How to cannabis. Where to apply?

Green Rush Advisory Group, LLC · US Cannabis Licensing Authorities

“Who do I contact to apply for a cannabis license?”

An analysis of all of the state licensing authorities for legal cannabis programs in the United States. Completing, perfecting, and submitting your state’s application for a cannabis license is invariably a mandatory process, however, pro tip, focus first on your local authority approval. Increasingly, and part of how politicians overcome local authority resistance to legalized cannabis programs, those local authorities are empowered to have a say about the cannabis activity that occurs in their jurisdiction. Local authority control over your cannabis business ranges from full prohibitions against any cannabis activity, to having a comprehensive overlay of their own regulatory requirements and application processes.

The Landscape of Cannabis Legalization in the United States: Early 2025

Executive Summary:

As of early 2025, the legal landscape surrounding cannabis in the United States presents a complex and rapidly evolving picture. A significant majority of states, totaling 39 including the District of Columbia, have enacted some form of legislation permitting cannabis use, reflecting a strong and continuing trend towards its broader acceptance. This includes a spectrum of approaches, from comprehensive adult-use and medical programs to more restricted medical-only access and even limited allowances for specific cannabis compounds like CBD. Specifically, 25 states and the District of Columbia have legalized cannabis for both recreational and medical purposes, while 14 states permit medical use only. One state maintains a limited medical program focused solely on CBD products. This distribution underscores a common trajectory in cannabis policy, where medical legalization often serves as an initial step before the more widespread adoption of adult-use frameworks. However, the continued presence of medical-only states indicates that medical access remains a primary consideration in many jurisdictions. The regulatory oversight of this burgeoning industry is managed by a diverse range of state agencies, each with its own specific focus and responsibilities. Furthermore, the financial implications of obtaining and maintaining licenses to operate within the cannabis sector are substantial and vary considerably across different states.

State-by-State Breakdown of Cannabis Legalization:

The foundation of understanding the current state of cannabis legalization lies in examining the specific laws enacted by each state. The following table provides a snapshot of the legal status of cannabis across the United States as of early 2025:

Table 1: US States with Legal Cannabis Programs (Early 2025)

State	Recreational Legal?	Medical Legal?
Alabama	No	Yes
Alaska	Yes	Yes
Arizona	Yes	Yes
Arkansas	No	Yes
California	Yes	Yes
Colorado	Yes	Yes
Connecticut	Yes	Yes
Delaware	Yes	Yes
District of Columbia	Yes	Yes
Florida	No	Yes
Georgia	No	Limited (CBD)
Hawaii	No	Yes
Illinois	Yes	Yes
Kentucky	No	Yes
Louisiana	No	Yes
Maine	Yes	Yes
Maryland	Yes	Yes
Massachusetts	Yes	Yes
Michigan	Yes	Yes
Minnesota	Yes	Yes
Mississippi	No	Yes
Missouri	Yes	Yes
Montana	Yes	Yes
Nevada	Yes	Yes
New Hampshire	No	Yes
New Jersey	Yes	Yes
New Mexico	Yes	Yes
New York	Yes	Yes
North Dakota	No	Yes
Ohio	Yes	Yes
Oklahoma	No	Yes
Oregon	Yes	Yes
Pennsylvania	No	Yes
Rhode Island	Yes	Yes
South Dakota	No	Yes
Utah	No	Yes
Vermont	Yes	Yes
Virginia	Yes	Yes
Washington	Yes	Yes
West Virginia	No	Yes

Examining this table reveals that a significant number of states have embraced the legalization of cannabis in some form. The 24 states along with the District of Columbia that have legalized both recreational and medical cannabis represent a substantial portion of the country, indicating a growing acceptance of cannabis for various uses. These states include Alaska, Arizona, California, Colorado, Connecticut, Delaware, Illinois, Maine, Maryland, Massachusetts, Michigan, Minnesota, Missouri, Montana, Nevada, New Jersey, New Mexico, New York, Ohio, Oregon, Rhode Island, Vermont, Virginia, and Washington.

