Cannabis Licensee Variance Requests

In accordance with 560-RICR-1.3.3, “All applicants, provisional licensees and licensees must seek pre-approval from the Commission by means of requesting a variance for all material changes to the submitted and/or approved application or any materials, operations or plans approved thereafter by the Commission.”  All variance requests must be submitted via the state’s Licensing Portal, available here:

A user guide that provides instructions for each type of variance request is included at the bottom of this page.

A variance request and approval is required for material changes which may include, but are not limited to, changes to operational procedures, moving licensed locations, adding or removing owners, and updates related to licenses or administrative actions in other states.

Several types of changes require a variance request to be submitted at least sixty (60) days prior to their proposed effective date. These are as follows:

• Proposed change in ownership of the proposed or licensed cannabis establishment;
• Proposed change in the membership of a board of directors, board of trustees, or corporate officer;
• Proposed merger, dissolution, entity conversion or amendment of corporate organization;
• Proposed entering into a management agreement, changing management companies, and/or material changes to an existing management agreement;
• Proposed changes to the approved premises or location;
• Proposed changes in the interest holder/key person disclosure and certification or certification of nonprofit compliance, including but not limited to investors and financiers, and anyone else required to be disclosed in those forms;
• Proposed changes to approved premises floor plan including expanding or modifying the scope or scale of approved and/or licensed activity:
• Proposed changes to operations, including but not limited to implementation or modification of curbside pick-up, home delivery, or manufacturing plans and/or processes;
• Proposed changes to security and safety plans, operations manual and business plans;
• Proposed plans to discontinue operations on a reasonable and temporary basis as determined and approved by the Commission. The license shall be void and returned to the Commission if the cannabis establishment discontinues its operation without Commission approval;

In addition to the above, applicants, provisional licensees and licensees must notify the Commission of any change of status of cannabis applications, licensure, disciplinary or enforcement activity in other jurisdictions within five (5) days of the change occurring via a variance request. 

While many variance requests can be processed by Cannabis Office staff, several, including those related to a change in majority ownership, require a public hearing before the Commission. An overview of the different types of variance requests and whether they may be processed by the Cannabis Office and which require Commission approval can be found in at this link