Registered Organization (Medical)

Registered Organizations (ROs) are vertically integrated medical cannabis companies authorized to cultivate, process, distribute, and dispense medical cannabis in New York. Originally licensed under the Department of Health, they now operate under the Office of Cannabis Management (OCM) pursuant to the Marihuana Regulation and Taxation Act (MRTA).

ROs form the core of New York’s medical cannabis market and may participate in the adult-use system through a regulated dual-license and co-location framework. This page explains what ROs are allowed to do, how they operate, and how they must comply with both medical and adult-use requirements.

Legal Standing and Role in the System

Registered Organizations:

Were licensed under the 2014 Compassionate Care Act
Are now regulated by OCM under MRTA
May operate up to four medical dispensaries
May cultivate, process, manufacture, and distribute medical cannabis
May apply for approval to operate adult-use retail through co-location

Although ROs are larger-scale operators, they must follow the same adult-use compliance standards as any retailer, processor, or cultivator. Nothing in MRTA exempts them from these requirements.

What ROs Are Licensed to Do

Under MRTA and OCM regulations, Registered Organizations may:

Cultivate cannabis for the medical program and, if approved, for adult-use
Process and manufacture medical cannabis products
Distribute products internally within their organization
Operate state-authorized medical dispensaries
Apply for up to three co-located adult-use retail dispensaries

These privileges exist only within the boundaries of the RO license and do not permit unrestricted expansion or ownership across unrelated license tiers.

Co-Location Rules for Adult-Use Retail

ROs approved for adult-use operations must maintain a clear separation between medical and adult-use activities. Co-located dispensaries must demonstrate:

Physically separate retail spaces
Distinct entrances and customer pathways
Separate inventory rooms and POS systems
Staff trained and assigned specifically to medical or adult-use operations

Medical operations must remain uninterrupted, accessible to patients, and fully compliant with all Department of Health and OCM requirements even after adult-use approval.

Supply Chain, Tracking, and Reporting Standards

Registered Organizations must meet the same manufacturing, retail, transport, and reporting standards required of all license types, including:

METRC seed-to-sale tracking for adult-use inventory
Segregated inventory systems for medical and adult-use products
Mandatory testing through approved third-party laboratories
Documented SOPs for security, storage, and access control
Incident reporting, required logs, and compliance records
Reporting obligations to OCM and, where applicable, the Department of Health

Medical and adult-use inventory may not be combined. All product movement must be fully traceable and tied to the appropriate program.

Limits and Restrictions

Registered Organizations are prohibited from:

Selling untested or improperly labeled products
Mixing medical and adult-use inventory
Sharing premises with unrelated licensees
Expanding into other license tiers outside the RO and dual-license framework
Operating without required workforce training or medical-program documentation

Despite their scale, ROs are subject to heightened regulatory oversight and must meet the same operational expectations as smaller licensees.

Source Material

MRTA Section 68 (Registered Organization Provisions)
MRTA