Conversely, 14 states currently permit cannabis for medical purposes only: Alabama, Arkansas, Florida, Hawaii, Kentucky, Louisiana, Mississippi, New Hampshire, North Dakota, Oklahoma, Pennsylvania, South Dakota, Utah, and West Virginia. These states have established regulatory frameworks to allow patients with qualifying medical conditions to access cannabis under the guidance of healthcare professionals.

Finally, Georgia stands alone in offering a limited medical program, primarily focused on CBD products. This more cautious approach suggests a state taking initial steps into the realm of cannabis legalization, potentially as a way to study its effects and gauge public opinion before considering broader programs 1.

To further clarify the overall landscape, the following table summarizes the number of states within each category of cannabis legalization:

Table 2: Summary of Cannabis Legalization Status by Category

Legalization Category	Number of States	List of States
Recreational & Medical	25	Alaska, Arizona, California, Colorado, Connecticut, Delaware, District of Columbia, Illinois, Maine, Maryland, Massachusetts, Michigan, Minnesota, Missouri, Montana, Nevada, New Jersey, New Mexico, New York, Ohio, Oregon, Rhode Island, Vermont, Virginia, Washington

The data presented in these tables highlights a clear trend: states that have legalized cannabis often start with a medical program before moving towards recreational legalization. The existence of a substantial number of states with both recreational and medical programs supports this observation. The limited prevalence of states with highly restrictive programs like Georgia’s suggests that this is typically an initial phase rather than a long-term policy stance for most jurisdictions.

Regulatory Authorities and Licensing Frameworks:

The responsibility for regulating and licensing cannabis businesses falls primarily to state-level agencies, although local authorities can also play a significant role. The specific agencies and their mandates vary considerably from state to state.

In Arizona, the Arizona Department of Health Services (ADHS) is the key licensing authority for both adult-use and medical marijuana. This agency oversees various aspects of the industry, including retail sales, cultivation, manufacturing, and testing facilities 2. Businesses intending to sell marijuana or marijuana products must first obtain licensing from the ADHS before they can register for a Marijuana Excise Tax (MET) registration number and a Transaction Privilege Tax (TPT) license through the Arizona Department of Revenue (ADOR), which is responsible for collecting taxes on cannabis sales 2. This division of responsibilities ensures that the ADHS focuses on regulating the industry while ADOR manages the financial aspects.

Arkansas takes a different approach, with the Medical Marijuana Commission (MMC) under the Arkansas Department of Finance and Administration (DFA) tasked with administering and regulating the issuance of licenses specifically for medical marijuana dispensaries and cultivation facilities 4. It is important to note that the MMC does not handle the issuance of Medical Marijuana Patient Cards, which falls under the purview of the Arkansas Department of Health 4. This separation allows the MMC to concentrate on the business side of the medical cannabis program.

California operates a more complex regulatory system. The Department of Cannabis Control (DCC) licenses and regulates all commercial cannabis activity within the state, encompassing retail, distribution, testing, and microbusinesses 6. However, operating a cannabis business in California requires both local approval from the city or county and a state license to be legal 6. Additionally, the California Department of Food and Agriculture (CDFA) is responsible for licensing cannabis cultivation businesses, while the California Department of Public Health (CDPH) manages businesses involved in cannabis manufacturing 6. This multi-agency approach, coupled with local control, reflects the scale and complexity of California’s cannabis market.

In Colorado, the Colorado Marijuana Enforcement Division (MED) serves as the primary state regulatory authority for both medical and recreational marijuana 8. However, within Denver, the Denver Department of Excise and Licenses also plays a crucial role in local licensing and the implementation of city-specific regulations 8. This layered system allows for both statewide standards and local adaptations to address community needs.

Connecticut has entrusted the Connecticut Department of Consumer Protection (DCP) with the licensing of all cannabis establishments in the state. This includes a wide range of license types, such as producers, dispensaries, cultivators, retailers, manufacturers, product packagers, and delivery services 13. A significant aspect of Connecticut’s framework is the requirement for cannabis establishments to receive local zoning approval before the state grants final licensure 13. This provision ensures that local municipalities have a say in where cannabis businesses can operate.

Delaware has established the Office of the Marijuana Commissioner (OMC) as the agency responsible for regulating the recreational marijuana industry 15. The OMC’s mandate includes safeguarding public health, preventing underage use, generating tax revenue, and fostering an equitable and competitive marijuana market 15. This dedicated office signifies the state’s focused approach to overseeing its new recreational cannabis market.

