Top 10 Things to Know Before Applying for a Maryland Social Equity Cannabis License
CannManage is here to help you with your quickly approaching Maryland Social Equity application, regardless of your budget. Set up a Vision Intake meeting with our CEO Beth Myers, who has worked in the cannabis industry as a technical writer since 2008, and will offer a quote that fits your needs. Maryland has many of their own resources for you to review, which were prepared by the State with the intention to help you navigate your application. Below, see our top ten key takeaways from our own research in Maryland that will help you prepare for your submission.
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Key Dates for the First Application Round |
(source:Cannabis Reform Act) |
| September 8, 2023 | Social Equity Verification Portal Opens |
| November 7, 2023 | Social Equity Verification Portal Closes |
| November 13, 2023 @ 12am EST | Application submission window opens for 30 days |
| December 12, 2023 @ 5pm EST | LAST DAY TO SUBMIT APPLICATION |
| January 1, 2024 | Lottery (awarding of licenses) begins |
| May 2024 | MCA may not begin awarding second round application licenses prior to this date COMAR 14.17 |
1. You Must Verify Your Social Equity Status by November 7th to Apply
The first application round is for social equity applicants ONLY. If you plan to apply for licensing this round and have not verified social equity status – go and do so immediately. All applicants must verify through the Maryland OneStop portal: https://onestop.md.gov/ . The Maryland Cannabis Administration (MCA) opened the Social Equity Verification Portal on September 8, to allow individuals to confirm their eligibility as a social equity applicant prior to the beginning of the licensing round.
The Social Equity Verification portal will be open for a period of 60-days, closing on November 7, 2023.
To request a link to this portal from the MCA, you must first complete this form: Cannabis Business Licensing Interest Form. More information on the verification process can also be found here : Maryland Social Equity Cannabis Verification A Guide for Applicants. Maryland OneStop does require a potential applicant to register an account before accessing any application. From there, you will upload the necessary attachments and complete the required information. If you have not already, you may register for a OneStop account here: https://onestop.md.gov/ .
2. Utilize All Resources in Preparing Your Application (Including CannManage)
MCA Written Resources
The MCA has provided more guidance and technical assistance for this application than most Social Equity licensing rounds across the United States. Even the State is aware this is a detailed process that requires focus and experience. Apart from the law, COMAR 14.17 and COMAR 10.62, the State has also released the following guidance documents that lend additional information on submission requirements. All of these must be reviewed in detail before applying.
Sept 8, 2023 – MCA Application Announcement
Oct 13, 2023 – Application Guidance
Application Guidance – General Instructions
Oct 13, 2023 – Evaluation
Application Evaluation Worksheet (lists narrative guidelines/instructions)
Oct 13, 2023 – Application FAQ
FAQ (MCA Will Update Regularly)
MCA Technical Assistance Seminars/Virtual Classes
On October 2nd, MCA opened a Virtual Academy for Verified Social Equity Applicants. You should have received a link from the Virtual Academy’s Canvas Platform once verified. If you have not yet received your link, but have already been verified as a Social Equity Applicant contact: [email protected]. Additionally, the Office of Social Equity is conducting live, in-person Technical Assistance seminars throughout the month of October. Information for these events can be found at the Office of Social Equity’s website .
CannManage Application Services and Discord Community
As a technical writing firm, CannManage understands an abundance of data can be overwhelming to someone who is not familiar with this process. We’ve prepared and written applications for 17 US States, and have researched all the details of this application. As a small business itself, CannManage understands first hand that live conferences and events can be difficult and costly (and stressful) to attend, especially while simultaneously forming a company. If you have no budget for help – that’s okay, too. Come join CannManage’s free online Discord community here, where you can communicate with other applicants and CannManage staff throughout this licensing round.
The team will be accessible on Discord at least once per week in voice, text, and video form with regular real-time events through the application deadline (December 12, 2023 at 5p EST) to answer questions and foster continued guidance. Those with limited resources still have the opportunity to gain insight from experts.
We offer everything from full service application processing to low cost micro-consulting. Once the application round is over, stay in the Discord Community to network and convene with other industry professionals, and we’ll help you prepare for post Conditional Licensing written requirements once you’ve secured your win.
3. Shorter Cannabis Application ≠ Easier Cannabis Application
CannManage has over 15 years of experience in writing cannabis applications, business models, community and investor presentations, and due diligence reports. Contact us to help with your cannabis business start up needs, including Maryland application prep. Most people assume (including the regulators) that a shorter application itself equates to it being easier for the applicant. This is not always the truth, and in this case it may be the opposite. Maryland has a robust legislative framework, where their laws are detailed and specific. Their regulatory history involves a conversion from a medical to a dual use market with only previous medical facilities allowed to serve both patients and consumers. Regulations must be researched and digested accordingly before preparing your application.
