Conditional License Extensions

On October 10, 2025, the Maryland Cannabis Administration (MCA) submitted to the Administrative, Executive and Legislative Review (AELR) committee a Notice of Proposed Action (NOPA) to amend COMAR 14.17.01, .02, .05, .06, .10-.15, .18, and .21. The NOPA proposes a number of policy updates, including an extension of the conditional license period from 18 to 24 months. The MCA anticipates the proposed regulations will take effect in January 2026. 

The MCA is extending the conditional license period from 18 to 24 months to give licensees additional time to overcome several significant hurdles to becoming operational. A primary challenge is securing suitable business locations that meet local zoning and planning requirements. Licensees have faced difficulties raising adequate start-up capital and accessing anticipated State resources. These issues, along with other unexpected challenges such as potential government shutdown impacts, have made the initial 18-month timeline unfeasible for many conditional licensees. The extension is intended to provide necessary time for businesses to navigate these obstacles and move toward final licensure. 

For any conditional licensees whose 18-month conditional license period ends before the proposed regulations take effect, MCA will not rescind conditional licenses solely because the business is not operational by that deadline. 

To determine the revised expiration date of your conditional license period based on the 6month extension, add 6 months to the deadline to become operational stated in your conditional license award letter. For example, if your original deadline is January 11, 2026, it is now July 11, 2026. 

MCA will continue to keep conditional licensees informed about possible extensions after 24 months.  Please direct any questions regarding this bulletin to [email protected].