Update! On October 24,2026 MCA submitted Notice of Proposed Action
(NOPA) to COMAR 14.17.01, .02, .05-.12, .14-.16, and .18-.21 to Administrative,
Executive, and Legislative Review (AELR). This submission followed a 15-day informal posting on the MCA’s website. During this time, MCA received feedback from industry stakeholders and incorporated certain
recommendations into its NOPA. MCA anticipates the NOPA will print in the Maryland Register on November 30, 2026 for a 30-day public comment period.
The purposes of the proposed amendments are to:
● Clarify the definitions of “caregiver,” “green waste,” and “social equity
applicant,” to align with current statute and policy;
● Codify that the MCA may not disclose sociological information for
purposes of immigration enforcement unless provided with a valid
warrant, pursuant to Md. Code Ann., Gen. Prov. § 4-320.1;
● Codify the submission, consideration, fee, and disposition of petitions
for declaratory rulings, pursuant to Md. Code Ann., State Gov't §§ 10-301–10-305;
● Establish that MCA may rescind conditional licenses for failure to
respond to MCA communication related to conditional licensure within
30 days and codify the MCA’s responsibility to send a notice of its intent
before rescinding, revoking, or denying a license, conditional license, or
registration;
● Codify that the MCA may review criminal history, financial information,
and other information when a licensee requests to transfer ownership
of a license;
● Establish that dispensaries may display cannabis for visual and olfactory inspection (i.e. sniff jars), provided certain security requirements are met (licensees may not implement prior to regulation effective date in early 2027);
● Increase the number of employees a micro dispensary licensee may
employ from 10 to 20, pursuant to Chapter 375 of 2026;
● Establish a process for licensees to submit documentation supporting
advertising audience composition claims, pursuant to Chapter 375 of
2026;
● Replace the Responsible Vendor Training program with the Cannabis
Agent Training program and establish minimum program
requirements, pursuant to Chapter 375 of 2026; and
● Require allergens to be listed on the outer marketing layer of a
cannabis product package.
The NOPA includes other minor, technical clarifications to correct typos or align with current policy. These changes do not alter any existing processes and are not anticipated to have any operational impact on stakeholders at this time.
Stakeholders will have 30 days to provide formal public comment once a
proposed action prints in the Maryland Register.
