Minnesota enters the slog phase of finalizing cannabis licenses

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The license acquisition process in Minnesota has entered a new phase as of June 2025. Uncapped license-type applicants have been informed of their preliminary application acceptance, and the lottery has been held, identifying the winners of the larger license types. The Office of Cannabis Management (OCM) has closed the application window until further notice, which, based on how licensing has gone in other states, could take years. The focus now is on getting the more than 3,500 applicants, of all types, operational.

Meeting OCM’s cannabis licensing requirements

The OCM is not making it easy. Similarly to New Jersey’s licensing requirements, a wide range of documents must be submitted, and a suitable location must be secured, built out, and inspected before the OCM will give its blessing and fully approve and finalize a license.

The document set that must be submitted is called “Final Plans of Record” and includes a detailed facility design diagram (digital set of drawings) that will generally be overseen by an architect but requires input from other contractors such as the security hardware company, a fire suppression expert, engineers, and cultivation/manufacturing consultants. Some applicants might not realize that the OCM’s required design drawings are different from what a local building department would require, but both sets of requirements can be done in one document set as long as the variation is taken into account from the beginning. The local building department, for example, will require MEP (mechanical/electrical/plumbing) drawings, whereas the OCM only requires ventilation/filtration diagrams from engineers.

Other documents required for the Final Plans of Record are:

• Site, Security, and Operations Plans
• Quality Assurance Plans
• Inventory, Storage, and Diversion Prevention Plans
• Accounting and Tax Compliance Plans

Challenges in finding locations and staying compliant

For applicants with multiple “endorsements,” meaning they will perform more than just one licensing function, such as retail and cultivation, or cultivation and manufacturing, or all three, they must submit extra documents for each location and provide additional documentation for each specific license type. With the facility design included, it adds up to months of work. The OCM will let applicants submit plans for one endorsement at a time (because your retail location might be ready before your cultivation facility is), but a facility must be built out and ready to inspect before anyone can submit all of the drawings, plans, and procedures. Essentially, for each license type, everything must be submitted all at once when the applicant is fully ready to operate.

So the search for properly zoned locations is on. Cannabis real estate brokers are at their busiest, and bidding wars are beginning for the best locations. When property owners realize their locations are in “green zones,” they immediately consider asking a higher price to lease or sell, so it pays for cannabis operators to get in early.

Key takeaways for cannabis license applicants

Applicants who won licenses in the lottery or have otherwise been notified of preliminary approval have 18 months to become operational. This is a fairly reasonable limit for retail facilities but could be difficult for cultivation facilities, especially if they are doing ground-up construction. If the OCM follows New Jersey’s lead, extensions will be given under reasonable circumstances, although the best strategy is to just move forward expeditiously at this point and not flirt with missing the deadline.

The low cost of entry ($500) for the most common license type—microbusiness—gave many applicants the false impression that becoming operational could be financially accessible for small business operators, but the production limits for microbusinesses are fairly high (5,000 square feet of indoor canopy, 10,000 lbs of biomass per year for manufacturing), meaning that a full build-out for maximizing microbusiness output could still cost millions of dollars. Even if a microbusiness operator wanted to start small, the design plans and a modest build-out will run into a few hundred thousand dollars in investment, with retail locations being the most affordable endorsement and cultivation being the most expensive.

The OCM has been responsive and helpful to applicants since overcoming some hiccups with its original leadership and difficulties administering last summer’s social equity licensing round. One benefit of their current system is that they allow for corrections in submitted materials, known as a “cure period.” This is what allows consultants like me to guarantee application acceptance—we know we can please the regulatory agencies if we can correct and resubmit deficient materials. We always strive to submit perfect materials because deficiencies usually come along with time setbacks, but every OCM application investigator is different, and sometimes what passes with most investigators won’t pass with an investigator who is either less experienced or more of a stickler. Submitting materials early, in other states, has proven to be beneficial because the application investigators are not yet fully grounded in their methods of judging documents until they’ve seen quite a few submissions.

The bottom line is this: If you have preliminary application approval in Minnesota, you will save the most money by getting your location as soon as possible, and you will have the smoothest licensing process by submitting your Final Plans of Record as soon as possible. However, it’s not worth skimping on work quality for speed, because if the OCM kicks your application back for corrections, it will set your operations date back by 30–90 days. Setbacks are more common than not in all states with new cannabis licensing programs because there are so many components that must come together, and the process is generally new territory for applicants and regulatory agencies alike.

Jennifer Martin is a veteran, award-winning indoor grower, a facility designer and cannabis licensing expert. She operated large-scale clone facilities in California until 2012, when she moved to Hawaii and went into consulting. She has helped cannabis entrepreneurs obtain production and retail licenses in California, New Jersey, Mississippi, New York, Illinois, New York, Delaware, Maryland and Minnesota.