Sales Operations (ID Check, POS, Limits)
What rules apply when selling cannabis inside your dispensary?
Sales operations are where most violations occur.
Every sale must follow the same steps: verify age, check ID, stay within limits, use the POS correctly, and refuse unsafe or illegal transactions.
Who You Can Sell To
You may only sell cannabis to customers who meet all of the following requirements:
- Are 21 years of age or older
- Present a valid, government-issued ID
- Are not visibly intoxicated
- Are not attempting to resell or purchase on behalf of another person
There are no exceptions.
Regular customers do not receive “ID-free” privileges.
ID Check Requirements
Before every sale, staff must:
- Check a valid government-issued ID (driver’s license, passport, or state ID)
- Verify the ID is real, unexpired, and matches the customer
- Refuse the sale if the ID is questionable
Additional rules:
- ID checks must occur in person
- Online-only verification is not sufficient
- If two staff members disagree about an ID, the sale must be refused
Failure to properly check ID is treated by OCM as a sale to a minor.
Who Cannot Buy
You must not sell cannabis to:
- Anyone under 21
- Anyone presenting fake, altered, or digital-only identification
- Anyone who is visibly intoxicated (alcohol or other substances)
- Anyone you reasonably suspect is reselling or purchasing for someone else
- Anyone involved in gambling, illegal drug activity, or prohibited behavior inside the store
If a customer becomes aggressive or pressures staff, management must be called immediately.
Purchase Limits
Customers may not exceed OCM’s daily purchase limits across all product types.
Your POS must enforce:
- Flower limits
- Concentrate limits
- Edible and ingestible limits
- Any applicable THC-per-day limits set by guidance
Staff must not manually override limits unless:
- The issue is documented
- The override is internally approved
If the POS blocks a sale due to limits, the transaction must not proceed.
POS Requirements
Your POS system is part of your compliance infrastructure.
The POS must:
- Block sales that exceed purchase limits
- Record each sale by SKU, batch or lot number, quantity, and price
- Sync sales data with inventory tracking daily
- Maintain transaction records on-site for inspection
- Display product test results to customers upon request
Incorrect POS configuration is treated as a compliance violation.
Sales Floor Rules
Your sales SOP must clearly define:
- Where ID checks occur (door, register, or both)
- How customers line up and approach the register
- How budtenders call customers forward
- How staff handle double purchases or suspicious buying behavior
- When issues must be escalated to a supervisor
Staff must be able to clearly see:
- The customer’s ID
- The customer’s behavior
- The product being purchased
- The POS screen during checkout
Prohibited Sales Activities
You must not:
- Sell alcohol or hold an alcohol license
- Sell unauthorized products
- Allow customers to open, sample, or consume cannabis in-store
- Offer promotions or coupons that violate OCM rules
- Sell damaged or mislabeled products
- Sell near prohibited advertisements or brand signage
Damaged or mislabeled products must be treated as quarantine, not discounted inventory.
How Discounts Affect Tax at the Register
Discounts are allowed, but tax treatment depends on the type of discount.
Store-funded discounts (no reimbursement):
- Tax is calculated on the discounted price
Example:
A $20 pre-roll sold for $10 → tax is calculated on $10
Vendor- or manufacturer-funded discounts (with reimbursement):
- Tax is calculated on the full, undiscounted price
- Treated like manufacturer coupons
Example:
A $20 pre-roll sold for $10 with $10 reimbursement → tax is calculated on $20
Your POS must distinguish between these discount types.
Returns Handled at the Register
Returns must follow your approved SOPs.
Staff must:
- Log the return in the POS
- Move returned product to quarantine or waste
- Never resell returned items
- Update inventory counts the same day
Returned products must never go back on the sales floor.
Cash Handling at the Register
Your cash-handling SOP must include:
- Opening and closing drawer counts
- Dual verification for large cash drops
- Secure cash storage during business hours
- Procedures for theft, miscounts, or discrepancies
Additional rules:
- Personal and store funds must never be mixed
- Loose cash outside drawers or safes is prohibited
OCM and law enforcement may inspect cash handling procedures at any time.
Inspections and Enforcement
During inspections, OCM may:
- Observe live sales
- Ask staff to explain ID-check procedures
- Compare POS data to inventory records
- Request sales logs
- Review security footage
- Verify purchase limits are enforced
Sales operations must match your SOPs, floor plan, and POS configuration.
Why This Matters
Most enforcement actions result from:
- Weak ID checks
- Ignored purchase limits
- Sales to suspicious buyers
- Poor recordkeeping
- Selling damaged or mislabeled products
Fixing these issues early protects your license and reduces risk.
Related Section Pages
Source Material
- Adult-Use Retail Compliance Welcome Packet (2024)
- OCM Guidance for Adult-Use Retail Dispensaries (Sales & Operations)
- Sales Tax Rate Publications
- Taxable Receipt Guidance (Discounts & Charges)
- 9 NYCRR Part 128 – Adult-Use Packaging & Labeling