The District of Columbia divides its regulatory responsibilities based on the type of cannabis use. The Department of Health (DOH) regulates medical cannabis, while the Alcoholic Beverage Regulation Administration (ABRA) oversees recreational cannabis 17. This separation allows each agency to apply its specific expertise to the respective programs.

In Florida, the Florida Department of Health, Office of Medical Marijuana Use (OMMU), is the authority responsible for issuing Medical Marijuana Treatment Center (MTC) licenses 20. These licenses are comprehensive, authorizing various marijuana business activities, including cultivation, processing, and dispensing, and Florida does not issue separate licenses solely for distribution 20.

Georgia‘s regulatory structure involves the Georgia Access to Medical Cannabis Commission (GMCC) for licensing medical cannabis production and dispensing (mentioned in22. Additionally, the Department of Public Health (DPH) manages the Low THC Oil Registry, which allows qualified patients to legally obtain low-THC oil 1. This dual structure reflects the state’s specific approach to limited medical cannabis access.

Hawaii‘s medical cannabis program is managed by the Hawaii Department of Health (DOH) through its Medical Cannabis Registry Program 25. This program facilitates access for patients with qualifying medical conditions.

Illinois employs a multi-agency system. The Cannabis Regulation Oversight Office (CROO) coordinates among all agencies involved in regulating and taxing the cannabis industry 27. The Illinois Department of Agriculture (IDOA) licenses cultivation centers, craft growers, infusers, and transporters 28, while the Illinois Department of Financial and Professional Regulation (IDFPR) licenses dispensing organizations 29.

As Kentucky prepares to launch its medical cannabis program in 2025, the Kentucky Medical Cannabis Program, under the Cabinet for Health and Family Services, will oversee the licensing of various cannabis businesses 30. The Kentucky Board of Medical Licensure (KBML) is responsible for authorizing physicians to provide written certifications for medical cannabis use 30.

Louisiana has different agencies overseeing different aspects of cannabis. The Louisiana Department of Health (LDH) manages the medical marijuana program, which requires a physician’s recommendation rather than a state-issued card 32. Industrial hemp is regulated by the Louisiana Department of Agriculture and Forestry (LDAF) 33, and consumable hemp products fall under the jurisdiction of the Louisiana Office of Alcohol and Tobacco Control (ATC) 35.

In Maine, the Office of Cannabis Policy (OCP) handles the registration, licensing, compliance, and general oversight for both medical and adult-use cannabis programs 36.

Maryland‘s regulatory landscape is now managed by the Maryland Cannabis Administration (MCA), which was previously known as the Maryland Medical Cannabis Commission (MMCC). The MCA oversees both medical and recreational marijuana in the state 37.

Massachusetts has established the Cannabis Control Commission (CCC) to administer the laws enabling access to medical and adult-use marijuana in the Commonwealth 39.

Michigan‘s cannabis market, both medical and adult-use, is regulated by the Cannabis Regulatory Agency (CRA), which was formerly known as the Marijuana Regulatory Agency (MRA) 40.

Minnesota‘s adult-use cannabis market, which began its rollout in early 2025, is overseen by the newly established Office of Cannabis Management (OCM) 42.

Mississippi involves multiple agencies in its medical cannabis program. The Mississippi Medical Cannabis Agency (MMCA) provides general assistance and information 44, the Mississippi Department of Health (MSDH) also plays a role 44, and the Mississippi Department of Revenue (MDOR) is responsible for licensing medical cannabis dispensaries 44.

Missouri‘s Department of Health and Senior Services (DHSS) is responsible for the licensing and regulation of both medical and comprehensive (adult-use) cannabis 46.

In Montana, the Cannabis Control Division (CCD) within the Department of Revenue is tasked with developing and regulating the state’s medical and adult-use cannabis programs 48.

Nevada‘s cannabis industry is governed by the Nevada Cannabis Compliance Board (CCB), which has broad authority over licensing and operations 50.

New Hampshire‘s medical cannabis program, known as the Therapeutic Cannabis Program (TCP), is managed by the Department of Health and Human Services (DHHS) 52.

