AGCO Launches Youth Compliance Monitor Program to Strengthen Underage-Protection Checks
The Alcohol and Gaming Commission of Ontario has expanded its mystery-shop enforcement by appointing youth compliance monitors to work with inspectors.
LISTEN TO THIS ARTICLE:In a move announced in November 2025, the AGCO said it will appoint Youth Compliance Monitors aged 16 to 18 to accompany AGCO Inspectors in authorized compliance visits to licensed retail outlets and establishments across Ontario. The monitors will attempt controlled purchases of age-restricted products such as alcohol and cannabis; successful purchases will trigger a violation under provincial legislation and may lead to enforcement action.
The AGCO emphasized that the new measure strengthens existing protections for youth and brings the province into line with enforcement models used elsewhere in Canada and internationally. "This program is designed to close gaps between education and enforcement", said the AGCO Registrar. "By pairing trained youth monitors with experienced inspectors, we can more accurately assess retail compliance and target enforcement where it will most reduce harm to the public."
Under the revised approach, licensees whose premises are found to have sold or supplied age-restricted products to a Youth Compliance Monitor will be cited under either the Liquor Licence and Control Act, 2019 or the Cannabis Licence Act, 2018 depending on the product involved. The AGCO said potential outcomes range from monetary penalties to licence conditions, suspensions or revocation, with sanctions determined by the severity of the breach and the operator’s compliance history.
Officials said the program supplements education and compliance tools already available to businesses, and that the AGCO will continue to provide guidance to help operators meet their obligations. "Our objective is not punitive action for its own sake", the Registrar added, "but to ensure licensees understand and meet their legal duties so that Ontario’s youth are better protected."
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How the Youth Compliance Monitor Program Will Operate
Youth Compliance Monitors will act only as part of an authorized AGCO compliance activity and will be supervised by an AGCO Inspector at all times. Visits will target a range of venues, including licensed grocery and convenience stores, dedicated cannabis retailers and on‑premises alcohol licensees. If a monitor is asked for identification and lawfully refused service, no violation will be recorded.
The regulatory requirements licensees must follow are unchanged: cannabis retailers are required by Ontario Regulation 468/18 to request identification from anyone who appears under 25 and to confirm they are at least 19 before entry or sale. Liquor licensees must verify ID for anyone who appears under 19 under Ontario Regulation 746/21. Additional standards, such as the Registrar’s Standards for Grocery and Convenience Stores and the Registrar’s Interim Standards and Requirements for Liquor, prohibit possession of liquor by minors in retail outlets.
Industry observers welcomed the clarity the program brings, but urged measured implementation. "Effective enforcement relies on consistency and transparency", said Emily Chen, a regulatory compliance consultant who has worked with provincial regulators. "Licensees need clear notice about how inspections are conducted and fair processes to contest enforcement decisions. When done properly, these programs reduce risky sales and raise standards across the sector."
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Compliance Advice for Licensees
Retailers and hospitality operators should treat the program as a reminder to review age-verification practices and staff training. Practical steps include reinforcing a challenge‑25 approach, ensuring all staff know what valid identification looks like, adopting documented refusal procedures, and keeping records of staff training and compliance checks. The AGCO also recommends regular internal mystery shops and refresher training following any compliance incident.
Operators remain able to seek clarification from AGCO Inspectors and to use existing regulatory processes to respond to alleged violations. As regulators sharpen enforcement tools, licensees who proactively bolster their ID-checking procedures and incident documentation will be best placed to avoid sanctions and demonstrate a commitment to public safety.
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