Navigating Cannabis Business Opportunities in Washington, D.C. – Your Guide to Licensing in 2025
Washington, D.C., the nation’s capital, is a progressive market for cannabis, with medical cannabis legalized in 2010 and recreational possession and cultivation permitted since 2014 under Initiative 71. The Medical Cannabis Amendment Act of 2022, effective March 2023, overhauled the District’s medical cannabis program, removing license caps, enhancing social equity, and expanding patient access through self-certification. With medical cannabis sales reaching $38 million in 2024 and projections of $173 million by 2025, D.C. is a lucrative market despite the absence of recreational retail. The city’s enforcement against unlicensed “gifting” shops and focus on regulated medical cannabis create a stable environment for licensed operators.
Securing a cannabis business license in Washington, D.C., requires compliance with regulations from the Alcoholic Beverage and Cannabis Administration (ABCA) and local zoning rules. While the most recent application window for retailer and internet retailer licenses closed on August 29, 2024, additional rounds may open in late 2025, particularly for social equity applicants or testing laboratories, which accept applications on an ongoing basis. Key requirements include:
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Eligibility:
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Applicants must be 21 or older.
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No felony convictions for violence, firearms, tax evasion, fraud, or credit card fraud within the past three years.
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Applicants cannot be medical practitioners recommending cannabis or have had patient/caregiver status revoked.
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Social equity applicants, prioritized for 50% of licenses, must meet at least two of:
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Returning citizen (post-incarceration).
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Familial ties to someone arrested, convicted, or incarcerated for cannabis/drug offenses.
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Residency in a disproportionately impacted area (designated by ABCA).
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Registration as a for-profit or nonprofit corporation in D.C. with current tax filings (no debts over $100 to the District).
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Documentation:
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Comprehensive business plan detailing operations, marketing, financial projections, and community impact.
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Security plan with surveillance systems, access controls, and theft prevention protocols.
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Proof of property ownership or lease agreement, compliant with zoning rules.
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Certified Business Enterprise (CBE) registration from the Department of Small and Local Business Development (DSLBD) for priority consideration.
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Operational policies ensuring compliance with ABCA regulations (e.g., METRC inventory tracking).
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Facility Requirements:
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Compliance with zoning rules, prohibiting locations within 300 feet of preschools, K-12 schools, or recreation centers.
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Detailed floor plan showing restricted access areas, ADA compliance, and odor control measures (e.g., carbon filters).
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Certified alarm test by the Office of Unified Communications and ABCA final inspection.
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Local Compliance:
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Obtain zoning approval from the D.C. Office of Zoning.
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Submit applications via ABCA’s Quickbase portal or in-person at 899 North Capitol Street, NE, Suite 4200-A.
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Pass a 45-day public comment period for cultivation and manufacturing licenses.
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Washington, D.C., offers six medical cannabis business licenses, with testing laboratory licenses and retailer endorsements available on an ongoing basis and potential new rounds for other types in late 2025. Available licenses include:
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Retailer License: Permits dispensing medical cannabis and products to registered patients/caregivers at a physical storefront (7:00 a.m.–11:00 p.m.). Includes manufacturing and paraphernalia sales. Endorsements include Delivery, Educational Tasting, Safe Use Treatment Facility (on-site consumption), and Summer Garden.
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Internet Retailer License: Allows online/mobile app sales and delivery of medical cannabis to patients/caregivers without a storefront (9:00 a.m.–9:00 p.m.).
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Cultivation Center License: Permits growing cannabis for sale to licensed retailers, with six tiers based on canopy size (up to 100,000 sq. ft.).
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Manufacturer License: Allows processing, packaging, and labeling cannabis products. Type 1 (manufacturing only) and Type 2 (manufacturing and extraction) available.
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Testing Laboratory License: Permits safety and potency testing of cannabis products, accepted on a rolling basis.
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Courier License: Authorizes third-party delivery of medical cannabis on behalf of retailers/internet retailers.