New Jersey has established the Cannabis Regulatory Commission (CRC) to regulate both its medicinal and recreational cannabis programs 54.

New Mexico‘s cannabis market is overseen by the Cannabis Regulation and Licensing Department (RLD), which includes the Cannabis Control Division (CCD) 56.

New York employs a two-tiered regulatory structure, with the Office of Cannabis Management (OCM) implementing regulations and the Cannabis Control Board (CCB) providing approval and oversight 58.

North Dakota‘s Medical Marijuana Program is managed by the Department of Health and Human Services 60.

Ohio divides its regulatory responsibilities among the Department of Commerce for business licensing, the State Medical Board of Ohio for physician certifications, and the Division of Cannabis Control (DCC) for patient and caregiver registration 61.

Oklahoma‘s medical marijuana program is overseen by the Oklahoma Medical Marijuana Authority (OMMA) 64.

Oregon combines the regulation of liquor and cannabis under the Oregon Liquor and Cannabis Commission (OLCC) 66.

Pennsylvania‘s Medical Marijuana Program is overseen by the Pennsylvania Department of Health (mentioned in68.

Rhode Island has established the Cannabis Control Commission (CCC) to regulate both adult-use and medical cannabis 70.

The South Dakota Medical Cannabis Program is managed by the South Dakota Department of Health 72.

Utah‘s Industrial Hemp and Medical Cannabis Division, under the Utah Department of Agriculture and Food, oversees the state’s medical cannabis program 74.

Vermont‘s Cannabis Control Board (CCB) is responsible for administering the state’s adult-use and medical cannabis programs, as well as regulating hemp and CBD product manufacturing 75.

Virginia‘s Cannabis Control Authority has broad control over the state’s retail marijuana market 77.

Washington‘s regulatory framework is managed by the Washington State Liquor and Cannabis Board (WSLCB), which oversees cannabis along with liquor, tobacco, and vapor products 79.

Finally, West Virginia‘s medical cannabis program is overseen by the Office of Medical Cannabis 96, and Alabama‘s medical cannabis program is regulated by the Alabama Medical Cannabis Commission (AMCC), with physician certifications handled by the Alabama Board of Medical Examiners (ALBME) 97.

Across these states, a variety of license types are typically issued to cover the different aspects of the cannabis industry. These commonly include licenses for cultivation (growing cannabis), processing (extracting and refining cannabis), manufacturing (creating cannabis-infused products), retail or dispensaries (selling to consumers), testing laboratories (analyzing cannabis products for safety and potency), and transportation (moving cannabis between licensed facilities) 6. The specific types of licenses available and the activities they authorize vary depending on the state’s laws and the maturity of its cannabis market.

Financial Aspects of Cannabis Licensing:

The financial costs associated with entering and operating within the cannabis industry are significant and multifaceted, encompassing application fees, annual licensing fees, and in some cases, surety bond requirements. These costs vary considerably from state to state and often depend on the type and scale of the cannabis business.

In Kentucky, which is launching its medical cannabis program in 2025, initial application fees for cannabis business licenses range from $3,000 for Tier I cultivators and Safety Compliance Facilities to $30,000 for Tier IV cultivators 101. Processors and Producers face an initial fee of $5,000, while Dispensaries also pay $5,000, in addition to the applicable cultivator tier fee for Producers 101. The annual renewal fees are even more substantial, ranging from $12,000 for Tier I cultivators and Safety Compliance Facilities to $100,000 for Tier IV cultivators 101. Processors and Producers will pay an annual renewal fee of $25,000, with Dispensaries facing a $30,000 annual renewal fee, plus the cultivator tier renewal fee for Producers 101. These fees must be paid electronically at the time of submission and are generally nonrefundable, except in specific circumstances for initial applications submitted after the designated timeframe 101.

Washington State has a different fee structure. Application fees for cannabis licenses are typically $250 for research and transportation licenses, while other licenses like producer, processor, and retailer have a $1,000 application fee 80. However, these fees are generally non-refundable 88. Annual licensing fees in Washington range from $450 to $1,500 for hemp licenses 83, and can go up to $7,000 for standard cultivation, product manufacturing, and retail store licenses 102.

