Motor vehicle dealer licensing on a sale in Manitoba

Manitoba is direct about dealer permits. The Drivers and Vehicles Act says no person may carry on business as a dealer unless the person holds a valid dealer’s permit issued by the registrar, and it says a permit is not transferable. Manitoba Public Insurance (MPI) manages the Dealer, Salesperson and Recycler Permit programs under delegated authority from the Registrar of Motor Vehicles, and its Dealer’s Permit Handbook sets out the steps. For a sale, the practical consequence is that a buyer of the assets has to hold a permit in its own right, while a change of officers or directors in a company that already holds one is among the changes the handbook says must be reported. The handbook’s notice list does not mention a change of shareholders, so ask MPI about that.

A permit that stays with its holder

Under the Act a permit is subject to the conditions the registrar considers appropriate and sets out in it. Subject to the notice and hearing process in section 100, the registrar may refuse to issue a permit to an applicant who does not hold one, including where an incorporated applicant’s past conduct, or that of its officers or directors, affords reasonable grounds to believe it will not carry on business according to law and with integrity and honesty. Other grounds include contravening the Act or regulations, failing a prescribed qualification, and a material misstatement or failure to disclose in the application. Those grounds apply to the buyer’s application on an asset purchase, so the buyer’s directors and its application answers matter.

What MPI asks of a new owner

The handbook says that when ownership of a dealership changes, the new holder of the Dealer’s Permit must register the change at the Companies Office, file official documents confirming the registration change, file a new Application for Dealer’s Permit with the required charge and security, and satisfactorily complete the written knowledge test. MPI’s handbook adds that a new applicant must provide written operating location approval from the municipality, current within three months and specific to the individual or corporation named on the application, proof of ownership or a lease for the location, and an original criminal record search for the directors listed. Buying an used car dealership is easier to plan with that list in hand.

Share sale: seven days to report

The handbook requires a permit holder to notify MPI’s Vehicle Safety department within seven days of a change in the officers or directors of an incorporated holder, a change in its status such as dissolution or amalgamation, a change of location or contact details, and the start or end of a salesperson’s employment. It also says that where only one director of a corporate applicant passed the knowledge test, that director is the only one able to sell vehicles, and that each partner or director who wants to sell must pass it. A buyer installing a new director who will sell vehicles should ask MPI about the test before closing.

The location and the lease

A dealer can only carry on business as a dealer under the name and at the location identified on its permit, except at a temporary location such as an off-site sale or a motor show. The handbook describes a permanent building with office space exclusively designated to the permit holder and not shared with another business, enough to store records securely, and dedicated parking. Because the municipal approval is specific to the individual or corporation named, a buyer’s entity needs its own. Check that any lease assignment and the municipal approval are in place for the buyer, not just for the seller.

Salespeople need permits naming the buyer

The Act bars anyone from acting as a salesperson of a dealer without a valid salesperson’s permit authorizing the salesperson to sell for that dealer, and bars a dealer from allowing it. The handbook adds that a salesperson may act only for the dealer named on their permit, and that a salesperson who moves to another dealer may not work for it until the registrar has issued a new permit noting the new dealer’s name. After an asset purchase, each salesperson who moves to the buyer should expect to need that new permit, so plan the transfer date around it, and keep in mind that the handbook treats a salesperson’s actions as potentially the dealer’s own.

Records, audits and current guidance

MPI’s handbook requires dealer records to be kept for a minimum of two years from the date each is made, and says permit holders must take part in audits as a condition of the permit. MPI has said it introduced a dealer audit framework in 2024 to increase the frequency of audits and that suspended dealers are monitored, so ask MPI how soon a new holder’s records may be reviewed. MPI’s handbook also states a minimum level of vehicle sales or purchases in any 12-month period, effective July 1, 2026, with suspension or cancellation possible if it is not met. MPI’s Vehicle Safety partner site lists the handbook as updated on January 14 and July 17, 2026, so use the current revision.