Cash on Delivery (C.O.D.) System

New York’s Cash on Delivery (C.O.D.) system is an enforcement mechanism used by the Office of Cannabis Management (OCM) to address unpaid supplier invoices. When a retailer fails to pay a licensed supplier, the supplier may report the delinquency to OCM.

Once reported, the retailer is placed on the C.O.D. List and faces immediate purchasing restrictions until the issue is formally resolved.

What This Covers

What the C.O.D. system is and why it exists
How the C.O.D. List works
How delinquent payments are reported
How retailers are removed from the list
How suppliers use the list to manage risk

The C.O.D. List

The C.O.D. List is maintained by OCM as an active enforcement tool.

When a retailer is placed on the list:

They cannot receive cannabis products on credit
All future purchases must be paid upfront
They remain on the list until the reporting supplier submits a resolution

Retailers are not removed automatically.
Only the supplier who filed the delinquency can clear the listing.

Reporting a Delinquent Payment

Licensed suppliers may report a retailer when an invoice is not paid according to agreed terms.

Reports typically include:

Supplier license information
Retailer name and license number
Invoice date
Amount owed
Documentation showing nonpayment

Accurate and complete documentation allows OCM to validate and process the report.

Submitting a Resolution

If the retailer pays the outstanding balance or resolves the dispute, the supplier must submit a resolution to OCM.

Resolution filings generally include:

The delinquency report identifier
Confirmation of payment (date, amount, method)
Supplier license details

Until a resolution is submitted and accepted, the retailer remains on the C.O.D. List even if payment has occurred.

Viewing the C.O.D. List

Licensed suppliers may review the active C.O.D. List to:

Verify a retailer’s status before extending credit
Confirm whether a retailer has unresolved delinquencies
Review the date and reason for a listing
Assess credit risk before entering supply agreements

Regular review helps suppliers avoid transactions with retailers who may not be able to pay.

What Operators Usually Miss

Retailers cannot remove themselves from the list
Partial payment does not clear a listing unless documented as resolved
C.O.D. status affects all suppliers, not just the reporting one
Listings remain active until a formal resolution is filed
Being on the list can disrupt inventory flow immediately

When This Comes Up

When retailers miss payment deadlines
During supplier credit reviews
Before approving new wholesale relationships
During audits or compliance reviews
When retailers experience cash flow issues

What Happens If You Ignore This

For retailers:

Loss of access to credit purchasing
Delayed or blocked inventory deliveries
Operational disruptions and revenue loss
Increased scrutiny from suppliers and regulators

For suppliers:

Unrecoverable receivables
Increased financial risk
Compliance issues if transactions proceed improperly