Alert: Florida DABT Proposes New Recordkeeping Rule for 13CT Caterers
Update (4.1.25): The Division published amended rule language based on feedback from the Joint Administrative Procedures Commission. This article has been updated to reflect the current language.
While the Division of Alcoholic Beverages and Tobacco’s 13CT license allows caterers to sell or serve alcoholic beverages at events when the caterer is also providing prepared food, the caterer must derive at least 51% of its gross revenue from the service of food and non-alcoholic beverages. In an apparent effort to facilitate enforcement of this requirement, the Division is now proposing a new rule that clarifies recordkeeping requirements for 13CT licensees.
An excerpt of the notice and the full text of the proposed rule are reproduced below. The key change is that that licensees would be required to prepare and maintain a new “Catered Event Form” that would record details of each event. To the extent that the rule takes effect, this article will be updated with the final requirements and a link to the form.
NOTICE OF CHANGE/WITHDRAWAL
Notice is hereby given that the following changes have been made to the proposed rule in accordance with subparagraph 120.54(3)(d)1., F.S., published in Vol. 50 No. 182, September 17, 2024 issue of the Florida Administrative Register.
The change is in response to written comments received from the Joint Administrative Procedures Committee via letter dated September 24, 2024. The rule shall now read as follows:
61A-3.057 Catered Events Enforcement and Recordkeeping.
(1) Any licensee catering an event using a 13CT license must prepare and maintain the Catered Event Form, DBPR BLE-202, as part of the records for a catered event. In addition to the Catered Event Form, DBPR BLE-202, any licensee who caters an event using a 13CT license must have the following information available for inspection at the location of the event:
(a) No change.
(b) Customer’s name Customers’ names;
(c) through (e). No change.
(2) The Catered Event Form, DBPR BLE-202, effective May 1, 2025, incorporated herein by reference, may be obtained on the Division’s website at https://www2.myfloridalicense.com/alcoholic-beverages-and-tobacco/forms-and-publications/#1507126373827-6fd96ad1-b842 and at (new DOS link), incorporated herein by reference and effective ____________.
Rulemaking Authority 561.11, 561.08, 561.20(2)(a)(5) FS. Law Implemented 561.20 FS. History-New ____________.
The language on the Catered Event Form DBPR BLE-202 to be incorporated herein, has been amended as follows:
The language “Catered Event Form DBPR BLE-202” has been inserted at the top of the form.
The first section with a white background now reads as follows:
This completed form and the event contract with the customer’s name required attachments shall be onsite and available for inspection by any person(s) having regulatory authority over catered events. This form shall be provided by the 13CT license holder License Holder or person on-site representing the 13CT license holder employee or officer of the 13CT. The event contract and receipts associated with this specific event must be maintained with this form during the entire event, and then retained for a period of three years following the date of at the conclusion of the event.
The seventh section with a white background now reads as follows:
Person Onsite Representing the 13CT Licensee License.
The tenth section with a white background now reads as follows:
Event Location
The eleventh section with a white background now reads as follows:
A representative of the 13CT licensee license must be present at all times during the catered contracted event. 13CT services may not occur before or after the contracted dates and times. Onsite storage of alcoholic beverages outside of the contracted dates and times are prohibited. The 13CT license holder must be able to demonstrate compliance with section § 561.20(2)(a)5., Florida Statutes, by providing proof of alcoholic beverage and food sales during the onsite inspection, and for three years after the date of the event’s conclusion.
______________________________________ Date __________________________________
Printed Name and Signature of 13CT Licensee
______________________________________
Printed Name of 13CT Licensee
______________________________________
Printed Name of Event Holder
The footer now has May 1, 2025 inserted as an effective date.
