Guidance to Unlicensed Establishments Regarding the March 31, 2025 Statutory Deadline
The guidance below is intended to assist and provide clarity to unlicensed establishments that applied during the statutory open application period who are required to have their medical cannabis retailer or internet retailer license issued and be in operation by Monday, March 31, 2025.
1. March 31 Statutory Deadline
March 31, 2025 is the deadline for all remaining unlicensed establishments that applied during the statutory open application period to have their retailer or internet retailer licenses issued and be in operation. D.C. Code 7-1671.06b(2)(C)(i) states in relevant part that those unlicensed establishments that do not meet the March 31, 2025 deadline shall “have its Board approval rescinded or its license application denied by the Board”. There is no provision in the District’s medical cannabis law that allows for an extension beyond the March 31, 2025 deadline.
ABCA interprets the phrase “be in operation” as being able to sell cannabis and cannabis products obtained from a cultivation center or manufacturer licensed in the District to registered medical cannabis patients. As such, unlicensed establishments that applied during the statutory open application period are expected to have their employees registered and be set up in METRC and able to accept and sell medical cannabis to patients no later than March 31, 2025. Questions about getting setup in METRC should be directed to ABCA Program Analyst Nick McLean at [email protected].
Unlicensed operators that applied during the statutory open application period are also advised that your location is required to pass a certified alarm test conducted by the Office of Unified Communications as well as a final inspection by ABCA. ABCA’s Licensing Division must also be provided with any outstanding documentation prior to the issuance of your medical cannabis retailer or internet retailer license.
2. Enforcement
The agency will start taking enforcement action on Tuesday, April 1, 2025, against any remaining unlicensed establishments that applied during the statutory unlicensed establishment open application period that continue to sell cannabis and cannabis products at a location without a medical cannabis retailer or internet retailer license. Illegal cannabis products present after the expiration of the March 31, 2025 deadline will also be subject to seizure. Unlicensed establishments that have their business summarily closed and padlocked by our agency have five business days to request a hearing before the Alcoholic Beverage and Cannabis Board (Board). The Board is required to issue a written decision within five business days after a hearing is held.
Unlicensed businesses that applied during the statutory unlicensed establishment open application period that have their license issued and open by March 31, 2025 are reminded that all cannabis and cannabis products are required to be purchased from a cultivation center or manufacturer licensed in the District. The continued sale of cannabis and cannabis products not purchased from a cultivation center or manufacturer shall be grounds for a medical cannabis retailer or internet retailer license to be summarily revoked by the Board.
Additional questions regarding a pending medical cannabis license application should be sent to [email protected].