MO Marijuana License Refund Applications Due 4/2; Second Round of Applications Opens 4/15

Intern Brendan McGuire contributed to the writing of this advisory.

The Department of Health and Senior Services Division of Cannabis Regulation (DCR) has released an initial report summarizing the data collected from the first round of microbusiness applicants. Additionally, the report shares information regarding refunds for the first round of applicants, and a timeline for the second round of 48 microbusiness licenses that will open in April.

The minimum total of microbusiness licenses made available is 144, including 48 dispensary and 96 wholesale evenly dispersed among Missouri’s eight congressional districts.

Application Fee Refunds

During the first round in 2023, 48 licenses were issued out of 1,625 applications. Pursuant to Article XIV, Section 2.4(12) of the Missouri Constitution, “[a]ny applicant that meets the criteria to apply for a marijuana microbusiness facility license but is not chosen by the lottery system may have their application fee refunded.”

Applicants for Missouri marijuana microbusiness licenses who were not chosen by DCR may be eligible for a refund of their application fee. An applicant may submit a Microbusiness Application Refund Request if the applicant:

1. met the criteria to apply for a microbusiness facility license; and
2. has no pending or future legal actions related to the denial of the application.

Refund applications must be submitted via email to [email protected] by April 2, 2024. Confirmation post-submission will be sent to the Designated Contact for each application, and refunds can take up to 14 processing days, returned to the original method of payment.

Second Round of Microbusiness Applications

• An additional 48 licenses will be awarded in the second of three rounds from DCR.
• The application period for the second round is set to open on their online registry portal on April 15 and run through April-29, 2024.
• Licenses for the second round of applications are expected to be issued in July 2024.
• Per Article XIV, Section 2, the third round of licenses may not be issued prior to March 2025.

Armstrong Teasdale’s Cannabis and Hemp Law team is actively monitoring for developments in this space and has deep experience helping clients navigate complex regulatory issues, including microbusiness license applications. Contact your regular AT lawyer or the author to discuss your unique situation.