While most Kentucky cannabis licensees are still in the process of finding a suitable location and/or building out their facilities, licenses still expire one year from the date they were initially issued. This means that many licensees will file their renewal applications before commencing operations, and must ensure that they have been complying with all applicable requirements in order to avoid potential issues with the Kentucky Office of Medical Cannabis (“OMC”) processing their applications.
Critically, renewal applications must be submitted at least 60 days before expiration. Licensees will submit their applications through the online licensing portal. The primary contact on the license should look out for a reminder e-mail that will come through 90 days prior to the expiration date. This means cultivators and processors should generally receive notices in August, with deadlines in September, whereas dispensaries will receive notices in September and have hard deadlines for their submissions in October.
We recommend starting the renewal application process early. Keep in mind that any pending changes in ownership/control must be approved before a renewal application is submitted, so it is important to plan ahead.
OMC will reject late submissions and indicated they will return renewal fees (which range from $12,000 to $50,000 depending on license type).
Requirements for renewal applications include the following:
- Disclosure of investigations or legal actions during the current or previous licensing period
- Operational updates (e.g. staffing, supply issues, recalls, location changes)
- Compliance history or statement of no violations
- Any additional documentation requested
Through this process, licensees must demonstrate:
- Effective control against diversion of medical cannabis
- Accurate and honest communications with OMC
- Strong compliance history
- Ability to meet all legal and regulatory obligations
- Responsiveness to required surveys that OMC sent to licensees and timely reporting
If you have questions or would like assistance preparing a renewal application for your cannabis license please reach out to a member of our team.
