If you’re building a cannabis business in New York, you already know it’s not for the faint of heart. From shifting regulations to tight deadlines, the pressure to stay compliant can feel constant, and sometimes overwhelming.
At Seligson Law, we’ve worked with cannabis operators across New York and California, helping them navigate everything from licensing delays to regulatory curveballs. Our team, led by attorney Ken Seligson, brings legal insight grounded in real-world industry experience. Whether you’re just starting out or racing to meet final licensing deadlines, we’re here to help you move forward with clarity and confidence.
If you hold a New York adult-use cannabis provisional license, you’ve likely heard the news: the Office of Cannabis Management (OCM) has granted a 6-month extension for certain licensees. While that’s welcome relief, it’s not a reason to slow down. This is a limited window, and the clock is already ticking.
What the 6-Month Extension Means
Provisional adult-use licensees who were approved on or before February 1, 2025, now have six more months before their provisional license expires.
This change stems from a resolution adopted by the New York Cannabis Control Board (CCB) in early 2025, which temporarily extends timelines for provisional licensees under specific conditions.
But here’s the catch: even with this extension, provisional licenses remain non-renewable under 10 NYCRR § 120.4, meaning that once your updated expiration date arrives, you must have your final adult-use license in place or risk losing your provisional status entirely.
No, You Don’t Need to Be Fully Operational Yet
A common misconception is that a business must be fully up and running to qualify for a final license. But the Cannabis Law Section 67 and supporting OCM guidance make it clear: you do not need to be operational to transition to a final license.
You do not need:
- A completed or open facility
- “Approval to Commence” from the OCM
- Active customer operations
Final licensure is about demonstrating readiness and compliance, not about being open for business. Waiting to apply until everything is “perfect” may put your license at risk.
What You Do Need to Secure Final Licensure
Transitioning from a provisional license to a final one does come with specific legal requirements. Under 10 NYCRR § 120.6, final licensure requires applicants to submit:
- All completed licensure forms
- Updated ownership and operations documentation
- Proof of a compliant business location
Your physical location must meet both state-level siting criteria and any local municipal opt-out or zoning rules under Cannabis Law § 76. The OCM’s LOCAL Map tool is one of the best ways to confirm whether your proposed location qualifies.
How to Use the Extension Strategically
Six months might seem like a long time, but it can fly by quickly in this industry. Here are some simple but effective steps to make the most of the time you’ve been given:
Contact Our New York Cannabis Lawyers at Seligson Law Today
Getting to the finish line in New York’s adult-use cannabis program is about more than just paperwork, it’s about staying prepared and avoiding small mistakes that can lead to big setbacks.
At Seligson Law, we work with cannabis licensees who need straightforward legal guidance backed by experience. Whether you’re dealing with siting, compliance, investor structure, or application requirements, we’re here to walk you through it all with clarity and strategy. Because in this business, extensions are rare, but the risks of falling behind are very real.
Contact us today at 213-293-6692 for an initial consultation.
