Deavo
Due diligenceChecklist · 3 min read

Vending machine business due-diligence checklist

A vending machine due-diligence checklist covers the health authority’s notice or permit, operator labels on the machines, any tobacco or vapour sales, GST/HST registration and cash-collection records, and the source of any meat products.

By the Deavo teamCanadaUpdated

Use this checklist once you are under a letter of intent on a vending route, such as one of the vending businesses for sale. It covers the points that are specific to vending machines: the rules that apply to the machines themselves, what they may dispense, and how cash and GST/HST are handled. Rules differ by province, and the items below use Ontario, Alberta and Quebec as examples. For the general checklist, see the buyer due-diligence checklist.

Health authority and permits

Start by confirming which health rules cover the machines and what the seller has on file.

Ask the local health unit which rules apply to the machines and the routeOntario’s Health Protection and Promotion Act covers premises where food is sold or offered for sale, so confirm with the health unit how it treats the machines.
Request the seller’s notice to the medical officer of health (Ontario)The Act says a person who intends to commence to operate a food premise must give notice to the medical officer of health of the health unit where it will be located. Ask whether you must give your own.
In Alberta, ask whether the machines depend on a commissary or depot food handling permitAlberta’s Food Regulation does not apply to food handling for operating a vending machine that dispenses pre-packaged food or food from a commissary or depot identified on a food handling permit, unless, in the regional health authority’s opinion, the exemption would or is likely to create a nuisance (s. 2(3)).
Ask how the machines will be covered after closing if a permit is the seller’sAlberta’s Food Regulation says a permit is not transferable, subject to section 7(3), so do not assume the seller’s permit comes with the sale.

The machines on site

Visit the locations and inspect the machines themselves, since several rules attach to individual machines.

Check that the operator’s name and telephone number are displayed on each unattended machineOntario’s food premises regulation requires this on or near a vending machine if an employee of the operator is not in full-time attendance.
Confirm that any machine mixing water has a potable water supply piped in under pressureOntario’s food premises regulation requires this for a vending machine in a food premise that automatically mixes water to create a product.
Make a list of every machine and what it dispensesMatch the list to each rule below, because tobacco, vapour and meat products are treated differently from other goods.

What the machines sell

Some products raise their own legal questions, so check them one by one.

Check whether any machine sells tobacco or vapour productsOntario’s Smoke-Free Ontario Act, 2017 bars an owner or occupier of a place from having a vending machine for these products in any part of the place, with exceptions that include a machine only operable by a retailer or an employee of a retailer.
In Alberta, confirm no machine sells tobacco or vaping productsAlberta’s Tobacco, Smoking and Vaping Reduction Act (s. 7.3(f)) says no person shall sell these products, or offer them for sale, from a vending machine.
In Quebec, ask where any meat products come fromQuebec’s Regulation respecting food says meat products dispensed by an automatic vending machine must have been prepared and packed in a plant operated in conformity with that regulation and serving only for that purpose.

GST/HST and cash records

On a cash route, ask for the records that show what the machines took in and when tax was treated as collected.

Request GST/HST registration and filed returnsThe Canada Revenue Agency says goods sold through vending machines or coin-operated machines are generally subject to GST/HST.
Ask for cash-collection logs by machine and dateThe CRA says you are considered to have collected the GST/HST when you remove the money from the machine, so the logs show when tax was treated as collected.
Ask which machines the seller treated as single-coin machines with GST/HST equal to zeroSection 165.1(2) of the Excise Tax Act sets the tax at zero where a single coin is deposited in a mechanical coin-operated device designed to accept only a single coin, up to the value that subsection sets, as the total consideration. Section 160 sets other coin-operated device rules, so ask your accountant to confirm each treatment.

Related reading

6 pages on the same subject, grouped by topic.

Businesses for sale on Deavo

Sources

Every item on this checklist traces to a primary source. Links were last confirmed on the dates shown.

  1. 01
    Government of OntarioGovernment
    Health Protection and Promotion Act, R.S.O. 1990, c. H.7
    ontario.ca·Checked Oct 21, 2026
  2. 02
    Government of OntarioGovernment
    O. Reg. 493/17: Food Premises
    ontario.ca·Checked Aug 16, 2026
  3. 03
    Alberta King’s PrinterGovernment
    Food Regulation, Alberta Regulation 31/2006
    kings-printer.alberta.ca·Checked Oct 24, 2026
  4. 04
    Government of OntarioGovernment
    Smoke-Free Ontario Act, 2017, S.O. 2017, c. 26, Sched. 1
    ontario.ca·Checked Oct 24, 2026
  5. 05
    Alberta King’s PrinterGovernment
    Tobacco, Smoking and Vaping Reduction Act, Chapter T-3.8
    kings-printer.alberta.ca·Checked Oct 24, 2026
  6. 06
    Canada Revenue AgencyGovernment
    General Information for GST/HST Registrants (RC4022): coin-operated machines
    canada.ca·Checked Oct 24, 2026
  7. 07
    Gouvernement du QuébecGovernment
    Regulation respecting food (P-29, r. 1), meat products in vending machines
    legisquebec.gouv.qc.ca·Checked Oct 24, 2026
  8. 08
    Government of Canada (Department of Justice)Government
    Excise Tax Act, R.S.C. 1985, c. E-15
    laws-lois.justice.gc.ca·Checked Oct 20, 2026

Deavo is an advertising and listings platform, not a brokerage, law firm or valuation firm. This page is general information, not legal, tax, accounting or valuation advice, and rules differ by province. Confirm anything you rely on with a qualified professional before you act on it.