Adult-Use License Types
MRTA Article 4, Sections 68–75, 77
Sections 68–75 and 77 define every adult-use cannabis license type in New York and strictly control what each license allows, prohibits, and requires. These sections establish permissions, ownership limits, eligibility rules, and operational boundaries for all adult-use businesses.
If an activity is not explicitly allowed under your license type, it is prohibited.
What This Covers
- Adult-use license categories and authorizations
- Ownership limits and eligibility rules
- Operational permissions and prohibitions
- Vertical-integration restrictions
- OCM oversight and enforcement boundaries
Adult-Use Cultivator License (68)
Authorizes the licensee to:
- Grow, harvest, dry, and trim cannabis
- Sell cannabis to licensed processors
- Conduct limited processing if authorized by OCM
- Apply for one processor license and one distributor license to distribute its own products
Restrictions include:
- No ownership interest in retail or other adult-use licenses
- One cultivator license per person unless OCM authorizes multiple sites
Registered Organization Adult-Use License — Full Vertical (68-A)
Authorizes a Registered Organization to:
- Cultivate, process, distribute, and retail adult-use cannabis
Limits include:
- Maximum of three adult-use retail dispensaries at existing medical sites
- Distribution limited to its own products
- Medical operations must be maintained
- No ownership of other adult-use licenses
Registered Organization Adult-Use License — Vertical, No Retail (68-B)
Authorizes a Registered Organization to:
- Cultivate, process, and distribute adult-use cannabis
Restrictions include:
- No adult-use retail activity
- Distribution limited to its own products
- No ownership of other adult-use licenses
Adult-Use Processor License (69)
Authorizes the licensee to:
- Process, manufacture, package, label, and brand cannabis products
- Sell products to processors or distributors
- Apply for one distributor license to distribute its own products
Restrictions include:
- No cultivation
- No unrelated business activities unless approved by OCM
- One processor license per person
- No ownership interest in retail or Registered Organization licenses
Adult-Use Cooperative License (70)
Authorizes the cooperative to:
- Cultivate, process, and distribute cannabis
- Sell to retailers, cooperatives, microbusinesses, on-site consumption licensees, and Registered Organizations
Restrictions include:
- No direct sales to consumers
- Ownership limited to New York residents
- One vote per member
- Members may belong to only one cooperative
- No ownership interest in other adult-use licenses
Adult-Use Distributor License (71)
Authorizes the licensee to:
- Acquire and distribute cannabis products
- Sell to retailers, on-site consumption licensees, cooperatives, microbusinesses, and eligible Registered Organizations
- Charge an OCM-approved distribution fee
Restrictions include:
- No ownership interest in microbusiness, retail, on-site, or other Registered Organization licenses (except as allowed under §39)
- If affiliated with a cultivator or processor, distribution is limited to those products
Adult-Use Retail Dispensary License (72)
Authorizes the licensee to:
- Acquire, possess, sell, and deliver cannabis products to consumers
Restrictions include:
- Maximum of three dispensaries per person
- No ownership interest in other adult-use licenses except as allowed under §§68-A and 68-B
- Public, street-level storefront required unless delivery-only or microbusiness
- Prohibited within 500 feet of a school or 200 feet of a house of worship
Microbusiness License (73)
Authorizes limited:
- Cultivation
- Processing
- Distribution
- Delivery
- Retail of the licensee’s own products
Restrictions include:
- No ownership interest in other adult-use licenses
- OCM-set limits on canopy, production volume, and eligibility
- Mandatory support of social and economic equity goals
Delivery License (74)
Authorizes the licensee to:
- Deliver cannabis products directly to consumers
Restrictions include:
- Maximum of 25 full-time-equivalent delivery workers
- No ownership interest in more than one delivery license
- OCM-set operating criteria and rules
- Mandatory support of social and economic equity goals
Nursery License (75)
Authorizes the licensee to:
- Produce, sell, and distribute clones, immature plants, seeds, and starter materials
Restrictions include:
- Sales limited to cultivators, cooperatives, microbusinesses, and Registered Organizations
- License requirements set by OCM
- Cultivators may apply for only one nursery license
Adult-Use On-Site Consumption License (77)
Applications are not yet open.
This license authorizes:
- On-site consumption of cannabis purchased on the premises
Restrictions include:
- Licensee must own or control the premises
- Maximum of three licenses per person
- No ownership interest in other adult-use licenses
- Prohibited within 500 feet of a school or 200 feet of a house of worship
- Access restricted to individuals 21 and over
- Full purchase and sales records required
- Subject to inspection at any time
What Operators Usually Miss
- You may not hold multiple license types unless explicitly allowed by statute
- Vertical integration is prohibited by default
- Ownership conflicts alone can trigger enforcement
When This Comes Up
- License application and eligibility review
- Business planning and structuring
- Ownership changes or investment discussions
- Enforcement actions and audits
What Happens If You Ignore This
- License denial or revocation
- Forced divestment of ownership interests
- Fines and enforcement penalties
- Denial of renewal or future licenses
Related MRTA Article 4 Section Pages
References