The Medical Cannabis Amendment Act eliminated caps on most license types, except for limiting licensees to two cultivation licenses and three combined retailer/internet retailer licenses. The ABCA prioritizes social equity applicants for 50% of licenses, with recent windows (e.g., July 1–August 29, 2024) awarding 33 retailer and two internet retailer licenses. While no confirmed application window is set for Q3/Q4 2025, ongoing testing laboratory applications and potential new rounds for retailers or cultivation centers are anticipated, especially as unlicensed operators face enforcement post-March 31, 2025.
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Submission: Apply via ABCA’s Quickbase portal, in-person, or by mail during open periods, with fees ($800–$8,000) based on license type and social equity status.
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Review: ABCA scores applications on criteria like business plan, security, and community impact (150+ points for priority). A 45-day public comment period applies for cultivation/manufacturing.
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Provisional Approval: Conditional licenses (one-year validity) require lease agreements, security plans, and Certificates of Occupancy.
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Final Licensing: Pass ABCA inspections, METRC setup, and alarm tests to operate by deadlines (e.g., March 31, 2025, for prior applicants).
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Permitted Zones:
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Commercial Districts (CM, MU): Retail, internet retail, and manufacturing allowed with zoning approval.
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Industrial Districts (PDR): Preferred for cultivation and manufacturing due to minimal residential impact.
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Retailers must operate in designated commercial zones, with specific hours (7:00 a.m.–11:00 p.m.).
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Restricted Areas:
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Facilities prohibited within 300 feet of preschools, K-12 schools, or recreation centers, measured from property lines.
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No operations in residential zones (R, RF, RA) or on D.C./federal government properties.
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Municipal Approval:
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Submit a Geographic Information System (GIS) map or surveyor’s report verifying distance compliance.
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Obtain a Certificate of Occupancy and DSLBD certification for CBE status.
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Internet retailers must avoid residential zones and school premises for deliveries.
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Visibility and Access:
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Facilities must not be publicly visible or accessible to unauthorized persons, requiring secure, locked areas.
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Application Fees:
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Retailer: $8,000 (standard), $800 (conditional/social equity).
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Internet Retailer: $4,000 (standard), $400 (conditional/social equity).
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Cultivation Center: $8,000 (standard), $800 (conditional/social equity).
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Manufacturer: $4,000 (Type 1), $8,000 (Type 2).
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Testing Laboratory: $4,000.
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Courier: $1,000.
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Annual License Fees:
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Retailer: $16,000.
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Internet Retailer: $8,000.
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Cultivation Center: $8,000.
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Manufacturer: $4,000 (Type 1), $8,000 (Type 2).
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Testing Laboratory: $4,000.
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Courier: $1,000.
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Social equity applicants receive 50% discounts for the first three years.
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Local Fees:
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Zoning approval: $500–$2,000.
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Building permits/inspections: $1,000–$5,000, based on facility modifications.
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Taxes:
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6% sales tax on medical cannabis purchases, with no additional excise tax.
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Other Costs:
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Capital investment: $500,000–$2 million for retail/cultivation build-out, security, and operations.
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Insurance (general liability, product liability, workers’ compensation), with premiums varying by facility size.
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Licensing Consultation: Our attorneys guide you through ABCA requirements, preparing you for future application windows.
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Business Plan Development: We craft detailed business plans showcasing operations, compliance, and social equity commitments to impress regulators.
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Incorporation Services: We handle business entity formation, incorporating your company to meet D.C. regulations and protect your interests.
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Zoning and Local Compliance: We secure zoning approvals, manage DSLBD certifications, and navigate public comment periods.
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Social Equity Support: We assist clients in qualifying for social equity status, leveraging fee discounts and priority processing.
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Regulatory Expertise: We ensure compliance with D.C. Code § 7-1671, minimizing risks of denials or enforcement actions.
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Dispute Resolution: We represent clients in appeals or hearings, addressing licensing or zoning challenges.