documents must be accessible (a) at the pharmacy where the information was recorded; or (b) if that pharmacy has ceased its operations, at a place in Canada.”
Primary sources for the figures on this page. Regulations change; confirm the current requirement with the source before you rely on it.