Bulletin | Cannabis Social Equity Trust Fund Requirements in COO/COL Applications | May 6, 2026

This bulletin applies to Marijuana Establishments and Medical Marijuana Establishments (Medical Marijuana Treatment Centers) (collectively referred to as “licensees”).

The Commission is issuing this communication to notify licensees of required updates to the Change of Ownership (COO) and Change of Location (COL) processes for applicants who have received funds from the Cannabis Social Equity Trust Fund (CSETF), administered by the Executive Office of Economic Development (EOED). These updates ensure that licensees meet all applicable contractual and regulatory obligations associated with CSETF funding while preserving the appropriate separation of agency roles.

Cannabis Social Equity Trust Fund Requirements
EOED imposes two relevant restrictions on CSETF awardees:

1. License Transfer Restriction
   CSETF awardees may not sell, transfer, or relocate a cannabis license during the contract term without prior written EOED approval. See 400 CMR 8.00 and the applicable CSETF awardee contract with EOED.
2. Restricted Asset Restriction (400 CMR 8.02, 8.07)
   Assets valued over $5,000 and purchased with CSETF funds may not be transferred or encumbered without EOED approval for a period of three to five years. While a license is not a “Restricted Asset,” a transfer may involve assets purchased with CSETF funds.

Updated Requirements in COO and COL Applications
Effective June 1, 2026, the Commission will update its COO and COL application requirements consistent with 935 CMR 500.102(1)(a)1 and 501.102(1)(a)1. Applicants must:

1. Disclose CSETF Funding Status
   Applicants must indicate whether they are a current CSETF awardee or have received CSETF funding within the past three years.
2. Submit EOED Determination
   If a licensee is a current awardee or received CSETF funds within the past three years, they must include EOED’s determination on whether the proposed ownership or location change requires EOED written approval and, if so, provide that approval.

Commission staff will confirm whether EOED documentation has been submitted during completeness review. The Commission will not interpret or evaluate EOED’s determinations and EOED maintains sole authority to determine compliance with CSETF restrictions.

Ongoing Review and Compliance
If EOED later identifies a violation of CSETF requirements, it may notify the Commission. In such instances, the Commission may take enforcement action authorized under its regulations. EOED has also implemented internal review procedures for awardee requests involving ownership changes, location changes, or the movement of assets purchased with CSETF funds. Licensees are encouraged to contact EOED early in the process to ensure timely review and minimize delays.

Questions?
For questions regarding the Commission’s COO/COL process, please contact the Commission at Licensing@CCCMass.com.

For questions about CSETF-related conditions or EOED approval requirements, licensees should contact the Executive Office of Economic Development at CannabisEquityFund@mass.gov.