CDSA recordkeeping: what to keep, and for how long

Published June 19, 2026

Controlled-substance recordkeeping is about being able to show your work. Here's what pharmacies generally need to keep, in what form, and for how long.

Reconciling narcotics isn't only about counting — it's about being able to show the records behind every number. Here's what pharmacies generally keep for controlled substances, and the form it needs to be in. Confirm the specifics with your provincial college and the federal regulations.

What records to keep

The core set is the ledger your reconciliation is built on: receipts/purchases of controlled substances, dispensing records, destructions, your periodic counts and reconciliations, and any loss or theft reports. Notes that explain a variance and the corrective action belong with the count they relate to.

How long to keep them

Keep these records retrievable for at least two years; some records and circumstances call for longer. The safe approach is to retain the full history rather than only the most recent count, so a past variance can be explained on request.

Retrievable and legible

Records can be paper or electronic, but they must be complete, legible, and available to an inspector when asked. Electronic systems should maintain an audit trail so it's clear who recorded or changed what, and when.

Why it matters for reconciliation

Expected on-hand is only as accurate as the records behind it. A missing receipt or an unlogged destruction is exactly what a reconciliation surfaces — and exactly what an inspector will ask you to produce. Good recordkeeping and clean reconciliations are two sides of the same coin.

Keep it organized

A per-drug history keyed by DIN makes both counts and inspections far faster. A system that stores counts, transactions, and notes together saves you assembling them from separate places later.

NarcCount does the reconciliation math for you and flags every variance. Get started or read the OCP reconciliation guide.

General information, not legal or professional advice. For authoritative requirements, refer to the Ontario College of Pharmacists and Health Canada.