The muscular tone of the sphincter of Oddi (SO) can be up- or down-regulated by neurons that lie within ganglia in the wall of the tissue. Previous studies have demonstrated that neurons in the ganglia of the guinea-pig SO can be classified into two major populations, one of which expresses tachykinins and enkephalin and another which expresses nitric oxide synthase. Although results of previous pharmacological studies indicate that acetylcholine is released in the SO, the neurons that express this neurotransmitter have not previously been identified. This study was conducted to establish which neurons in the ganglia of the guinea-pig SO are cholinergic by examining the distribution of choline acetyltransferase (ChAT) immunoreactivity, since the enzyme, ChAT is necessary for acetylcholine synthesis. Choline acetyltransferase immunoreactivity was intense and widespread in the ganglionated plexus of the SO. ChAT-immunoreactive nerve fibers were present in ganglia, interganglionic fiber bundles and in the circular muscle layer. Neurons that were immunoreactive for ChAT comprised about 69% of the population and most of these neurons were also tachykinin-immunoreactive. Co-expression of ChAT and nitric oxide synthase was not observed in nerve cell bodies or nerve fibers. Data from this study support the concept that SO ganglia are largely made up of two populations of neurons, one excitatory and the other inhibitory, on the basis of their chemical coding. The excitatory neurons are cholinergic and co-express tachykinin and opiate peptides and the inhibitory neurons are ChAT-negative and express nitric oxide synthase.