How to Renew Your New York Cannabis License and Avoid OCM Denial

How License Renewal Works in New York

Every adult-use cannabis license expires after two years.

Renewal requires OCM approval. OCM reviews:

• Compliance history
• Ownership and control
• Financing and investors
• Tax status
• METRC records
• Inventory accuracy
• Labor compliance
• Security systems

Renewal functions as a full audit of your business.

OCM may deny renewal if:

• Violations remain unresolved
• Past compliance issues were not corrected
• Required documents are missing
• Ownership changed without approval
• Financing was not disclosed

What You Must Submit During Renewal

Renewal requires updated documentation across your operation.

Ownership and Control

You must provide:

• Updated ownership percentages
• True Party of Interest disclosures
• Disclosure of new investors or lenders
• Confirmation that no undisclosed control exists

Even a one percent ownership change must be reported.

Financial and Tax Documentation

You must provide:

• Tax compliance documentation
• Proof of good standing
• Updated financial disclosures
• Disclosure of all loans and financing

Silent investors or undocumented lenders are major red flags.

Operations and Compliance Records

You must provide:

• Updated insurance
• Security documentation
• METRC reconciliation records
• Inventory and destruction logs
• Staffing and labor compliance records
• Updated premises information

Missing or inconsistent information pauses renewal review.

What OCM Reviews Before Renewing

Compliance History

OCM reviews:

• Violations and warnings
• Underage sales
• Complaints
• Inventory issues
• Labor violations

Patterns matter more than one-time mistakes.

Operational Stability

OCM evaluates:

• METRC consistency
• Inventory accuracy
• Waste and destruction logs
• Security functionality

If inventory does not match records, renewal risk increases.

Financial Transparency

OCM looks for:

• Hidden owners
• Undisclosed financing
• Prohibited cross-tier funding
• Revenue-based repayment agreements
• Side agreements

If OCM cannot clearly see who controls or benefits from the business, renewal may be denied.

What Counts as an Ownership or Control Change

OCM treats the following as ownership or control:

• Equity ownership
• Profit sharing arrangements
• Decision-making authority
• Control over bank accounts
• Loan guarantees
• Authority to hire or fire
• Management authority

If ownership, money, or decision-making changed, OCM must be notified before it happens.

Changes That Require OCM Approval Before They Happen

You must obtain approval before you:

• Sell or transfer equity
• Add or remove owners
• Accept new loans or investors
• Change business control
• Relocate premises
• Enter long-term operational partnerships

Acting first and reporting later is a violation.

Financial Rules Retailers Often Miss

Retail dispensaries cannot:

• Borrow from cultivators, processors, or distributors
• Lend money to other license tiers
• Conceal lenders or investors
• Use undocumented financing

All funds must be documented, traceable, and disclosed.

Cross-tier money is a common enforcement trigger.

Common Renewal Traps

Operators are frequently flagged for:

• Adding investors without approval
• Allowing consultants to act like owners
• Taking vendor loans
• Failing to update OCM after control changes
• Undisclosed restructuring
• Lease terms that give landlords control

Renewal is when hidden influence is discovered.

What Happens If Renewal Is Denied

Denial can result in:

• License expiration
• Forced shutdown
• Enforcement actions
• Required ownership restructuring
• Inability to renew

Most renewal denials are tied to disclosure failures, not store performance.

Go Here Next

• Inspection and Audit Preparation
• Record-Keeping and Retention Rules
• Taxes, Fees, and Regulatory Reporting
• Regulatory Amendments and Legal Changes
• Reference Library

Source Material

• MRTA Sections 78 and 79 and 121 through 124 (Ownership, Control, Agreements)
• 9 NYCRR Adult-Use Licensing Rules
• New York State Corporate and Tax Filing Requirements