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ARTICLE · 08 OCTOBER 2026

Excise Act 2001 Recordkeeping Requirements

Millar Kreklewetz
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The Excise Act, 2001 governs taxation and regulatory frameworks for specified goods including tobacco, wine, spirits, and vaping products, with recordkeeping requirements among the most stringent in Canadian tax legislation. CRA is increasingly relying on imperfect or incomplete records as a basis for assessing additional duty, interest, and significant penalties.

CanadaTax
Robert Kreklewetz
Robert Kreklewetz
Daniel Zhang
Daniel Zhang

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The Excise Act, 2001 (“EA 2001”) governs the taxation and regulatory framework applicable to specified goods, including tobacco, wine, spirits, and, more recently, vaping products. Recordkeeping requirements under the EA 2001 are among the most stringent in Canadian tax legislation. In our experience, CRA is increasingly relying on imperfect or incomplete records as a basis for assessing additional duty, interest, and, in some cases, significant penalties.

In this Indirect Tax Report, we review the statutory requirements for books and records under the EA 2001 and highlight key compliance risks and practical traps for industry participants.

Statutory Recordkeeping Framework

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