The licensing questions we get most, with direct answers. Missing one? Email us and we’ll add it.
Yes. Under BPC §26055(a), the DCC cannot issue a state license unless you attach evidence of local authorization — either a permit, license, or a signed letter from the city or county confirming the proposed activity is allowed at the proposed premises. Local comes first; state comes second. There is no workaround, and "we're working on it" is not evidence.
In practice, that means your first call is to the local planning department, not the DCC. In ban jurisdictions you cannot operate at all; in permissive cities you'll typically need a Conditional Use Permit or equivalent zoning clearance before the local business license is even on the table. One thing to watch: some cities will issue a "comfort letter" that satisfies BPC §26055(a) while you complete the full local buildout — we use those deliberately to keep the state timeline moving while local work continues.
DCC targets roughly 60 business days of substantive review after a complete submission, but the honest number most applicants experience is 4 to 9 months from filing to issuance once you factor in DOJ background checks, CEQA clearance, and the one or two rounds of deficiency notices that almost always come back. The 60-day clock does not start until the file is deemed complete — incomplete submissions reset it each time they're returned.
The two biggest time-eaters are CEQA (particularly for cultivation and manufacturing) and ownership disclosures on Form 9101 when there's any private equity, trust, or layered entity structure upstream. We sequence the file to submit CEQA and local authorization in parallel with Form 9101 owner packets so nothing blocks the critical path. Note: a single owner whose Live Scan comes back with an unresolved disposition can stall the entire license for 30–45 days — resolve those before submission, not during.
Provisional licenses were an abbreviated review category created under BPC §26050.2 to let operators start the state license process before CEQA was fully cleared at the local level. DCC stopped renewing provisional licenses on January 1, 2025, and all remaining provisional licenses sunset on January 1, 2026 — except for local-equity retailers, who remain eligible for provisional issuance through January 1, 2031 under the equity carve-out. For any non-equity applicant filing today, annual is the only available pathway: full review, full CEQA documentation under CCR §15010 (Notice of Exemption, Mitigated Negative Declaration, or final EIR from the local lead agency), full Owner disclosure under CCR §15003, full Financial Interest Holder disclosure under CCR §15004, and a complete operational packet.
The practical upshot: you cannot rely on the provisional shortcut to get operational early. If you're acquiring a business that holds a provisional, confirm its conversion status before closing; an unconverted provisional that misses its deadline does not fall back to annual, it lapses. One thing to watch: local authorization still runs on its own timeline, and many cities still issue local permits that presume a state provisional exists — you may need to re-educate local staff about the annual-only posture.
Under BPC §26001(al) and CCR §15003, an "Owner" is anyone holding 20% or more aggregate ownership interest in the applicant entity, the CEO, every member of the board of directors, and any individual who participates in the direction, control, or management of the licensed business. Every Owner files a Form 9101 Commercial Cannabis Owner Submittal, completes Live Scan fingerprinting (DOJ + FBI), and discloses the criminal-history narrative, ID number, percentage of ownership, and financial information required under CCR §15002(c).
The trap most operators fall into is thinking "owner" means only the cap table. It does not. A minority equity holder who signs contracts, approves budgets, or directs operations is an Owner for DCC purposes regardless of percentage — control triggers disclosure independent of equity. Trustees and beneficiaries with control rights count. Management companies with operational authority count. Financial Interest Holders below the 20% threshold (passive investors, profit-share landlords, profit-participating lenders, revenue-share consultants) are disclosed under the separate CCR §15004 schedule, but only Owners require Live Scan. One thing to watch: failing to disclose an Owner is one of the fastest ways to trigger an accusation and license revocation under the DCC Disciplinary Guidelines. When in doubt, disclose.
The core packet for most applicants is the license-type application form (Form 5 testing laboratory, Form 6 retailer, Form 7 distributor, Form 8 microbusiness; cultivation and manufacturing apply through CLS and MLS portal-driven workflows), Form 9101 Commercial Cannabis Owner Submittal — one per Owner at the ≥20% CCR §15003 threshold plus officers, directors, and anyone with control — Form 9206 Landowner Approval when the applicant is not the property owner, Form 9205 Labor Peace Agreement notarized statement (required at 10 or more employees per the July 2024 threshold change, lowered from 20), Form 8113 Commercial Cannabis Licensee Bond at the $5,000 minimum per premises payable to the State of California (every license type, not distribution only), and the consolidated Form DCC-LIC-019 SOP packet covering receiving, storage, inventory, security, surveillance, transportation, waste, and recall.
Beyond those, the file includes the CCR §15006 premises diagram, the financial information statement, CEQA evidence under CCR §15010, local authorization evidence under BPC §26055(a), and license-type-specific schedules — sampling SOPs on Forms 21–24 for testing laboratory applicants, manufacturing process narratives under CCR §17200, cultivation plans under the CCR §15300 series, and equity attestations where applicable. Form DCC-LIC-027 is the post-issuance Notifications and Modifications form — premises changes, ownership changes, license-type amendments — not part of the initial packet, and Form DCC-LIC-017 is the Corrective Action Plan filed after a Notice to Comply. We maintain a full mapped checklist of all 28+ DCC forms in the California licensing guide. One thing to watch: DCC rejects incomplete Form 9101 packets silently by deeming the application incomplete — there is no friendly warning, just a returned file.
