If you’re a provisional adult-use retail dispensary licensee (whether CAURD or general adult-use) in New York, you’re sitting on one of the most valuable assets in the country’s third-largest cannabis market. But as every operator knows, a provisional license is not a final license. Until you cross that finish line, you can’t open your doors, stock shelves, or generate revenue.
Good news: The Cannabis Control Board (CCB) just extended all provisional CAURD and adult-use retail licenses through December 31, 2026. This is likely the final extension — use it wisely.
This step-by-step guide is written specifically for New York operators (especially in the five boroughs and downstate) who need to convert their provisional status to a full adult-use retail dispensary license now, before the market saturates further.
1. Understand Your Deadline (It’s Real This Time)
- All provisional licenses expire December 31, 2026 (Resolution 2025-66, approved September 9, 2025).
- If you submit a complete post-selection/secondary application before that date, OCM will continue processing even past 2026.
- Miss it? Your provisional license lapses. No appeals, no mercy.
Pro Tip: Start your secondary application today. The review queue is massive, and OCM is still catching up from 2023–2024 litigation delays.
2. Secure a Viable Location — The #1 Roadblock for 90% of Provisionals
The single biggest reason provisionals fail to convert? Location violations.
Use the Right Tools (2025 Edition)
- LOCAL Map (Legal Online Cannabis Activities Locator) – Launched 2025, this is now the only official tool for proximity checks.
- Replaces the old Proximity Protected Locations Map.
- Generates automated proximity reports.
- Shows pending and active licenses in real time.
- Distance rules (still in effect):
- 500 feet from schools/daycares (measured entrance-to-entrance).
- 200 feet from houses of worship.
- Municipal opt-outs still honored (check the map!).
NYC-Specific Gotchas
- Community Board notification: 30–270 days before final submission.
- Certificate of Occupancy must explicitly allow retail (many older leases don’t).
- Colocation with delivery/depot? Possible now, but separate entrances required.
Operator Hack: Run every potential address through LOCAL before signing an LOI. We’ve seen operators lose six-figure deposits on “almost compliant” spaces.
3. Submit Your Secondary/Post-Selection Application via NYBE
- Log into New York Business Express (NYBE) portal.
- Upload:
- Proof of exclusive right to the premises (fully executed lease or deed).
- Municipal notification proof (or Community Board in NYC).
- Updated True Party of Interest (TPI) disclosures.
- Capital/financing proof (bank statements, investor commitments).
- Final site plans/floor plans.
- Security plan (cameras, vaults, access control).
- Any outstanding deficiencies from your original provisional award.
2025 Change: OCM no longer accepts emailed location packages. Everything must go through NYBE or it’s rejected.
4. Pass Pre-Operational Inspection
Once OCM deems your location “viable”:
- Schedule site inspection (they’re backlogged — book early).
- Expect scrutiny on:
- POS & Metrc/BioTrack integration.
- Vault/safe requirements.
- Video surveillance (180-day retention, specific camera angles).
- Odor control (especially in multi-tenant buildings).
Real Talk from the Field: In 2025, OCM has been failing ~30% of first inspections on surveillance alone. Hire a compliance consultant who has done 50+ NY inspections — it pays for itself.
5. Pay Final Fees & Get Board Approval
- Final license fees: $7,000–$10,000 (varies by municipality population).
- Social & Economic Equity (SEE) licensees may have reductions/deferrals.
- Final review goes to the Cannabis Control Board for approval (monthly meetings).
- Once approved → You get your final adult-use retail dispensary license.
You can open the moment you receive it (no more “authorization to operate” delays for most).
Timeline Reality Check (November 2025)
| Milestone | Realistic Timeline (if you start now) |
| Secure compliant location | 2–6 months |
| Submit secondary app | 1–2 months after location |
| OCM location review | 3–8 months |
| Inspection & deficiencies | 2–4 months |
| CCB final approval | 1–3 months |
| Total to Open | 9–18 months |
With the 2026 extension, you have breathing room — but the fastest movers will capture the remaining prime territories and customer base.
Final Words: This Is Your Equity Moment
New York’s adult-use market is finally maturing. Over 700 final retail licenses have been issued statewide, but thousands of provisionals are still racing to convert.
The operators who treat the provisional-to-final transition like a full-time job — with real estate brokers who know cannabis zoning, attorneys who live in the regs, and compliance teams that speak OCM fluently — are the ones opening in 2026 while others expire.
You’ve already won the hardest part: getting the provisional. Now finish the job.
✍️ By Daniel Sabet, Cannabis CFO & Financial Advisor at @GreenGrowthCPAs. Daniel advises cannabis operators nationwide on finance, compliance, and strategy.
GreenGrowth CPAs: 1178 Broadway, 3rd Floor, New York, NY 10001
