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KCanG §26 — Record-Keeping Requirements

The Konsumcannabisgesetz (KCanG), in force since 1 April 2024, imposes specific record-keeping obligations on licensed Cannabis Social Clubs (CSCs) under §26.

What §26 Requires​

Cultivation Records​

Clubs must record and retain:

  • All cultivation batches (strain, quantity, growing period, yield)
  • Plant counts per grow zone
  • Harvest data including THC and CBD content where analysed
  • All propagation events (cuttings, seeds distributed to members)

Dispensing Records​

For every dispensing event, clubs must record:

  • Member identifier (pseudonymised for the statutory report)
  • Date and time
  • Quantity dispensed (in grams)
  • Product (strain/batch reference)
  • Cumulative monthly total for the member

Compliance Records​

Clubs must also maintain:

  • Destruction records — for any cannabis that must be destroyed
  • Loss records — any unexplained losses must be reported to authorities within the same business day
  • Transport records — movement of cannabis between locations
  • Recall events — defective product recalls, reported to authorities within 2 hours

Annual Reporting​

Every club must submit an annual report to the competent authority containing:

  • Total cultivation quantities by strain
  • Total quantities dispensed by category
  • Aggregated statistics (no individual PII in the submission)

CANNEVO automates the generation of this report and enforces PII redaction before export.

How CANNEVO Implements §26​

CANNEVO enforces §26 compliance at the database level, not just the user interface:

  • All dispensing events are written to an immutable table (no updates or deletes permitted via RLS)
  • The monthly quota cap is enforced by a database stored procedure (execute_dispensing_gate) that atomically checks and records each dispensing event
  • Recall and loss SLAs are tracked and generate automatic escalation alerts when deadlines approach
  • The annual report generator validates that no PII survives in the export output

For full implementation details, see the CANNEVO Compliance & Governance documentation.