When DCC issues a deficiency notice, you get 10 business days to respond under CCR Title 4 §15002(d), calculated from the date of service — not the date you opened the envelope. The response has to actually cure the deficiency — not just acknowledge it — which means filing the missing document, correcting the flagged disclosure, or submitting a narrative that explains why DCC's read of the file is wrong. Extensions are discretionary and granted sparingly; you cannot plan around getting one.
The mistake that kills applications is treating the deficiency as a low-priority email. A deficiency notice is a legal deadline. Miss the window and DCC can deem the application abandoned under CCR §15002 and deny it under BPC §26057, forcing a full refile with a new non-refundable fee. Two exceptions worth knowing: (1) if the deficiency is substantively impossible to cure in 10 days (e.g., a CEQA document that takes 30 days to produce), request an extension in writing inside the original window with a dated plan; (2) if DCC's deficiency itself is in error, respond with a written correction on the record — silence is treated as agreement.
Annual license fees are published in CCR §15014 and scale by license type and gross revenue tier. The current range runs from roughly $1,205 for a Specialty Cottage Outdoor cultivator at the lowest tier to over $120,000 for the largest retail and distribution classifications. Application fees are separate, run from $1,000 to $8,000 depending on license type, and are non-refundable on submission.
Plan for the surrounding costs too: the $5,000 minimum surety bond per premises (Form 8113), Live Scan at roughly $50 per Owner, the Cal-OSHA 30-hour course (one supervisor and one employee within 12 months of issuance), CDTFA seller's permit registration, local permit and impact fees that vary widely by jurisdiction, and CEQA documentation costs at the local lead-agency level for annual cultivation and manufacturing applicants. Equity-eligible applicants apply for a DCC fee waiver or deferral via Form 1601 (Form 1602 for additional Owners). Confirm current fees against the DCC fee schedule at the time of filing — the table is updated annually.
License type is determined by the activity, the scale, and the technology in use — not by what's easiest to apply for. Cultivation is sized by canopy in square feet (Specialty Cottage at ≤2,500 sq ft outdoor, Specialty at ≤5,000, Small at 5,001–10,000, Medium at up to 22,000 indoor or one acre outdoor, Large above 22,000) and by lighting (outdoor under Type 1/2/3, indoor under Type 1A/2A/3A, mixed-light under Type 1B/2B/3B). Manufacturing splits Type 6 (non-volatile, including CO₂, ethanol, and mechanical), Type 7 (volatile-solvent, with closed-loop certification and local fire authority sign-off under CCR §17200–17210), Type N (infusion only), Type P (packaging and labeling only), and Type S (shared-use facility for small brands). Retail is Type 10 storefront or Type 9 non-storefront delivery; distribution is Type 11 full or Type 13 transport-only.
Two consolidation paths exist for multi-activity operators. Type 12 microbusiness combines three or more activities under CCR §15500 — cultivation up to 10,000 sq ft canopy, Type 6 manufacturing, distribution, and retail — at a single premises. Type 15 Combined Activities License, effective January 1, 2025 under SB 1064, authorizes two or more commercial cannabis activities at the same premises with no microbusiness scale cap (testing labs are excluded by statute). Picking the wrong classification is a re-application, not an amendment, and a re-application means a new fee, a new portal submission, and a new review cycle. We pressure-test the classification against the build-out plan before any portal work begins.
Under CCR §15011, DCC may inspect the proposed premises before license issuance to verify that the premises diagram, limited-access areas, security infrastructure, cultivation canopy measurements, manufacturing equipment, or distribution and retail workflow match the application. Volatile-solvent manufacturers (Type 7) and large cultivators are routinely inspected; other license types are inspected on a discretionary basis when DCC sees inconsistencies in the file or when local fire or zoning authorities flag conditions. The inspection is the moment the diagram, the SOPs, and the physical premises are compared against each other.
The most-cited finding on first inspection is mismatch between the CCR §15006 premises diagram and the physical site — a wall added during build-out, a camera blind spot in a limited-access area, a storage room not labeled on the diagram. The fix is to stage the premises to match the diagram before the inspector arrives, walk every camera field of view against CCR §15044–15047 (1280×720 minimum at 15 fps, 24/7 recording, 90-day retention), and verify every limited-access area is signed and physically restricted. We accompany clients through pre-licensure inspections and pre-empt the deficiency notice before it gets written.
Issuance is the start of the operational clock, not the end of the work. Within the post-issuance window you must activate the METRC track-and-trace account through the state-administered Franwell portal and tag all on-site inventory, register a CDTFA seller's permit (and excise tax permit for retailers under AB 564's 15% rate effective October 1, 2025 through June 30, 2028), complete the Cal-OSHA 30-hour general industry course for one supervisor and one employee within 12 months, file the local business tax registration, and bind the general liability and product liability insurance the application attested to.
Ongoing obligations attach immediately: 7-year recordkeeping retention under CCR §15037, material-change reporting within 14 calendar days under CCR §15020 (any change in Owners, Financial Interest Holders, officers, directors, business name, premises diagram, or activity scope) filed via Form DCC-LIC-027, METRC reporting cadences under the DCC track-and-trace mandate, and renewal filed inside the 60-day window before expiration with updated gross revenue documentation under CCR §15014. We hand off a complete 60-day post-licensure compliance calendar with named owners and dated milestones, and continue the cadence under our Ongoing Compliance Retainer when the engagement extends.
