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Maryland Cannabis Administration

Conditional License Extension Requests

Notice |

IMPORTANT NOTICE -  Conditional License Extension Requests

First and foremost, thank you for your ongoing dedication and hard work toward building Maryland’s cannabis industry. We know that establishing a new business comes with unique milestones and challenges, and the Maryland Cannabis Administration (MCA) is here to help support you through every step of the regulatory process. 

As part of our commitment to keeping you informed, we want to share an important reminder regarding your licensing timeline so you can plan ahead effectively. 

This notice is an important reminder that the conditional license period expires twenty-four (24) months after the date your conditional license was issued by the Maryland Cannabis Administration (MCA) per the Code of Maryland Regulations (“COMAR”) 14.17.05.05A(1)(b). The first conditional licenses were issued in July 2024 and will therefore expire in July 2026 if the applicant has not completed the requirements for licensure or MCA does not receive an extension request. 

MCA has discretion to issue up to two (2) six-month extensions if MCA determines the conditional licensee “has made consistent good faith efforts to establish a cannabis business.” However, it is your responsibility to request an extension, pursuant to COMAR 14.17.05.05A(2). 

The MCA will consider the following as ways to demonstrate consistent good faith efforts: 

  1. Demonstrating legal control of a premises which requires that the premises are: (a) suitable for operations of the cannabis license; and (b) complies with local planning and zoning requirements; 
  2. Provide a fully executed Letter of Intent demonstrating the applicant’s plan to locate at the premises described in the letter, which must be suitable for the operations of the business; or 
  3. Providing adequate documentation that a political subdivision has unduly burdened the conditional licensee’s efforts to become operational, as defined in Md. Code Ann., Al. Bev. & Cann., §36-405. 
  4. MCA will evaluate extension requests based on circumstances other than those described above, provided the conditional licensee demonstrates good faith efforts through objective documentation.

In order to demonstrate legal control of the premises, the conditional licensee must provide to MCA a lease, purchase agreement, or other acceptable form specific to the location of the proposed location. Additionally, the premises must be suitable for the operations of the cannabis license and must comply with local planning and zoning requirements.

If you are not yet operational, we encourage you to complete the form at the following link: https://mmcc.seamlessdocs.com/ng/fa/ExtensionRequest. Those conditional licensees seeking to file an extension request must do so by completing the form and providing all required documentation at the same link. For those conditional licensees not yet ready to file an extension request, the information provided in this form will help the MCA better understand the positioning of conditional licensees and the challenges you are facing. 

The MCA urges you to submit the request at least 30 days before the expiration of the conditional license period. This provides sufficient time for MCA to review the request and, if necessary, allows the conditional licensee an opportunity to correct any errors or omissions before the conditional license period expires. MCA generally expects to issue a decision within 30 days of receiving a complete extension request. 

While MCA is considering the extension request, the conditional license period will be automatically extended for the duration of MCA’s review. If the extension is granted, it will apply retroactively to the date of the conditional license period ended. 

If the extension request is denied, MCA will notify the conditional licensee of its decision and your conditional license will be subject to rescission based on COMAR 14.17.05.05A(4). If the conditional licensee disputes the decision, it is entitled to an evidentiary hearing before the Administration in accordance with Md. Code Ann., Alc. Bev. § 36-202. A written request for an evidentiary hearing must be submitted no later than 30 calendar days after the date of the denial letter. The evidentiary hearing will be conducted in accordance with the Administrative Procedure Act, Md. Code Ann., State Gov’t § 10-201 et seq., and MCA’s hearing regulations set forth in COMAR 14.17.22. 

If a conditional licensee has not met the requirements for final licensure by the expiration of the conditional license period and you have not requested an extension, your conditional license will be subject to rescission based on COMAR 14.17.05.05B(6). For this reason, the MCA encourages all licensees to continue to read correspondence from the MCA and remain in touch with your direct point of contact.