Bulletin No. 3 | An Act Modernizing the Commonwealth’s Cannabis Laws | May 1, 2026

Purpose of Bulletin

This bulletin from the Massachusetts Cannabis Control Commission (Commission) informs licensees and applicants of statutory changes enacted through Chapter 65 of the Acts of 2026 (the Act), which amends the ownership and control thresholds applicable to Marijuana Establishments (MEs) and Medical Marijuana Establishments (MMEs), formerly known as Medical Marijuana Treatment Centers (MTCs), and Indepdent Testing Laboratories (ITLs).

Previous bulletins relative to the implementation of the Act, (formerly referenced as H.5350), are available on the Commission’s “Enforcement Annoucements” webpage:

• Bulletin No. 1:Two-ounce Sales of Marijuana Flower and Equivalency
• Bulletin No. 2: Delivery of Marijuana and Marijuana Products – Municipal Waiver Option

Statutory Change

Section 36 of the Act amends Section 16 of Chapter 94G to increase the equity interest threshold relevant to ownership and control assessments. Under the reforms signed into law on April 19, a person or entity may now hold less than 20 percent equity in a license without being subject to the Commonwealth’s license cap limitations, provided they do not otherwise exercise direct or indirect control over operations as defined in statute and Commission regulations.

Relationship to Existing Regulations

The Commission’s previous 10 percent disclosure and ownership interest thresholds were adopted to reflect the prior standard under the law. With the enactment of the Act, the underlying statutory requirement has changed.

Accordingly, the Commission will apply the new 20 percent threshold when evaluating ownership and control interests for new licenses, renewals, and change of ownership applications.

Interim Application of the Statute

Until the Commission completes formal rulemaking to update its regulations:

• Licensees and applicants should apply the 20 percent financial ownership threshold when preparing, updating, or submitting ownership and control information.
• Once Commissioners have been appointed, the Commission will review ownership and control disclosures consistent with the new statutory requirement.
• All other disclosure obligations in existing regulations remain in effect unless expressly superseded by statute.

Regulatory Updates

Consistent with Section 65 of the Act, the Commission will update its regulations to ensure consistency with the Act within one year of its effective date, or April 19, 2027.

The Act further requires the Commission to open its regulatory process to revise policies and begin accepting applications in accordance with the statutory changes no later than two months following its effective date. The Commission intends to initiate the public rulemaking process as soon as practicable, after the arrival of Commission appointees, which is anticipated no later than May 19, and before June 19.

Next Steps for Licensees and Applicants

• Review ownership structures to ensure disclosures reflect the new 20 percent threshold.
• Apply the statutory threshold for all pending, inprocess, or forthcoming applications.
• Contact the Commission’s Licensing Division with any questions regarding ownership and control reporting requirements.

Questions?

Questions may be directed to Licensing@CCCMass.com.