Frequently Asked Questions - Adult-Use Retail License Application

Adult Use Retail License Application Frequently Asked Questions

Last Updated: 10/03/2025

1. Will Workers’ Cooperative Retail License applicants need to show that the applicant is in fact structured as a worker-owned entity?

Yes. At the application phase, a Workers’ Cooperative applicant will need to be structured as and meet the requirements of Chapter 6.2 of Title 7, the Rhode Island statute governing Workers’ Cooperatives.

2. Is there a specific amount of capital or money that an applicant must have or demonstrate at the time of application?

No. However, at the time of application, applicants are required to provide a detailed description of the amount and source of equity, debt, and operating capital, including financial statements or other documentation establishing the source of any funds.

3. Is a contingent lease sufficient to satisfy the proposed physical location site control requirement?

A lease with an effective date contingent upon being selected for a license is sufficient to satisfy site control at the application phase. The lease must allow the operation of a cannabis establishment on the property, cannot be at a shared location with another licensee and must afford the applicant exclusive rights to the property. As such, no more than one applicant can demonstrate such rights at a single location.

4. If more than one applicant holds a contingent lease for the same property, is site control satisfied, or will this disqualify one or both applicants?

Since an applicant must have exclusive rights to their proposed cannabis establishment property, no more than one applicant can hold a lease for the same physical location, whether they have a contingent lease or a regular lease. If multiple applicants provide leases for the same physical property, the applications may be disqualified for not being able to demonstrate the site control requirement. It is the responsibility of each applicant to ensure that no other leases exist for the same proposed physical property.

5. Will the random selection process, or lottery, occur at the same time for all three retail license categories?

The Commission intends to conduct the selection process for all three retail license types—general, social equity, and workers’ cooperative—in close proximity, at a time and date that will be announced. Please continue to check our website and sign up for our email list to know when each selection process will take place.

6. Can I submit letter of intent to lease or to purchase a property to satisfy the requirement of a proposed physical location for my cannabis establishment?

No. A letter of intent is not sufficient to satisfy the site control requirement. Only an executed lease or document evidencing property ownership will satisfy the site control requirement at the application phase.

7. Do I need a background check, often referred to as NCIC, prior to applying for an adult use retail license?

Individuals will have to attest that they have no disqualifying offenses at the application stage, and all interest holders or key persons as defined in 560-RICR-10-10-1, § 1.2(A)(12) will need to complete the NCIC as a requirement of licensure. 

8. What is evidence of final zoning approval?

A “zoning certificate,” established by R.I. Gen. Laws § 45-24-54, is a standard document in every municipality that is issued by a municipality official.

In circumstances where a cannabis retailer is an allowed use by right in the zone where the property is located, a zoning certificate stating that will suffice as evidence of final zoning approval.

If a conditional or special use permit is required, the zoning certificate will reflect that such a permit is necessary, and the permit itself must be granted and submitted as evidence at the time of the license application. In these cases, the zoning certificate precedes the conditional or special use permit.

Applicants should consult legal advisors and/or the city or town zoning official to confirm local zoning laws, requirements, processes, and timelines.

9. What must be provided to prove residency in Rhode Island?

Applicants need to provide addresses for all interest holders on Form 2 which will be verified during review of applications. There is no need to provide extra documentation.

10. Do the Rhode Island residents comprising the majority ownership have to have been residents of Rhode Island for a certain amount of time before applying?

Majority owners are required to be Rhode Island residents at the time the application is submitted.

11. Could one person be an interest holder in multiple licenses?

Yes, one person may invest in multiple licensed cannabis establishments provided that such investments are in accordance with R.I. Gen. Laws § 21-28.11-19 and § 1.3.2(A)(2)(a) of 560-RICR-10-10-1. An individual may not be an interest holder in more than one application per Zone, pursuant to § 1.3.4(E)(2) of 560-RICR-10-10-1. Individuals may only have an interest of more than 10% in one license.

