Introduction to Missouri’s Cannabis Microbusiness Licenses

Hello, and welcome to the Missouri cannabis market post-passage of Amendment 3, where adult-use sales, and consumption of cannabis in Missouri was legalized for any adult aged 21 and older. This blog series is designed to help you better understand the rules and limitations around Missouri’s microbusiness cannabis licenses.

First, let’s start with a quick summary on the current status of the law:

  • Missouri is considered a “limited license state,” which means that Missouri has limited the number of active licenses allowed within the state for the following commercial license types: cultivation, processing/manufacturing, dispensing, and testing.
  • Currently, there are sixty-nine (69) cultivation licenses that have been awarded in Missouri; there are two hundred and nineteen (219) licensed dispensaries throughout the state; eighty-nine (89) processing/manufacturing licenses have been awarded; and there have been twelve (12) testing lab licenses that have been awarded. The regulatory body in Missouri for the cannabis industry is called the Division of Cannabis Regulation (DCR), but technically it is still under the Missouri Department of Health and Senior Services (DHSS).
    • The DCR has no intentions of adding any more commercial licenses for any license type going forward.
    • While you may have missed the boat on acquiring one of these licenses in Missouri, fear not, as there are non-commercial licenses, called microbusiness licenses, that will soon become available for application submission beginning in July, 2023.

Next, let’s try to better understand the microbusiness license. A microbusiness license refers to either a microbusiness dispensary or a microbusiness wholesale license, both of which are entitled to conduct operations related to the adult-use and medical cannabis industries here in Missouri. A microbusiness is different from a medical or comprehensive (medical and adult-use) license, and it was designed to provide an opportunity for individuals who might not otherwise be able to own a facility in the Missouri cannabis industry. We will get into the specifics of the requirements you must meet to qualify for a microbusiness license in Missouri, but for now, just remember that the licenses were designed to help those who would otherwise not have the opportunity.

Now, let’s talk about the important dates/deadlines for applications. Microbusiness license applications were originally intended to be submitted for a one-month period beginning in September, 2023, and ending in early October, 2023. However, recently, the DCR announced that it will open the application window for microbusiness licenses on July 27, 2023, and it will remain open until August 10, 2023. While it is great that the DCR chose to move up the application window, unfortunately the DCR also limited the window for submission, from 30 days down to 14.

Over the next three years the DCR will award a total of 144 microbusiness licenses to the winning applicants from applications submitted during the window this year. Each year a total of 48 microbusiness licenses will be given out to winning applicants. In other words, even if you are a winning applicant in August, you may not receive your microbusiness license until 2024 or even 2025. To determine the winning applicants, the DCR will use a “lottery” process, and will call on the Missouri Lottery to help with the process. This lottery selection process is designed to ensure the microbusiness program’s integrity and ensure that everyone who qualifies for a microbusiness license has an equal opportunity of being awarded one.

Finally, how are these awarded microbusiness licenses spread out throughout Missouri? If you weren’t already aware, Missouri is divided into 8 different congressional districts. The DCR will award a total of 6 microbusiness licenses in each of the 8 congressional districts each year, until April 2025. The 6 awarded microbusiness licenses in each congressional district will be broken down into two categories: 2 of the licenses will be for microbusiness dispensaries, and the remaining 4 licenses will be awarded to microbusiness wholesale facilities. If you’ve been following along and doing the math, you know that this means each year 48 new microbusiness licenses will be awarded until April 2025, each time spread out evenly between the congressional districts.

In the next blog post, I will be discussing the differences between the two types of microbusiness licenses up for award: the microbusiness dispensary license and the microbusiness wholesale license. We will also dig into the differences between the previously awarded commercial licenses and these new microbusiness licenses, and what this means for you, the potential owner of a microbusiness license.