Per 19 CSR 100-1.070(1)(E) an entity or individual may not be an owner in more than ten percent (10%) of the total number of comprehensive and medical cultivation, dispensary, or infused products manufacturing facility licenses outstanding, rounded down to the nearest whole number.

Who is subject to common relationship analysis?

Entities or individuals with financial and/or voting interest of 10% or greater will be subject to common relationship analysis to confirm compliance. This includes, but is not limited to, parent companies, sub-entities, and individuals. Unlike the review for disqualifying felony offenses, which only looks at the percent of ownership at the individual level, a review for common relationships will look at the percent of ownership of each entity in a licensee’s organizational structure at or above 10%.

Entity License Allowances

License Type Total Number of
Licenses Outstanding
Licenses Allowed Per Entity
or Individual
Comprehensive and Medical
67 6
Comprehensive and Medical
213 21
Comprehensive and Medical
87 8

*The above chart will be updated when the number of licenses for a facility type changes.

Other Common Ownership Considerations

Pursuant to 19 CSR 100-1.070(1)(F), no marijuana testing facility shall be owned by an entity or entities under substantially common control, ownership, or management as a cultivation facility, marijuana infused products manufacturing facility, or dispensary facility. Because of this, the division will collect information from all license types consistent with evaluation for substantial common control, as defined by 19 CSR 100-1.010(85).

Pursuant to 19 CSR 100-1.190(1), a marijuana microbusiness facility may not have an owner who is also an owner of an existing medical, comprehensive, or another microbusiness marijuana facility license.

Please email with questions or for assistance.