October 20, 2023
Last Update: September 1, 2026
If you’re interested in learning how to start a cannabis delivery service business in Minnesota, a good place to start is with the cannabis delivery service license.
Minnesota’s cannabis market is now actively licensing businesses following the adoption of Minnesota Rules, Chapter 9810, which took effect on April 14, 2025. Among the license types available is the cannabis delivery service license: a business-to-consumer delivery license that allows licensed operators to transport and deliver cannabis and hemp products directly to customers.
Obtaining this license isn’t a straightforward process and licensed operators are subject to detailed operational requirements under both the statute and the OCM’s guidelines.
It’s worth noting at the outset that the Minnesota Office of Cannabis Management (OCM) is not currently accepting new applications for cannabis delivery service licenses. Prospective applicants should monitor the OCM’s License Types page for updates on future application windows.
Authorized Actions
Under Minnesota Statutes § 342.41, Subd. 1, a cannabis delivery service license entitles the holder to:
- Purchase cannabis flower, cannabis products, lower-potency hemp edibles, and hemp-derived consumer products from: licensed cannabis microbusinesses with a retail endorsement, cannabis mezzobusinesses with a retail endorsement, cannabis retailers, and medical cannabis combination businesses
- Transport and deliver those products directly to customers
- Perform other actions approved by the OCM
Note that the scope of products covered, including lower-potency hemp edibles and hemp-derived consumer products, is broader than simple cannabis flower and products.
Additional Information Required
Aside from the standard application information that will have to be submitted by all applicants, those seeking a cannabis delivery service license will have to provide some additional information, including:
- A list of all vehicles to be used in deliveries, including each vehicle’s make, model, and color; the vehicle identification number (VIN); and the license plate number.
- Proof of insurance for each vehicle.
- A business plan demonstrating policies to avoid sales to individuals under 21 years of age and plans to prevent the visibility of cannabis flower, cannabis products, lower-potency hemp edibles, and hemp-derived consumer products to individuals outside the delivery vehicle.
Multiple Licenses
Under current OCM guidance, a cannabis delivery service licensee may simultaneously hold the following licenses:
- Cannabis retailer
- Cannabis wholesaler
- Cannabis transporter
- Cannabis event organizer
License stacking requires careful planning. For example, a cannabis retailer licensee is permitted to also hold a delivery service license, but a retailer may not hold a wholesaler license outside of the micro- or mezzobusiness contexts. Applicants should carefully map out their intended license combination before applying, as the restrictions on each license type interact with one another.
Cannabis Delivery Service Operations
When Minnesota’s cannabis law was first enacted in 2023, many of the specific operational rules for delivery services were left to the OCM to establish by rule. Those rules have now been adopted. Minnesota Rules, Chapter 9810, took effect on April 14, 2025, and cannabis delivery service licensees are subject to the following concrete requirements:
Age or Registry Verification
Before completing a delivery, the licensee must ensure that the customer receiving the delivery is at least 21 years of age or is enrolled in the medical registry program. Registry verification issued by the Division of Medical Cannabis may serve as evidence of enrollment.
Pre-Payment Required
A requirement not present in the original statute but now established by rule: drivers may only make deliveries on behalf of a cannabis business with a retail license or endorsement to a customer who has already paid for the product before the delivery. A driver must not deliver a product if the cannabis business has not received payment prior to the delivery. This means delivery service operators must build pre-payment verification into their standard operating procedures.
Driver Requirements
Under Minnesota Rules § 9810.2600, Subp. 3A, all drivers of delivery vehicles must possess a valid Minnesota driver’s license. Additionally, under § 342.42, Subd. 7, only cannabis workers employed by or contracted with the delivery service who are at least 21 years of age may transport regulated products. All passengers in a delivery vehicle must also be cannabis workers employed by or contracted with the delivery service; no non-employee passengers are permitted.
Records
The OCM has now established specific record-keeping requirements. For each delivery, the driver must carry a shipping manifest that includes:
- The customer’s name
- The delivery address
- The form of identification the customer provided to the driver
- The identification number on the government-issued ID provided by the customer
- The name of the delivery driver
- The vehicle’s time of departure from the originating cannabis business
- The time of delivery to the customer
- A description of the delivered product, including type, amount, and weight
Before taking physical possession of a delivered product, the customer must provide the driver with government-issued photo identification and sign the shipping manifest or delivery record. Drivers must deliver in person, which means products may not be left at a doorstep, in a P.O. Box, or with an unverified third party.
A driver must not complete a delivery if: the driver cannot verify the identity of the receiving customer; the customer does not sign the manifest; payment has not been received by the originating business; or (for medical patients) the patient has not provided evidence of registry enrollment to the cannabis business prior to delivery.
Failed Delivery Protocol
The finalized rules also establish a failed delivery procedure. If a delivery cannot be completed, the driver must immediately report the failed delivery to the originating cannabis business, return all undeliverable products to the retailer, and provide details including the time of the attempted delivery and the reason it could not be completed. All such events need to be logged, too.
Amount Limits
Under Minnesota Rules § 9810.2600, Subp. 2, a delivery driver may not transport more than $5,000 worth of regulated products on a single delivery route. Additionally, a driver must not have any regulated products in the vehicle that were not ordered by a customer. No unordered inventory allowed.
Statewide Monitoring System
Just like every other licensee that is involved in the chain of custody prior to the any cannabis product reaching the consumer, a delivery licensee will have to record the products delivered. Under § 342.42, Subd. 4, both the receipt of products by the delivery service and each delivery to a customer must be recorded within the time established by rule. Minnesota uses Metrc as its seed-to-sale tracking system.
Storage Compartment:
Products must be transported in a locked, safe, and secure storage compartment that’s part of the delivery vehicle or in a locked storage container with a separate key or combination pad. Under § 342.42, Subd. 5, cannabis flower, cannabis products, lower-potency hemp edibles, and hemp-derived consumer products must also not be visible from outside the delivery vehicle. This applies while driving between stops, too, not just during active delivery.
Identifying Logos or Business Names
Like transporter licensees, delivery licensees are not permitted to wrap their vehicles using any image that depicts the type of products being transported, or even the name of the delivery service if the name suggests the vehicle is part of a cannabis delivery business.
Vehicles Subject to Inspection
A delivery vehicle is subject to inspection at any time. As a result, compliance is going to be important even if that means creating some inefficiencies. For example, if a delivery driver has two deliveries to make and the recipients live next door to one another, the deliverer will still essentially have to make two stops. In other words, the deliverer will have to open the locked container, take out one order, leave the second order in the container, lock the container, and then deliver the product to the first recipient. Only after that is complete can the deliverer go back, open the locked container, and deliver the second recipient’s order to the house next door.
Starting a cannabis delivery service in Minnesota requires careful planning long before the first order goes out the door. Between licensing requirements, vehicle compliance, manifest documentation, and pre-payment systems, the operational groundwork is substantial. If you’re serious about getting into this space, Garner, Ginsburg & Johnsen can help you navigate the licensing process and build a compliance framework that holds up. Contact us to get started.