The State has provided attachment templates to complete and upload to the portal before the application submission deadline. Originally, they stated space limits ranging from 3-11 pages. Attachments A-C, however, offer a very limited amount of space to articulate your operational, business, and diversity plans. This is because the input sections are in boxes that do not allow the applicant to utilize the entire page. Most of the Operational Plan material will not be required until Conditional Licensing is granted. But, the Business and Diversity plans will have content longer than the page limits, with applicants then tasked with carefully choosing the most relevant details and placing them into the template, along with citations from any relevant regulations.
You will need a business plan and financials to secure investors in the future, so writing extensive plans will be useful for more than just the application. Prepare a full business plan, a two year financial projections (specifically: startup costs, revenue and pre-tax profit), and then accompany them with strong yet concise detail oriented, written narratives that match the company’s financials exactly. Maryland will verify your figures match your narratives exactly. Any written explanation that contradicts the State’s Financial Workbook template (attached to the Business Plan) will result in a failing application.
Application Attachments
Operational Plan – 3 Pages
Business Plan – 10 Pages (Plus 1 Worksheet Page)
Diversity Plan – 4 Pages
4. Do it Right the First Time – Unclear Deficiency Round
Some states allow applicants additional chances to correct any errors in their submission that would disqualify them. Per Page 9 of MCA’s General Application Instructions, every applicant is mandated to submit a thorough application, inclusive of all attachments and the stipulated application fee, by the exact deadline of 5PM Eastern Standard Time on December 12th. According to COMAR 14.17.05.03E, the Administration reserves the right to deny or disqualify any application that’s incomplete, contains any form of misleading information, doesn’t fulfill the lottery’s minimum qualifications, or misses the deadline.
The FAQ MCA released October 2023 says applicants will be notified and will then have 10 days to ‘request a record review’, as established in COMAR 14.17.05.07A. This implies they are giving an opportunity for the applicant to notice any discrepancies or errors on MCA’s part. It does not say that you’ll have a chance to correct any discrepancies or errors on your part.
The Administration further clarifies in their general instructions that:
The MCA will notify applicants of whether their application met the minimum requirements for licensing. An applicant whose application does not meet the minimum requirements will be notified prior to the lottery, and will have ten days to request a records review as established in COMAR 14.17.05.07A. A records review shall consist of an opportunity for the applicant to examine the applicant’s records received by the Administration and verify the basis on which the application was deemed ineligible for the lottery. No applicant may gain access to records submitted by any other applicant through the records review process.
5. Know the Regulations or Fail Your Application
This application round is a lottery…but you have to pass all the application criteria to make it into the lottery. It’s essential to read through all the regulations and application guidance documents produced by MCA. Having access to a cannabis attorney or cannabis technical writer to answer your questions and assist throughout this process is incredibly beneficial. The State has expressly communicated to applicants on page four of their Evaluation Worksheet document that:
Any aspect or part of the submitted information or materials that indicate the applicant will violate any provision of Alcoholic Beverages and Cannabis Article, Title 36, Annotated Code of Maryland, COMAR 14.17, or COMAR 10.62, will result in a “fail” for the application. All relevant statutes and laws should be carefully read and considered prior to the development of an application.
For example, if within your adult use Dispensary application, you detail your plan for “deli style” dispensing (ie: chopsticks used to pick from a jar of flower), that would directly contradict the MCA dispensary guidance, which states that: “Sales similar to a deli counter (as described in COMAR 10.62.30.09) are not allowed.” COMAR 10.62 was written for the medical industry, and COMAR 14.17 (and all recently released application guidance from MCA) has been written to regulate the adult use market.
When in doubt about the law, contact MCA first. If they are unable to help you, then ask an attorney. For questions related to nuances of the written/preparatory aspect of the application that MCA is unable to answer, contact CannManage.
If you don’t have the resources for assistance, refer to the most recent regulation or application guidance document released directly by the State on subjects related to the license type you are applying for.
6. Understand the Difference Between Demonstration v. Confirmation
At various points in the application, applicants are asked to either demonstrate or confirm components of their prospective business.
When asked to demonstrate, the applicant should describe their experience, understanding, or expertise in the criteria listed.
When asked to confirm, the applicant must “simply” state that they understand and will implement or abide by the criteria referenced.
However, if you look at the narrative Attachment templates MCA has provided, some sections that use the term “confirm” are also asking you to cite specific regulations. The sections you will need to expand upon from this application after Conditional Licensing has been granted are also direct references to regulations. Make sure you don’t only state you “confirm” you’ll abide. Also, do your research and mention what specific regulation you are confirming you understand. This will show regulators that you’ve done your homework.
7. No Need to Secure Property Yet, But Understand Local and State Zoning Requirements
Per MCA’s website, applicants are not required to possess or own property or a facility as part of the application, and the MCA strongly discourages any applicant from securing property or a facility prior to obtaining a conditional award. Micro and standard growers, micro and standard processors, and micro dispensaries must identify on their application the region in which they intend to apply and operate. Similarly, standard dispensaries will select the county in which they intend to apply and operate. If selected, applicants may only operate in those areas.
