DEA Form 106: Reporting Stolen or Lost Controlled Substances (Veterinary, 2026)

DEA Form 106 is the official report a DEA registrant files when controlled substances are stolen or significantly lost. For a veterinary practice, it is paired with a strict deadline: written notice to the DEA within one business day of discovering the theft or loss, and the completed Form 106 filed within 45 days. Missing either deadline is itself a violation — separate from the loss that triggered it.

This guide explains when you must report, the two deadlines, how to file Form 106 online, the difference between a reportable loss and a routine discrepancy, and what happens after you file. The reporting rules sit in 21 CFR 1301.76(b).

When you must report

A veterinary practice must report to the DEA when it discovers a theft or a significant loss of any controlled substance. Two things are worth pinning down immediately.

The clock starts at discovery, not at the event. If a drug was diverted gradually over months but you only realize it today, “today” is the discovery date and the deadlines run from today.

Theft is always reportable. Any theft of a controlled substance must be reported, regardless of quantity. There is no minimum-amount threshold for theft.

A loss must be reported when it is “significant.” Not every discrepancy is reportable — see the next-but-one section — but when a loss meets the significance criteria, it must be reported on the same timeline as a theft.

If you are unsure whether something is reportable, the conservative course is to treat it as reportable. Under-reporting a genuine loss is the far costlier mistake.

The one-business-day notification rule

The first deadline is fast. Under 21 CFR 1301.76(b), on discovering a theft or significant loss you must notify the DEA Field Division Office in your area in writing, within one business day of discovery.

Key points:

One business day — discover it on a Friday, and the written notice is generally due the following Monday.
In writing. A phone call is not the notice. Email or a letter to the Field Division Office is. Many practices phone the Field Division as well, to ask how they prefer to receive the written notice, but the written notice itself is the requirement.
It is separate from Form 106. The one-business-day written notice is the initial alert. The Form 106 is the detailed report and follows later. They are two distinct obligations — do not assume filing one satisfies the other.

This is the deadline practices miss most often, because it is so short and arrives in the middle of a stressful discovery. Knowing the rule in advance — and having the Field Division Office contact details on hand — is what makes it achievable.

Filing DEA Form 106 online

The second deadline: a complete and accurate DEA Form 106 must be filed within 45 days of discovery.

Form 106 is filed online through the DEA Diversion Control Division’s secure portal (deadiversion.usdoj.gov). The paper form has been phased out of routine use in favor of online submission — confirm the current filing method on the DEA Diversion Control site before you file.

The form asks for:

The registrant’s name, address, and DEA registration number.
The date of the theft or loss and the date of discovery.
The local police department notified (for theft).
The circumstances — break-in, employee diversion, loss in transit, unexplained shortage.
An itemized list of each controlled substance lost or stolen: name, strength, dosage form, and quantity.

File it accurately. The 45-day window is for a complete and accurate report — a rushed, vague Form 106 invites follow-up and looks worse than a careful one. But do not let “accurate” become an excuse to blow the deadline; file within 45 days even if some details are still being established, and supplement if needed.

Theft vs. significant loss vs. a routine discrepancy

Not every count that comes up short is a Form 106 event. Three categories:

Theft. Controlled substances taken unlawfully — a break-in, a robbery, or diversion by staff or a client. Always reportable, any quantity.

Significant loss. Controlled substances unaccounted for, where the loss is significant. The DEA does not set a single number; 21 CFR 1301.76(b) lists factors the registrant weighs, including:

The actual quantity lost relative to the type of business.
The specific controlled substances involved.
Whether the loss can be associated with access by particular individuals.
A pattern of losses over time, and whether the losses are unexplained.
The local trends and other indicators of the diversion potential of the substance.

A single small, fully explained discrepancy — a spill you witnessed and documented, a measuring variance within normal tolerance — is generally not a significant loss. A pattern of unexplained shortages, a missing vial of an opioid or ketamine, or any loss you cannot account for, generally is.