California‘s financial landscape for cannabis licensing is characterized by application fees that are generally $1,000, with some exceptions for smaller cultivation operations 104. However, the annual license fees vary significantly based on the gross annual revenue of the business and the specific license type. These fees can range from as low as $200 for very small transport-only distributors to as high as $300,000 for large microbusinesses 104. All application fees in California are nonrefundable 111.

In Colorado, the financial requirements for cannabis licensing also vary. In Denver, social equity licensees may have city application fees waived and pay a reduced city license fee of $1,500 annually for retail stores, while non-social equity applicants face a $2,000 application fee and a $3,000 annual license fee 10. At the state level, application fees can range from $0 for social equity medical marijuana transporter licenses in Denver to $5,000 for initial retail marijuana store applications 10. Annual license fees also show significant variation, ranging from a few hundred to several thousand dollars depending on the license type and location 10. Application fees are generally non-refundable in Colorado 121.

Connecticut employs a lottery system for many cannabis licenses, with entry fees ranging from $125 for social equity micro-cultivator, food and beverage manufacturer, and delivery/transporter licenses to $1,000 for general cultivator licenses 125. Provisional license fees range from $250 for social equity micro-cultivators to $25,000 for general cultivators 125. Final license fees vary from $500 for social equity micro-cultivators to $75,000 for general cultivators 125. All lottery and license application fees in Connecticut are non-refundable 130.

In Delaware, application fees for cannabis licenses range from $1,000 for social equity applicants to $5,000 for open applicants 132. Microbusiness applicants pay a $3,000 application fee 132. These application fees are non-refundable 132. Biennial license costs range from $2,500 to $10,000, depending on the license type and cultivation size 132. Social equity licensees pay a discounted rate of 40% of the applicable open license fee 132.

The District of Columbia has conditional application fees of $200 for social equity applicants and $800 for standard applicants 84. Standard license application fees range from $0 for testing laboratories to $8,000 for retailers, internet retailers, and cultivation centers 84. Annual licensing fees range from $4,000 for manufacturers (Type 1) to $36,000 for Tier 6 cultivation centers 84. Social equity applicants may have up to 75% of nonrefundable license fees waived for the first three years 146.

Florida stands out with a very high application fee of $146,000 for a Medical Marijuana Treatment Center (MTC) license 20. The biennial renewal fee for these licenses is also substantial at $1.33 million 20. In contrast, the annual fee for a patient medical marijuana card is $75 155. Application fees for MTC licenses are non-refundable 150.

In Hawaii, the application fee for patient registration is $38.50 for a one-year term or $77 for a two-year term 157. These fees are non-refundable 159. For cannabis businesses, the initial license fee is $75,000, with an annual renewal fee of $50,000 161.

Illinois has application fees ranging from $250 for social equity adult-use dispensing organization applicants to $100,000 for medical cultivation centers 163. Licensing fees range from $40,000 for craft growers to $200,000 for medical cultivation centers 163. Social equity applicants receive a 50% discount on application fees and may have licensing fees waived in some cases 163. All application fees are non-refundable 166.

Louisiana has relatively lower licensing fees compared to many other states. Industrial hemp licenses for growers, processors, handlers, and seed producers each cost $500 annually 33. The annual fee for a cannabis business license is $2,500, and a personal cultivation permit has an annual fee of $100 170. Application fees for consumable hemp wholesaler permits are $500 and are non-refundable 171.

Beyond application and licensing fees, many states also have surety bond requirements for cannabis businesses. These bonds serve as a financial guarantee that the business will comply with state regulations. In California, a surety bond of at least $5,000 is required for each licensed premises 172. Arkansas may require dispensaries to post a $100,000 performance bond and cultivators a $500,000 performance bond 178. In Connecticut, medical marijuana producers need performance bonds of $1.5 million for operation and $2 million for facility construction 183. Florida mandates a substantial $5 million performance bond for MTCs, or $2 million if they serve at least 1,000 patients 186. Illinois requires dispensaries to have a $50,000 surety bond, while cultivators may need bonds of $1.5 million or $2 million 169. Ohio has bond or escrow requirements ranging from $75,000 to $750,000 depending on the license type 191. While not explicitly detailed in the provided snippets, Alabama likely has surety bond requirements for some cannabis license types, as is common in regulated industries 186.

