ARTICLE
18 September 2025

Rhode Island Launches Application Round For Up To 24 New Adult-Use Dispensaries

FH
Foley Hoag LLP

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Foley Hoag provides innovative, strategic legal services to public, private and government clients. We have premier capabilities in the life sciences, healthcare, technology, energy, professional services and private funds fields, and in cross-border disputes. The diverse experiences of our lawyers contribute to the exceptional senior-level service we deliver to clients.
After months of anticipation, on September 12, 2025, the Rhode Island Cannabis Control Commission ("Commission") opened the application window for up to 24 new adult-use cannabis retail licenses statewide...
United States Rhode Island Cannabis & Hemp

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After months of anticipation, on September 12, 2025, the Rhode Island Cannabis Control Commission ("Commission") opened the application window for up to 24 new adult-use cannabis retail licenses statewide, which will be divided equally across six geographic zones. As noted in the press release accompanying the application launch, the current application round reflects the single largest expansion of the state's cannabis industry. Indeed, Rhode Island Governor Daniel McKee touted the announcement saying "Rhode Island's cannabis market is poised for growth, and this application is helping us do exactly that." Given the limited number of licenses available and Rhode Island's central location in New England proximate to major population centers and popular vacation destinations, we expect there to be significant interest in this application round. The application window closes at 4:00PM EST on December 29, 2025.

Our previous blog post on the looming expansion of the Rhode Island adult-use cannabis market following the finalization of new dispensary regulations in May outlined the key details for these dispensary license applications and the corresponding license award process. In short, licenses will be awarded by "qualified lottery," which will involve merit-based initial screening. All applicants that meet threshold criteria during the initial screening will be entered into a lottery. A random drawing to select the licensees in each zone will be held in a manner that can be observed by the public. Applications deemed unqualified will not be permitted to participate in the lottery and will not be eligible to receive a license. Other important details include:

Open Licenses v. Social Equity and Co-op Licenses
  • Of the 24 recreational dispensary licenses to be issued, six will be reserved for qualified social equity applicants and six will be reserved for worker-owned cooperatives. Twelve licenses will be "open" licenses (i.e., those not reserved for social equity applicants or worker-owned cooperatives). The Commission will issue a total of four dispensary licenses per zone (2 open, 1 social equity, 1 worker-owned cooperative).
Fees
  • For the 12 "open" licenses and the 6 licenses reserved for worker-owned cooperatives, the license application fee will be $7,500 and the annual license fee will be $30,000. For social equity licenses, there will be no application fee for this license round and annual fees will be $0 for the first year increasing ratably to $30,000 in year 5 (and each year thereafter).
Site Control and Zoning Compliance
  • Applicants are required to provide evidence of site control for the proposed location of the dispensary in the form of documents evidencing either ownership of the property or lease agreement with the owner of the property.
  • Applicants must also provide evidence of full compliance of the facility with the local zoning laws in the form of a certificate or letter from an authorized zoning official of the municipality confirming zoning compliance and receipt of all required final zoning approvals and certification by an authorized officer of the applicant as to compliance with any other applicable local ordinances. Proposed locations may not be within 500 feet of an existing public or private school.
  • A draft floor plan of the establishment must also be submitted.
Ownership and Control Disclosures
  • Applicants must provide a disclosure and certification for all owners, key persons/interest holders, which terms are defined in the regulations to include:
    • All persons and entities with ownership interests;
    • All officers, directors, members, managers and agents;
    • All persons or entities with managing or operational control;
    • All investors or other persons or entities with any financial interest; and
    • All creditors that will loan money to, finance and/or hold a security interest in the cannabis establishment and/or other assets to be used in the cannabis establishment operations, if any.
  • Applicants must also provide an organizational chart and "schedule of compensation/remuneration."
  • Minority, non-controlling interests in multiple applications/licenses is allowed.
Required Narratives
  • Applicants must draft and submit several discrete narratives, including:
    • A business plan that demonstrates experience running a business, including the applicant's experience running a cannabis business, and identifies all sources of funding for the proposed business.
    • A security and safety plan including the description of security equipment and standard operating procedures for the cannabis establishment.
    • An operations manual including policies, procedures and documentation of the following:
      • Record keeping and records retention plan;
      • Qualifications for sale, including ID verification procedures;
      • Staffing plan, including education and training of employees and volunteers;
      • Inventory tracking plan;
      • Data security plan;
      • Alcohol and drug free workplace plan;
      • Labeling and packaging plan;
      • Marketing and advertising plan;
      • Product storage plan;
      • Voluntary and mandatory recalls of cannabis and cannabis products plan;
      • Plan to ensure any outdated, damaged, deteriorated, mislabeled, or contaminated cannabis is quarantined from other cannabis and destroyed;
      • Odor control plan;
      • Community safety plan; and
      • Emergency management plan.
Limitations on Number of Applications Per Geographic Zone
  • An applicant who applies for any retail cannabis license may only submit one application per geographic zone. A person or entity cannot be an interest holder with respect to more than one applicant or application per zone irrespective of license type.
  • An applicant may apply for a license in more than one zone provided, however, if the applicant is selected for a license in more than one zone, the applicant must select a single zone in which the applicant will proceed with licensing.
Restrictions on Transfers of Licenses/Changes to Ownership and Location
  • Qualified applications, provisional licenses and licenses may not be assigned, sold or otherwise transferred to other persons or locations without prior approval of the Commission. 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. The types of changes that must be pre-approved include:
    • Proposed change in ownership of the proposed or licensed cannabis establishment, provided however that no variance which affects a majority change in ownership, control, financial interest and/or compensation/remuneration of a cannabis establishment will be approved in the first year of licensed activities, except upon the Commission's determination that public health, safety, welfare or other grounds requires such variance;
    • Proposed change in the membership of a board of directors or board of trustees;
    • Proposed change in 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 (but a selected applicant may not relocate or change the proposed location outside of the zone for which they were selected); and
    • Proposed changes in the interest holder/key person disclosure.
Our nationally renowned cannabis license applications team has been tracking these developments in Rhode Island for nearly a year and is already working with interested applicants. Please reach out to us with any questions.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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