Routine, explained discrepancy. A minor variance with a documented, innocent cause. Not a Form 106 event — but you must still document it in the log, including what you found and why. Documentation is what keeps a routine discrepancy from later looking like a concealed loss.

When the facts are ambiguous, treat it as significant and report. And recognize that an unexplained shortage is also a possible sign of drug diversion — the reporting step and the internal investigation happen in parallel.

Police report and state board notification

Form 106 is the federal step. It is usually not the only one.

Police report. For any theft, notify your local law enforcement and obtain a report. Form 106 asks which police department you contacted, so the police report typically comes first or alongside.
State veterinary board / state pharmacy board. Many states require their own notification of a controlled-substance theft or loss, sometimes on their own timeline and form. State requirements are separate from and additional to the DEA’s — confirm what your state board requires.
DEA registration is federal; state rules layer on top. Reporting to the DEA does not discharge a state obligation, and vice versa.

Build all three — DEA, police, state board — into your written response procedure so none is forgotten in the moment.

What happens after you file

Filing Form 106 does not by itself trigger a penalty — it is the required action, and failing to file is the violation. After you file:

The DEA reviews the report. Depending on the substance, the quantity, and the circumstances, it may follow up or open further inquiry.
A theft or significant loss is one of the recognized triggers for a DEA inspection of the practice. An investigator may visit to review your records and security.
The DEA expects the practice to have addressed the cause — tightened access, corrected a recordkeeping gap, or acted on suspected diversion.

This is why the records and security underneath the report matter. A practice that files a Form 106, can produce clean logs and a current biennial inventory, and shows it has fixed the cause is in a far stronger position than one whose report exposes broader recordkeeping failures. Use our DEA inspection checklist for veterinary practices to see what an investigator would examine if a Form 106 brought them to your door.

Get the free DEA Self-Audit Checklist {#lead-magnet}

The best time to find a controlled-substance gap is before it becomes a loss you have to report. Our free DEA Self-Audit Checklist turns a full DEA inspection into a self-scoring worksheet — 39 items, a Yes/Partial/No answer for each, and a readiness score. Enter your email and we’ll send it over, free.

Get the free DEA Self-Audit Checklist →

Frequently asked questions

What is DEA Form 106 used for? It is the report a DEA registrant files to document the theft or significant loss of controlled substances, as required by 21 CFR 1301.76(b).

How quickly must I report a controlled substance theft? Two deadlines: written notice to the DEA Field Division Office within one business day of discovery, and the completed DEA Form 106 within 45 days of discovery.

Is every controlled substance shortage reported on Form 106? No. Any theft is reported regardless of amount. A loss is reported only when it is “significant” under the 21 CFR 1301.76(b) factors. A minor, documented, explained discrepancy is not a Form 106 event — but it must still be recorded in your log.

How do I file DEA Form 106? Online, through the DEA Diversion Control Division’s secure portal at deadiversion.usdoj.gov. Confirm the current method on the DEA site before filing.

Do I have to report the theft to anyone besides the DEA? Usually yes. Notify local police for a theft and obtain a report, and check whether your state veterinary or pharmacy board requires its own notification — many do.

Reporting is the last step — prevention is the goal

Knowing how to file Form 106 is essential, but the report only exists because something went wrong. The stronger position is the practice that controls access, reconciles its logs, and catches a problem before it becomes a reportable loss. Read drug diversion in veterinary practices for the prevention side, and run the free DEA Self-Audit Checklist to find your gaps first.

When you’re ready to close them, the Vet Compliance HQ DEA Controlled Substance Compliance System gives you the SOPs, logs, staff training records, and a written theft-and-loss response procedure.

Vet Compliance HQ provides educational compliance resources for veterinary practices. This article is not legal advice. DEA and state requirements change and vary by state — verify current requirements with the DEA and your state veterinary board.