Social Equity in Cannabis Licensing:

Recognizing the disproportionate impact of cannabis prohibition on certain communities, many states have incorporated social equity provisions into their licensing frameworks. These initiatives aim to reduce barriers to entry for individuals and businesses from these communities through various mechanisms.

Arizona offers reduced application fees for social equity applicants seeking initial marijuana establishment licenses 199.

Connecticut provides significant reductions in lottery entry fees, provisional license fees, and final license fees for applicants who qualify under their social equity program 125.

Delaware also offers discounted application and license fees for both social equity and microbusiness applicants, aiming to promote a more diverse industry 132.

The District of Columbia provides substantial fee reductions for social equity applicants for the first three years of operation, waiving up to 75% of nonrefundable license fees, including application and annual fees 84.

Illinois offers a 50% discount on application fees for those who qualify for social equity status. Additionally, licensing fees may be waived entirely for certain social equity applicants 163.

Minnesota has taken a unique approach by reserving half of the available licenses for capped license types (mezzobusiness, cultivator, manufacturer, retailer) specifically for verified social equity applicants. These applicants also receive two opportunities in the licensing lottery process 42.

Even in established markets like Colorado, efforts are being made to promote social equity. In Denver, social equity licensees benefit from $0 city application fees and reduced city license fees for various cannabis business types 10.

These examples illustrate a growing trend across the United States to actively address the social and economic disparities created by past cannabis policies. States are employing various strategies to ensure that the legal cannabis industry provides opportunities for those who have been most affected by prohibition.

Future Developments and Program Timelines:

The cannabis industry is characterized by continuous change, with new programs launching and existing ones evolving. Early 2025 is expected to be a period of significant activity in several states.

Kentucky‘s medical cannabis program is slated to become legal on January 1, 2025 30. The Kentucky Board of Medical Licensure began accepting applications from physicians seeking authorization to provide written certifications for medical cannabis on July 1, 2024 30.

In Delaware, the issuance of licenses for retail marijuana stores and testing facilities is scheduled to begin on March 1, 2025 15.

Minnesota officially began accepting applications for cannabis business licenses on February 18, 2025, with the application window closing on March 14th. Lotteries for capped license types are anticipated to take place between May and June 2025 42.

The Arkansas Medical Marijuana Commission has a scheduled meeting on February 6, 2025 4.

The Nevada Cannabis Compliance Board has a board meeting scheduled for March 20, 2025 50.

New York’s Cannabis Control Board held a full board meeting on February 14, 2025 58.

In Colorado, the city of Colorado Springs will begin accepting applications from existing medical marijuana licensed locations to add a retail marijuana license starting on February 10, 2025 124.

These upcoming developments and ongoing processes highlight the dynamic nature of the cannabis industry and the continued expansion of legal markets across the country.

Conclusion:

The cannabis legal landscape in the United States as of early 2025 is marked by significant diversity and ongoing evolution. The analysis reveals a complex tapestry of state-specific regulations, licensing frameworks, and financial considerations. The absence of federal legalization continues to foster a decentralized approach, with each state crafting its own policies regarding medical and adult-use cannabis.

A clear trend emerges where medical legalization often precedes the broader acceptance of recreational cannabis, suggesting a common pathway for policy development. However, the specific regulatory authorities, the types of licenses issued, and the stringency of these regulations vary considerably. Financial aspects, including application fees, annual license costs, and surety bond requirements, represent substantial investments for businesses seeking to operate in this sector, with significant differences observed across states.

The increasing focus on social equity within cannabis licensing is a noteworthy development, indicating a growing recognition of the need to address the historical harms of cannabis prohibition. Various states are implementing programs to lower barriers to entry for individuals and communities disproportionately affected by past drug laws.

Looking ahead, early 2025 is a period of significant activity, with new programs launching, regulations being refined, and licensing opportunities emerging in several states. This dynamic environment underscores the continued growth and maturation of the US cannabis market. Navigating this complex and state-specific regulatory landscape requires a thorough understanding of the individual laws and policies of each jurisdiction. The future of the industry will likely be shaped by ongoing state-level policy changes and the potential for future federal reform.