When the AGCO Takes Action Against Your Licence
This page is for holders of licences under the Liquor Licence and Control Act, 2019 (LLCA), particularly licences to operate liquor consumption premises such as bars and restaurants. AGCO action usually follows an inspection, a police report, an incident at the premises, or concerns about the people behind the licence.
Illustrative example, not an actual AGCO notice
“Take notice that the Registrar proposes to suspend your liquor sales licence for 14 days and to attach conditions requiring additional security staff, for the reasons set out in this notice. You are entitled to a hearing by the Licence Appeal Tribunal if you mail or deliver a written request to the Tribunal and the Registrar within 15 days after this notice is served on you.”
Who Investigates and Who Decides
- Regulator
- The Registrar of the AGCO, under the LLCA and the Alcohol and Gaming Commission of Ontario Act, 2019, and the Registrar’s standards and requirements.
- Who investigates
- AGCO inspectors, who can inspect licensed premises (LLCA, ss. 54–55), often working with police.
- Who decides
- The Registrar proposes action. If you request a hearing, the Licence Appeal Tribunal decides (ss. 25–26).
- Further appeal
- An appeal from the LAT to the Divisional Court on liquor matters is available on a question of law only (Licence Appeal Tribunal Act, 1999, s. 11(2)–(3)).
Grounds for action
The Registrar can propose to refuse to renew, suspend or revoke a licence if the licensee would not be eligible for a licence, or has contravened the Act, the regulations, the Registrar’s standards and requirements, or a licence condition (LLCA, s. 13(1)).
Common Issues in Liquor Licence Enforcement
Over-service and intoxication
Serving intoxicated patrons and permitting drunkenness on the premises.
Minors
Serving or permitting minors on premises where that is not allowed.
Violence and safety
Fights, weapons and police calls, and how security and incident reporting were handled.
Capacity and hours
Overcrowding, serving outside permitted hours, and operating outside the licensed area.
Eligibility and ownership
Undisclosed owners or financial interests, the past conduct of the people behind the licence, and ownership changes that need approval (s. 14).
What Can Happen Next
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Monetary penalty
The Registrar can impose a monetary penalty from the AGCO’s published schedule by serving notice. You can appeal by serving a written request on the Tribunal and the Registrar within 15 days after the notice is served, and the Tribunal can confirm or set aside the penalty (AGCO Act, 2019, s. 14(5), (7), (10)).
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Notice of Proposal
To refuse to issue, renew or transfer a licence, suspend or revoke it, attach or review conditions, or refuse to remove a condition, the Registrar must serve a notice of proposal with written reasons (LLCA, s. 25(1)).
Deadline
You are entitled to a LAT hearing if you mail or deliver a written request to the Tribunal and the Registrar within 15 days after the notice is served (LLCA, s. 25(4)). If you do not request a hearing, the Registrar may carry out the proposal (s. 26(6)).
After a hearing, the Tribunal may direct the Registrar to carry out the proposal in whole or in part, with changes, or not at all, and may impose conditions on the licence (s. 26(4)–(5)).
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Immediate suspension
The Registrar can suspend a licence without a proposal if it considers that necessary in the public interest. The suspension takes effect as soon as you are served with notice and reasons, and you can request a LAT hearing within 15 days after service (LLCA, s. 13(2)–(4.1)).
Checklist: Responding to the AGCO
Documents to gather
- The notice, proposal or penalty, and proof of when it was served
- Incident logs, security staffing records and video footage
- Staff schedules and Smart Serve or other server training records
- Floor plans, capacity documents and the licensed area
- Ownership and corporate records, and any earlier AGCO history
- Police reports and correspondence about the incident
Details to check in the notice
- Whether it is a proposal, an immediate suspension or a monetary penalty
- The service date and your 15-day window
- Both recipients of your request: the Tribunal and the Registrar
- Whether conditions are proposed instead of, or in addition to, a suspension
Rules and resources to consult
- Liquor Licence and Control Act, 2019, ss. 13–14, 25–27 and 54–55
- Alcohol and Gaming Commission of Ontario Act, 2019, s. 14
- The Registrar’s standards and requirements and the AGCO monetary penalty schedule
- Licence Appeal Tribunal – General Service forms, rules and practice directions
Frequently Asked Questions
Can the AGCO close us before a hearing?
Yes. The Registrar can suspend a licence without a proposal if it considers that necessary in the public interest, effective on service. You can still request a LAT hearing within 15 days (s. 13(2)–(4)).
Can we appeal the Tribunal’s decision?
For liquor matters, an appeal to the Divisional Court is limited to questions of law (LAT Act, s. 11(3)). The Tribunal hearing is therefore usually your main opportunity to contest the facts.
Is a monetary penalty better than a suspension?
They are different tools. A penalty from the AGCO schedule can be appealed within 15 days, and the Tribunal can only confirm it or set it aside (AGCO Act, s. 14). A suspension or conditions arise from a proposal. Which applies is the Registrar’s choice, but your response can address both.
Sources
Statutory references are to the provisions listed below, as consolidated on e-Laws when this page was prepared.
- Liquor Licence and Control Act, 2019, S.O. 2019, c. 15, Sched. 22, ss. 13–14, 25–27, 54–55 — e-Laws consolidation period beginning December 11, 2025; checked November 10, 2026.
- Alcohol and Gaming Commission of Ontario Act, 2019, S.O. 2019, c. 15, Sched. 1, s. 14 — e-Laws consolidation period beginning May 12, 2025; checked November 10, 2026.
- Licence Appeal Tribunal Act, 1999, s. 11(2)–(3) — Checked November 10, 2026.
- Tribunals Ontario, Licence Appeal Tribunal – General Service — Checked November 10, 2026.