New York cannabis rules, explained for operators
What training records does a New York dispensary need?
Checked against OCM pages and the regulation text on September 6, 2026.
A New York dispensary must keep a training file for every person who works under its license. The file has to show the person's name, the date they started licensed work, the name and description of every training they finished, copies of any course certificates, and a signed and dated attestation that they completed every module.
The requirement is 9 NYCRR 125.5, titled "Responsible Workforce Training." The retention period comes from 9 NYCRR 125.13, which keeps training records on file for at least five years.
Who must be trained
The regulation covers more than employees. Section 125.5(a) says licensees shall provide the training to "all managers, employees, contractors, volunteers, or persons otherwise performing activities under a licensee's authorizations." Source: 9 NYCRR 125.5(a).
The Office's training page says the same in shorter words: "All persons performing activities under a licensed cannabis business, must complete mandatory Responsible Workforce Training." Source: OCM Responsible Workforce Training page.
People who will work fewer than 30 days get an abbreviated version. The regulation leaves the shape of that abbreviated version to the Office. Source: 9 NYCRR 125.5(b).
When it has to happen
Within 30 days of starting. Section 125.5(a) requires the training "within thirty (30) days of starting to perform licensed activities." Source: 9 NYCRR 125.5(a).
The Office's retail welcome packet lists this among the things it expects to find on inspection: "employees have required training within 30 days of hire." Source: OCM Adult-Use Retail Welcome Packet.
The training happens on the clock. Section 125.5(d) says: "Trainings shall happen during the employee's work hours and the licensee shall pay the employee their usual rate of pay while completing any required training." The training must also be at no cost to the trainee. Source: 9 NYCRR 125.5(a), (d), and (h).
What the training covers
Section 125.5(c) requires four parts. Source: 9 NYCRR 125.5(c).
| Part | What the regulation requires | Who provides it |
|---|---|---|
| 1 | The Cannabis Product Safety and Responsibility course | The Office's designated course. The Office's page describes it as a one-hour training it developed. |
| 2 | The Cannabis Workforce Responsibility course | The Office's designated course, developed by the New York State Department of Labor. The Office's page describes it as a 40-minute training. |
| 3 | "implicit bias training or cultural competency training that lasts at least one (1) hour" | The licensee, or a third party under 9 NYCRR 124.3. |
| 4 | "at least two (2) hours of other training intended to assist employees in conducting the license's licensed activities in a manner which protects employee and public safety" | The licensee, or a third party under 9 NYCRR 124.3. |
Source: 9 NYCRR 125.5(c) and (g); OCM Responsible Workforce Training page.
Section 125.5(g) says licensees "shall use only the specific Cannabis Product Safety and Responsibility course and Cannabis Workplace Responsibility course designated by the Office." A vendor's substitute for those two courses does not satisfy the rule. The other two parts can be your own training or a contracted third party's. Source: 9 NYCRR 125.5(g).
The Office's page says both designated courses are watched on YouTube, and that after watching, the trainee should "sign and date the Training Verification Form (attestation) and submit to your employer for their records." Source: OCM Responsible Workforce Training page.
Ongoing training each year
The 30-day training is not the end of it. Section 125.5(f)(4) requires licensees to "have policies and procedures for identifying training needs on an annual basis and providing ongoing training of personnel, for a minimum of four (4) hours per year, to each fulltime employee." Source: 9 NYCRR 125.5(f)(4).
The same subsection requires licensees to make sure all staff are "fully trained on all standard operating procedures, including, but not limited to, security and emergency procedures." Source: 9 NYCRR 125.5(f)(3).
Whether the two designated courses have to be repeated on a schedule could not be confirmed from the regulation text or the Office's training page. Neither states a renewal interval for those courses. UNVERIFIED
What the file has to contain
Section 125.5(i) is titled "Training Verification." It says licensees "shall keep records and shall make such records available upon request by the Office," and it names the contents. Source: 9 NYCRR 125.5(i).
"(i) trainee's name; (ii) trainee's first date of performing licensed activities; and (iii) the name and description of all trainings satisfactorily completed by trainee; and (iv) Copies of any certificates associated with the trainee's completion of the Cannabis Product Safety and Responsibility course and Cannabis Workplace Responsibility course and a page for signed and dated documentation demonstrating each employee's attestation of completion of all Responsible Workforce Training modules."
9 NYCRR 125.5(i)(2), effective September 27, 2023. Read the section.
Section 125.13 adds a second, overlapping requirement. Its list of records every licensee must keep includes training records showing "the content of the training provided and the names of the employees who received the training." Source: 9 NYCRR 125.13(c)(4).
Put together, a file that satisfies both sections has these pieces for each person.
- Name.
- First date performing licensed activities. This is the date the 30-day clock starts.
- A list of every training completed, with a name and a description of the content.
- Certificates for the two designated courses, if any were issued.
- A signed and dated attestation page covering all Responsible Workforce Training modules.
- Dates and content for the ongoing four hours per year, for each full-time employee.
How long to keep it
Section 125.13(a) says: "A licensee shall keep and maintain records required by this Title, or any other applicable federal or state rule or regulation, for at least five (5) years from the date of creation, unless a shorter time is specified by the Office." Records must be "readily retrievable and available to the Office upon request." Source: 9 NYCRR 125.13(a) and (b).
What this means for your store
- Write down each person's first day of licensed work the day it happens. Every deadline in 125.5 runs from that date, and it is the second item the regulation asks for.
- Get the training done inside 30 days, during paid hours. Inspectors are told to look for it, per the retail welcome packet.
- Use the Office's two designated courses for parts 1 and 2. Section 125.5(g) does not allow substitutes for those two.
- Have each trainee sign and date the attestation form and file it. The regulation names that page specifically.
- Keep a short description of each training, not only its title. Section 125.13(c)(4) asks for the content.
- Log the ongoing hours. Four hours per full-time employee per year is the floor under 125.5(f)(4).
- Keep every file for five years from the date it was created, including files for people who have left.