How to prepare for license renewal, or transition to an annual license

It’s been almost a year since the first provisional licenses were issued, and those licenses are beginning to expire. That means it’s time to get ready for license renewals. We’ve put together information to help you get ready, starting with a quick refresher on AB 97, followed by a to-do list.

Temporary, Provisional, and Annual Licensing

Assembly Bill 97, signed into law on July 1, 2019, contained changes related to temporary and provisional licensing:

  1. It removed the requirement to have held a temporary state license to receive a provisional license.
  2. It extended issuance of provisional licenses until January 1, 2022.
  3. It authorized renewal of provisional licenses, provided the licensee is actively and diligently pursuing annual license requirements, mainly CEQA compliance.

The industry is currently awaiting guidance about the transition process. State agencies have not yet disclosed the exact procedure to transition a provisional license to an annual license or renew a provisional license. We expect this to be forthcoming in the coming months.

We do know that the procedure to transition to an annual license or to renew a provisional license will not be the same as renewing an annual license.

When does your provisional license expire?

  • Look up the expiration date.
  • Mark your calendars to submit a renewal sufficiently in advance to receive your renewal or annual license in time. Avoid any gaps in licensure that would require you to stop operating.


Your surety bond expires each year and must be renewed.

  • Renew your surety bond a few weeks before you apply.
  • Provide the state with an updated copy.


Has your business, ownership, and/or financial interest holder information changed since you submitted your annual application?

  • Notify your licensing authority of any changes to the business or owner(s).
  • Provide an up-to-date list of financial interest holders.


Have you looked at your premises or property diagram lately? Is it an accurate reflection of your current layout and operations?

  • If not, prepare a new diagram for submission. Clark Neubert attorneys can review your diagrams to make sure they comply with state regulations. You cannot modify your premises diagram substantially without first obtaining approval from CDFA.


Where are you with CEQA compliance?

  • Stay in contact with your local jurisdiction (city or county) regarding CEQA compliance.
    If CEQA compliance is complete, obtain the documents to submit to the state agencies so you can transition to an annual license.


(Cultivators only) Do you intend to change your Waste Management Plan?

  • If you plan to change your Waste Management Plan, (for example you listed hauling off-site but now you plan to compost on-site), prepare an updated Waste Management Plan to submit.

(Cultivators only) Do you intend to change your Pest Management Plan?

  • Prepare a new Pest Management Plan to submit.

(Cultivators only) Will you be using a different water source?

  • If you will be using a different water source (new water service, different well, new water storage, etc.) you will need to update your water source documentation and the waste management plan.


(Cultivators only) Are you enrolled in the North Coast or Central Valley Regional Orders?

  • Enroll in the State Water Resources Control Board’s Cannabis Cultivation General Order. Licensees enrolled in the North Coast or Central Valley Regional Orders must transition to coverage under the General Order.
  • If you are already enrolled, make sure to submit your annual reports and remain in compliance with the State Water Resources Control Board’s requirements. They have annual reporting deadlines.


(Cultivators only) Have you obtained a final Lake and Streambed Alteration Agreement or written verification that you don’t need one?

  • If not, stay in contact with the California Department of Fish and Wildlife.
  • If you have an agreement, comply with the terms of your Lake and Streambed Alteration Agreement.
  • If you have a waiver, continue to comply with the conditions of the waiver.


Do you know your renewal fee amount?

  • Set aside funds for the license renewal fee.


More information will be forthcoming in the coming months. Consider this a great opportunity to get your compliance ducks in a row and start off the new year with a solid pathway to license renewal.

Good to Know

California law says that cannabis and cannabis products must be sold in child-resistant packaging (CRP). The January 2019 final regulations included an option – available until the end of 2019 – to fulfill the CRP requirement with exit packaging. Starting on January 1, 2020, the CRP requirement cannot be satisfied at retail with exit packaging. Cannabis and cannabis goods (except plants and seeds) in finished form must be placed in child-resistant packaging at the cultivation or manufacturing premises before a licensed distributor picks them up.

This email is provided as informational only and does not constitute legal advice.

If you have any questions about compassionate use donations, please contact your attorney directly or call our main line at 877-257-2442.

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