Gone are the days when buyers and sellers would wait months to hear back from an OLCC investigator after filing a change of ownership application. OLCC “processing dates” page. reports that applications for change of ownership are now being assigned and processed until September 3, 2025. This is not true. Over the past month or so, we have seen a number of applications set within a week or two of submission. They move fast.

b. Completed applications are required

OLCC Licensing Officers have begun pre-screening applications and are returning applications that lack the required documents. The old practice of applicants uploading filler documents will no longer be accepted. The idea here is to ensure that organized applicants are not forced to wait in line behind their unorganized counterparts, creating a bottleneck. In the future, incomplete applications will be delivered to the assignment queue only after all missing documents have been provided.

c. The 60-day appointment period expires

In case you missed it, the OLCC filed a Notice of Proposed Rulemaking September 25, 2025. The main aim was to comply with the 2025 legislation, but some technical updates were also made. These include OAR 845-025-1135(2)(A) and (B), which provide that applicants:

“…must complete the application process within 60 calendar days after the Commission notifies the applicant that the application has been designated,” and that “if the applicant does not complete the application process within 60 calendar days, the application will be canceled and suspended.”

Getting into such purgatory is a dangerous game. Most purchase agreements have cancellation periods, deposit forfeiture provisions, and other negative consequences for buyers, particularly those who fail to move forward properly. On the seller’s side, the downloaded program can be disruptive if there are problems with the landlord or if the seller has given the keys to management contract— something people still do regularly, often against advice.

d. Limited inspectors

We have recently experienced some delays with the availability of an OLCC inspector. There are probably not many of them. Several are also designed for large areas, making planning a challenge. Things tend to slow down around the end of the year holidays as well. When there is a change of ownership, final inspections are usually required by both the buyer and the seller, and the parties should be flexible.

Different market dynamics

a. Buyer’s market

Too many OLCC license and business sales these days are “fire sales”. Many sellers fail businesses that want to salvage some valuables under duress and leave in a hurry. This gives buyers significant leverage that should continue unabated even as the OLCC improves its processes and despite the ongoing moratorium on new licenses. These market dynamics are the new normal and have been for some time.

b. Brokers

Cannabis transactions in Oregon continue to suffer from unscrupulous or incompetent cannabis dealers brokerswith few exceptions. Every week, buyers and sellers come to us with confusing LOIs, dangerous purchase agreements, stupid leases and other contracts drawn up by brokers, some of whom also purport to act as escrow agents, application consultants and general counsel. We have spoken to these brokers and even filed malpractice complaints; but ultimately buyers and sellers should use common sense here.

c. Buyer profiles

We’ve been seeing a lot of Chinese buyers in the last year or so, following the Eastern European wave of buyers a few years ago. Existing network operators also continue to rake in licenses here and there. At the moment, there is very little action from multi-state operators (MSOs), and it would appear that Canadian public companies are not interested.

Stay tuned

I’ll touch on all of this again at the end of the year at my annual Oregon Cannabis “The state of the state“. In the meantime, take care and please give us a call if you need help getting or eliminating your Oregon cannabis license.

Source: Legal Canna Blog