NY Cannabis Registered Organization (RO) Rules Explained

Legal Standing in the System

Registered Organizations

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

Nothing in the MRTA exempts Registered Organizations from adult use operational, reporting, testing, or security requirements.

What a Registered Organization Is 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 adult use retail co location

These privileges exist only within the boundaries of the RO license structure. They do not permit unrestricted expansion across unrelated license tiers.

Co Location Rules for Adult Use Retail

If approved for adult use operations, a Registered Organization must maintain clear separation between medical and adult use programs.

Physical Separation Requirements

Co located dispensaries must demonstrate

• Physically separate retail spaces
• Distinct entrances and customer pathways
• Separate inventory rooms
• Separate point of sale systems
• Staff assigned specifically to medical or adult use operations

Medical services must remain uninterrupted and accessible to patients.

Medical and adult use inventory may not be combined.

Supply Chain and Tracking Requirements

Registered Organizations must comply with the same manufacturing, retail, transport, and reporting standards required of all license types when engaging in adult use activity.

Inventory and METRC

• METRC seed to sale tracking for adult use inventory
• Segregated tracking systems for medical and adult use
• Documented batch movement and reconciliation

Testing and Compliance

• Mandatory testing through approved third party laboratories
• Documented standard operating procedures
• Incident reporting and compliance logs
• Required reporting to OCM and, where applicable, the Department of Health

All product movement must be traceable and tied to the appropriate program.

Limits and Restrictions

Registered Organizations may not

• Sell untested or improperly labeled products
• Mix medical and adult use inventory
• Share premises with unrelated licensees
• Expand into unrelated adult use license tiers outside the RO framework
• Operate without required workforce training

Scale does not reduce oversight.

What Operators Often Miss

• Co location requires true physical separation
• Adult use inventory must be tracked independently
• RO status does not override adult use compliance rules
• Medical operations must remain uninterrupted
• Ownership and control restrictions still apply

Registered Organizations operate under dual regulatory oversight.

When This Comes Up

• Applying for medical licensure
• Applying for adult use co location approval
• Designing facility layouts
• Structuring inventory systems
• Preparing for inspection

What Happens If You Ignore These Requirements

Noncompliance may result in

• Denial of adult use approval
• Fines and enforcement actions
• Suspension
• Revocation
• Heightened regulatory scrutiny

Registered Organizations are permitted broader operational scope but not broader compliance flexibility.

Related OCM Licensing Section Pages

• Adult-Use Retail License
• Microbusiness License
• Processor License
• Distributor License
• Cultivator License
• Delivery License

Source Material

• MRTA Section 68 (Registered Organization Provisions)
• MRTA