What Happens During an OCM Compliance Inspection
OCM’s enforcement arm conducted 401 compliance inspections in 2025, resulting in 2,017 enforcement actions. If you hold a dispensary license, an inspection isn’t a question of if — it’s when.
Here’s what the process looks like from start to finish, based on 9 NYCRR Part 133 and publicly available OCM enforcement data.
Step 1: The Inspection
OCM inspectors can visit your location announced or unannounced. They review your physical premises, product storage, point-of-sale compliance, signage, and — increasingly — your website and social media.
Inspectors check for the same things our scanner does: age gate, warning statements, HOPEline info, license number display, health claims, youth-attractive content, and more. The difference is that an inspector can also review things we can’t see remotely: product packaging, employee conduct, security measures, and recordkeeping.
Website violations are increasingly common inspection findings because your site is publicly accessible and easy to screenshot as evidence.
Step 2: Statement of Findings
After the inspection, OCM issues a Statement of Findings documenting every violation observed. This is your formal notice that issues were found.
The Statement of Findings is not a fine — it’s the starting point. What happens next depends on how you respond.
Step 3: Corrective Action Plan (CAP)
For most violations, OCM will request or require a Corrective Action Plan. This is your opportunity to fix the issues before penalties are assessed.
Standard violations: You typically have 15 days to submit and implement a corrective action plan.
Critical violations: Issues involving public safety, minor access, or product safety may require correction within 24 hours. An age gate violation (§129.2(l)) or youth-attractive content (§129.2(b)(1)) could fall into this category.
If you fix everything within the CAP window and demonstrate compliance, many first-time violations can be resolved without monetary penalties. This is why catching violations before an inspection is so valuable — you can fix them on your own timeline instead of under a 15-day (or 24-hour) deadline.
Step 4: Notice of Pleading (NOP)
If you fail to submit a CAP, fail to implement corrections, or if the violations are severe enough, OCM issues a Notice of Pleading. This is formal charges with a proposed penalty.
At this point, the fines from Cannabis Law §16 come into play: up to $5,000 per violation for a first offense, with significantly higher penalties for repeat violations. Each page of your website with a violation can be counted as a separate offense.
A dispensary with a missing warning statement across 20 pages faces a theoretical maximum of $100,000 in first-offense fines for that single rule alone.
Step 5: Hearing or Consent Agreement
After a NOP, you have two paths: negotiate a consent agreement (a settlement) or request a formal hearing before an administrative law judge.
Most licensees opt for a consent agreement, which typically involves paying a negotiated fine and implementing corrective measures. The hearing process is more adversarial and can result in the full proposed penalty being assessed.
Step 6: License Suspension or Revocation
For repeated violations, failure to comply with a consent agreement, or severe public safety issues, OCM can suspend or revoke your license under Part 133.
License revocation is the nuclear option and is reserved for the most serious cases. But suspension — even temporary — means lost revenue, reputational damage, and a public record that follows your license.
The Timeline Matters
Here’s what most dispensary owners don’t realize: the entire enforcement pipeline — from inspection to NOP — can move in weeks, not months. And once a Statement of Findings is issued, the clock starts running whether you’re ready or not.
The best time to find and fix compliance issues is before an inspector does. A $997 compliance report is a rounding error compared to a $5,000-per-page fine and a consent agreement on your permanent record.
Don’t Wait for OCM to Find Your Violations First
Our scanner checks your website against all 23 OCM advertising regulations in under two minutes. You’ll know exactly what an inspector would flag — and you can fix it before they show up.
Run a free compliance scan now.