Table 1: Distribution of Available Standard Dispensary Licenses
| Jurisdiction | Avail Dispensary Licenses |
| Maryland | 75 |
| Allegany | 1 |
| Anne Arundel | 5 |
| Baltimore | 6 |
| Baltimore City | 11 |
| Calvert | 3 |
| Caroline | 1 |
| Carroll | 2 |
| Cecil | 2 |
| Charles | 2 |
| Dorchester | 1 |
| Harford | 3 |
| Howard | 3 |
| Frederick | 3 |
| Garrett | 1 |
| Kent | 1 |
| Montgomery | 9 |
| Prince George’s | 9 |
| Queen Anne’s | 1 |
| St. Mary’s | 2 |
| Somerset | 1 |
| Talbot | 2 |
| Washington | 3 |
| Wicomico | 2 |
| Worcester | 1 |
Distribution by Region: Growers, Processors, and Micro Licenses
| Region | Counties |
| Western Region | Allegany, Carroll, Frederick, Garrett, Montgomery, Washington |
| Southern Region | Anne Arundel, Calvert, Charles, Prince George’s, St. Mary’s |
| Central Region | Baltimore, Baltimore City, Cecil, Harford, Howard |
| Eastern Region | Caroline, Dorchester, Kent, Queen Anne’s, Somerset, Talbot, Wicomico, Worcester |
Table 2. Distribution of Growers, Processors, and Micro Licenses
| License Type | Available per Region | Total in Round 1 |
| Standard Growers | 4 | 16 |
| Standard Processors | 8 | 32 |
| Micro Growers | 6 | 24 |
| Micro Processors | 6 | 24 |
| Micro Dispensaries | 2 | 8 |
Tables Source: MCA Application Announcement
Due diligence must be performed before strategizing on a desired location. This may include hiring real estate and legal assistance. Once you decide on a county, create a solid plan on how you will work with the local government and your attorney to secure property that follows both state and jurisdictional zoning requirements for your application. Political subdivisions, such as cities and counties, in Maryland are authorized to establish their own reasonable zoning requirements for cannabis businesses, so long as they do not establish requirements for cannabis licensees that:
- Unduly burden them;
- Impose fees or requirements that are disproportionately more burdensome than those required for other businesses with a similar community impact;
- Prohibit transportation through or deliveries within the political subdivision by cannabis businesses located in other political subdivisions;
- Prevent a compliant, eligible entity from being granted a conversion license; or,
- Require them to negotiate or enter into an agreement that requires a cannabis licensee or applicant to provide money, donations, in-kind contributions, services, or anything of value to the political subdivision.
For additional details, see Md. Code, Alco. Bev. §36–405. All cannabis licensees, including Conditional License holders, are required to conform to and gain approval for all zoning and planning requirements from their respective political subdivision, if applicable (COMAR 14.17.05.05 and 14.17.10).
8. Even if You Win – There’s Still a Lot of Work to Do…
If you pass the application process, gain access to the lottery, and secure Conditional Licensing: You’ve completed only the first major step of this grueling entrepreneurial endeavor. Maryland requires extensive safety, security, and operational plans to be written before gaining licensure, as well as extending employees a 3rd party approved Responsible Vendor Training (RVT) program. CannManage is here to help you fulfill all your written post application licensing requirements, and is waiting on approval from MCA to be licensed RVT providers in the State of Maryland.
9. MCA Will Not Offer Further Guidance on Application Narratives
Consult with a cannabis application technical writer to assist with your application, especially if you are unable to retrieve an answer from MCA regarding the written portions. It was noted in general guidance documents that no further assistance will be provided by the Administration when it comes to the written attached plans.
10. Manage Your Stress Levels, and Hire Experts
Create a balance of self discipline and self care. Find ways to manage stress. Self actualization and accountability is key during this process. Make yourself accessible to only the right people, and stay accurate in your research. Delegate tasks that you do not have time for, or are not an expert in. Take care of your body, and your mind. Exercise, meditation, spending time with family and friends, and networking with other professionals in the CannManage Discord Community who are going through the same process will offer a foundation to recenter your priorities. Due diligence offers the innumerable advantage of foresight, and it is absolutely essential not only while securing conditional licensing, but for the 18 month road ahead, if you take all the right steps to get there in the first place.
Disclaimer: CannManage LLC is operated by writers with a passion for cannabis culture, policy, and technical knowledge. We are a small, majority female owned company that supplies research to ensure your hands are free to strategize with your accountant, legal counsel, real estate and security team during the application process. We are not here to give legal, financial or medical advice. We are not lawyers. The factual information from the above blog was taken directly from the Maryland Cannabis Administration’s website and Maryland’s regulatory framework, and is fully cited. All requests for corrections should be addressed to [email protected].