12. Can the same property be used to apply with multiple groups of worker owners?

See Questions 3 and 4.

13. Can a loan agreement contain restrictive covenants?

It is the responsibility of applicants to make sure that all business agreements comply with requirements set out in the Application, R.I. Gen. Laws Chapter 21-28.11 and the Regulations.

14. What is the deadline to apply for SEASC? What is the deadline to apply for an adult use cannabis retail license?

The deadline to fill out an interest form to applying for SEASC is Wednesday, September 24, 2025, at 11:59 p.m. EST.

The deadline to submit an application in the SEASC portal is Monday, September 29, 2025, at 5:00 p.m. EST.

The deadline to submit an application for Adult Use Cannabis Retail license is Monday, December 29, 2025, at 4:00 p.m. EST.

15. Can an employee of a compassion center participate as an owner in a Workers’ Cooperative that will be applying for a Workers’ Cooperative Retail License?

Yes, provided that individuals may not be interest holders in more than one application per Zone, pursuant to § 1.3.4(E)(2) of 560-RICR-10-10-1.

16. As a newly formed RI Workers’ Cooperative entity, is there any particular way to demonstrate the residency requirements to be Rhode Island resident owned? Should we include the residency information for the initial team member(s) who would be operating the Workers’ Cooperative? 

See Questions 9 and 10.

17. If a company owns 10% of a cannabis establishment, can the same company also have a revenue agreement from that business, such as a branding deal?

Yes, however, applicants are encouraged to consult with an attorney to confirm that all agreements are in accordance with § 1.3.2 of 560-RICR-10-10-1.

18. How is a majority interest defined? Is it 51% ownership of a license, or whoever owns the most interest in the license?

The definition of majority interest is determined based on the statutory definition of ownership and control. Pursuant to R.I. Gen. Laws § 21-28.11-3(35), “ownership and control” is defined as ownership of at least fifty-one percent (51%) of the cannabis establishment, and control over the management and day-to-day operations of the cannabis establishment, and an interest in the capital, assets, and profits and losses of the cannabis establishment proportionate to percentage of ownership. Multiple individuals’ ownership interests can combine for the purposes of determining majority ownership.

For example, for a license with three interest holders holding 36%, 34%, and 30% ownership respectively, no single individual holds a majority interest; however, any two of the interest holders together would constitute a majority interest.

19. Is it necessary that all appeal periods on the approval of a conditional or special use permit have run out prior to application submission?

Applicants may submit a conditional or special use permit that is in an appeal period, provided that if any appeals are lodged, then the application may be considered incomplete.

20. What forms of documentation are considered acceptable to demonstrate the source of funds (e.g., bank statements, tax returns, affidavits, etc.)?

There is not a specific list, however it is incumbent upon the applicant to ensure documentation submitted clearly demonstrates the ability to execute proposed business plans. 

21. While there is no stated minimum capital requirement, is there a recommended minimum amount of capital that would avoid raising concerns during the application review process?

The amount of capital must be feasible for the applicant to complete the pre-requisites for issuance of an Adult Use Retail license within the allotted time–nine (9) months for provisionally approved Adult Use Retail and Workers’ Cooperative applicants and twelve (12) months for provisionally approved Social Equity applicants–from the date of application approval, consistent with § 1.4(I) and § 1.5(I) of 560-RICR-10-10-1.

22. Are there any restrictions on how applicants can structure their capital, such as relying primarily on debt versus equity, or using certain types of investors or financing sources?

There are not specific structuring requirements for how applicants structure their capital, provided that all interest holder requirements and prohibitions are met pursuant to § 1.3.2 of 560-RICR-10-10-1 and Part 4, AUR Exhibit C of the application. Applicants are encouraged to consult with an attorney to ensure compliance.

23. Can multiple applicants share a single bank account, or does each applicant need to maintain a separate account to document their individual financial contributions?

Applicants are required to identify all individuals with financial interest or who have lent money to the applicant. Individuals may only be associated with one applicant per zone but are not prohibited from having an interest in applicants across multiple zones.

