In approximately three weeks’ time, the Rhode Island Cannabis Control Commission’s adult-use retail license application window will close at 4:00 p.m. EST on December 29^th, 2025. Interested parties that have not already filed applications should be working earnestly to finalize all required forms, narratives, and supporting documentation as the Commission has been clear that only complete applications will be deemed “qualified” and eligible for the license lottery. Incomplete submissions will be rejected and will not be eligible for selection. 

Background on License Application Requirements

In our September blog post, we outlined the two-step selection process for license awards: an initial merit-based screening to determine which applications meet threshold compliance, followed by a public lottery among qualified applicants in each of the six designated geographic zones of the state. Licenses are allocated by zone and by category—general, social equity, and workers’ cooperative. Each applicant may submit only one application per zone and must disclose all interest holders to ensure compliance with the regulatory restrictions on ownership and control of multiple licenses.

Before the fast-approaching December 29th deadline, applicants must submit the substantive materials specified in the Commission’s regulations and application checklist. These materials include a comprehensive business plan that identifies sources of equity and debt and demonstrates financial feasibility; a detailed security and safety plan covering equipment; and an operations manual addressing such topics as inventory tracking, data security, staffing and training, ID verification, labeling/packaging, marketing, storage, recall procedures, destruction of nonconforming product, odor control, community safety, and emergency management. Applicants must also provide an organizational chart and a disclosure of all interest holders, including owners, key persons, persons with operational control, investors, and creditors.

Site Control: Exclusive Rights Are Required

As a reminder, evidence of zoning compliance and site control are critical for this application round. More specifically, applications must identify the proposed premises, confirm the premises is not within 500 feet of a K–12 school, and include a draft floor plan and a certificate or letter demonstrating municipal zoning compliance. Note that the Commission has extended the deadline to provide evidence of final zoning approval to March 1^st, 2026, but all other application elements must be complete and submitted by December 29^th to be considered. Also note that the Commission has recently clarified its view on tethering multiple applications to a single property. The Commission’s FAQ 4 (updated November 4^th, 2025) underscores that only one applicant may claim a single property:

“Since an applicant must have exclusive rights to a proposed cannabis establishment property, no more than one applicant can hold a lease for the same physical location, whether it is a contingent lease or a regular lease. If multiple applicants provide leases for the same physical property, these applications may be disqualified for not being able to demonstrate the site control requirement, as multiple applicants cannot all be selected for licensure using a single property. It is the responsibility of each applicant to ensure that no other lease(s) exist for the same proposed physical property.” 

Given this interpretation, applicants should immediately confirm that their site is not subject to competing contingent leases.

Final Considerations

Application fees are due at submission for general and workers’ cooperative applicants, while application fees are waived for social equity applicants for this application round. With less than a month to go before the submission deadline, interested applicants should finalize their narrative plans, complete ownership and financing disclosures, secure executed site control documents, confirm zoning compliance pathways, and align their submissions to the Commission’s application checklist and regulatory requirements. Foley Hoag’s nationally renowned license application team is advising clients on this application round and is prepared to assist interested parties in drafting applications or answering discrete questions about the application requirements or the relevant regulations.