24. For municipalities that allow retail cannabis establishments by right, would the Site Plan Review approval be considered “final zoning approval” that an applicant must obtain and submit as part of a complete license application, even though no special use permit is required?

A Site Plan Review approval is not necessary in instances where the applicant can demonstrate the use is allowed by right. Applicants are encouraged to consult legal advisors and/or the city or town zoning official to confirm local zoning laws, requirements, processes, and timelines.

25. Are digital or electronic signatures (such as through DocuSign or Adobe Sign) acceptable for the Forms and any other documents requiring signatures that are submitted with the Adult Use Retail License application?

Yes.

26. Can approved applicants submit a change of location request?

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, in accordance with § 1.3.3 of 560-RICR-10-10-1.

27. At what stage in the licensing or pre-operational process can a change of location request be submitted?

Pursuant to § 1.3.3(A)(4) of 560-RICR-10-10-1, an applicant, provisional licensee or licensee shall submit to the Commission a request for a variance at least sixty (60) calendar days prior to the proposed effective date of the change.

28. Are there specific regulations limiting change of location requests?

Requirements and limitations for a variance request for changes in approved applications, licensed premises, activities, and ownership and control are set forth in § 1.3.3 of 560-RICR-10-10-1 and R.I. Gen. Laws § 21-28.11-10.2, provided that changes to approved premises remain within the same zone.

29. Will you be “qualifying” the Adult Use Retail License applications on a rolling basis, or will they all be evaluated at the close of the application period?

The Commission’s timetable for review and evaluation of the applications will be dependent upon the number of applications and timeframe in which they are received.

30. In reference to the drafting of an Operating Agreement, can the agreement require a supermajority for certain decision, so long as the qualifying owner(s) have 51% of the vote?

Under R.I. Gen. Laws § 21-28.11-3(35), “ownership and control” is defined as ownership of at least fifty-one percent (51%) of the cannabis establishment, and control over the management and day-to-day operations of the cannabis establishment, and an interest in the capital, assets, and profits and losses of the cannabis establishment proportionate to percentage of ownership. Applicants are encouraged to consult an attorney to ensure all agreements are in accordance with § 1.3.2 of 560-RICR-10-10-1 and R.I. Gen Laws Chapter 21.28-11.

31. On Form 2 of the Adult Use Retail License application, there isn’t a space to list a phone number after the first individual or entity in each section. Should the phone number be entered on the second address line instead?

The Form 2 on the website was updated on 10/10/2025 to include a line for phone numbers in all sections. Please use the most current version of the Form 2 for your submission.

32. Does the Certificate of Good Standing from the Rhode Island Secretary of State need to be dated within a specific timeframe the application is submitted?

No.

33. Can an entity applying for an Adult Use Retail License use the Social Equity Certification Number of an individual owner, even if that individual owns 51% or more of the entity?

No. An entity applying for an Adult Use Retail License cannot use the Social Equity Certification Number of an individual owner, even if that individual owns 51% or more of the entity. Approved Social Equity Applicants that wish to apply with a different ownership structure than the one approved for Social Equity Applicant Status must first complete the Social Equity Applicant Interest Holder Change Request Form before submitting an Adult Use Retail License application.

34. Who are the "third-party vendors" referred to in the prompt for Exhibit D of the Security and Safety Plan for the Adult Use Retail License application?

Third-party vendors may include but is not limited to, licensed cultivators delivering cannabis products and vendors providing on-site services related to the operation of a licensed cannabis establishment.

35. How is the 10% voting right limit defined? If someone has less than 10% voting rights overall but holds veto power over one type of decision, does that violate the regulations?

Individuals who hold veto power over a cannabis establishment, even if only a single type of decision, are considered a controlling person of that cannabis establishment.

Pursuant to § 1.3.2 of 560-RICR-10-10-1, individuals are prohibited from being a controlling person in more than one applicant or licensee.