FAQ — Filling out the application
The § 1301.13(k) application is more involved than most operators expect. It has seven sections, requires documentation that takes time to assemble, and contains two questions with real legal stakes. Plan one to two weeks of prep time before you sit down to file. The questions below walk through every section.
The § 1301.13(k) application is more involved than most operators expect. It has seven sections, requires documentation that takes time to assemble, and contains two questions with real legal stakes. Plan one to two weeks of prep time before you sit down to file. The questions below walk through every section.
The DEA Diversion Control Division portal at deadiversion.usdoj.gov. Standard browser, no special software.
If your entity doesn't already have a DEA registrant account — most cannabis operators won't — you create one before you can start the application. Supporting documents upload as PDFs.
The portal opened April 29, 2026. It has already seen heavy traffic. Don't leave the filing for the last day before June 27.
More than you'd expect. Treat the prep phase as a one-to-two-week project, not a same-day task.
At minimum, have ready before you open the portal:
The application has seven sections.
1. Personal/Business Information. Entity name, EIN, address, organization type, ownership history, prior DEA registrations.
2. Activity. What substances you handle. State-licensed medical marijuana is drug codes 7362 (marijuana), 7353 (marijuana extract), and 7386 (naturally-derived Δ9-THC), depending on what you handle. There's also an explicit yes/no question about whether you handle recreational marijuana — answer honestly.
3. State License(s). Your OMMA license number and expiration date.
4. Liability Questions. Five questions covering criminal history, federal licensure history, professional licensure history, and — the one that matters most — whether anyone in your ownership or operation has previously handled a controlled substance without a DEA registration authorizing it. Most established operators answer yes. Read the disclosure section of this FAQ before you answer this one.
5. Compliance Information. Supplier list with DEA numbers, your SOPs by activity type, and personnel disclosures for everyone with access to controlled substances.
6. Payment. The $794 application fee.
7. Submission. Final review and certification that everything you've said is accurate, under penalty of federal law.
A current, unexpired copy of your OMMA license. Most OMMA licenses are issued digitally; a clean PDF of the official license document is what the portal accepts.
The license must be in the name of the entity that is filing. If the license is held under a different legal name than the one applying — because of an acquisition, a restructuring, or a name change — sort that out before you file. The DEA uses the state license as conclusive evidence of authorization. If the names don't match, that evidence doesn't hold.
Section 5 asks you to identify your medical marijuana suppliers by name and, where they have one, their DEA registration number.
Here's the practical problem: most suppliers in the early window won't have federal registrations yet, because everyone is filing at the same time. Where a supplier doesn't have a DEA number yet, use their OMMA license information instead.
If your supplier list changes after you've been approved, you have ongoing update obligations. It's not a one-time disclosure.
The application asks whether you have SOPs for each activity you conduct — cultivation, manufacturing, packaging and labeling, dispensing, inventory, recordkeeping, security, disposal, and personnel access controls.
The answer for most OMMA operators is yes. OMMA compliance has required documented procedures in most of these areas for years.
The important distinction: you're identifying that SOPs exist, not uploading the full text. Your SOPs need to be on the shelf and available for inspection — not attached to the application.
State-law SOPs are accepted where they meet federal minimums. Most mature OMMA-compliant SOP packages do. Where they don't — primarily in areas where state law is silent and federal law has specific requirements — a federal addendum may be needed. That's a relatively narrow gap for most operators.
For every person who will have access to controlled substances at the registered location: full legal name, biographical detail, Social Security number, any individually-held DEA registration numbers, and criminal history.
The "who" is broader than just your security staff or your compliance officer. It covers anyone in the chain of custody at the location — which in a dispensary setting, for example, includes anyone who handles product. In a grow or processing facility, it includes anyone with access to the plant area.
This is one of the sections that takes time to assemble. Start the personnel roster early in the prep phase.
Criminal history is self-disclosed in the application for each person you list in the personnel section. You report it; the DEA then conducts its own background investigation as part of the review.
OMMA background-check documentation — whatever you collected when those employees were hired — should be retained on-site and available for inspection, but it generally doesn't get uploaded with the federal application.
Be accurate in what you self-disclose. The DEA will verify it. Discrepancies between what you report and what the investigation finds are a more serious problem than the underlying history itself.
The $794 application fee is currently paid through PayPal at the time of submission. Additional payment methods are reportedly being added to the portal, but PayPal is what's available now.
Renewal fees — when they come due — use existing DEA fee-payment infrastructure, which supports ACH and check in addition to online payment.
The $794 is per location. An operator filing for three dispensary locations files three applications and pays three fees.
Yes, through the DEA's standard modification process. But don't treat post-submission amendment as a substitute for a clean initial filing.
Minor corrections go through the registrant portal. Material changes — ownership structure, activity scope, location address — require a formal modification and restart certain parts of the review. An amendment is not a do-over; it adds process.
Get it right the first time. The prep work in the two weeks before you file is how you do that.
Separate filings for each state, each location, each activity type. There's no consolidated multi-state registration. An operator in Oklahoma and Florida files in both states separately, with separate state-specific license documentation, separate personnel disclosures where personnel differ, and separate fees per location.
This is mostly a question for operators already thinking about expansion. If you're Oklahoma-only right now, the answer is simple: one state, one set of filings.
Several. One legal entity, multiple registrations.
Each activity type — grower, processor, distributor, dispenser — requires its own registration, even under the same entity. Each physical location requires its own application.
A fully vertical operation with a single grow site, a single processing and distribution facility, and three dispensary locations files five registrations: one for the grow (Form 225), one for processing/distribution (Form 225), and three dispensary registrations (Form 224, one per location). Five applications, five fees.
The scope of each registration is bounded by the OMMA license at that location. A Form 225 filed on a grower license can't be used to authorize dispensing.
Early filers — submitted by June 27, 2026: six-month processing target. Plan for decisions in the late October to early November 2026 range, with some variation depending on how complex your application is.
During that period, if you filed inside the window, you're authorized to keep operating under your OMMA license. The timeline is less operationally critical for you than it is for a late filer, because you have cover while you wait.
Late filers — submitted after June 27: no timeline commitment. Historical DEA processing has ranged from a few months to well over a year. No during-pendency operating protection. The wait is both indefinite and legally exposed.
Honestly. Yes is the right answer for most established operators.
Here's the reasoning. Before April 28, 2026, every state-licensed cannabis activity in the United States was, federally, handling of a Schedule I substance without a DEA registration. That's what the law said and that's what every OMMA-licensed operator was doing, regardless of how clean the state-side compliance was. The federal text didn't distinguish between an operator running clean under state license and an operator running an illegal grow.
So if you've been operating in Oklahoma under an OMMA license for any meaningful period before April 28, the truthful answer to the question is yes.
False or incomplete answers are federal crimes under 18 U.S.C. § 1001 and 21 U.S.C. § 843. The DEA verifies what you disclose. Getting caught lying is much worse than the underlying history. DOJ has signaled it does not intend to use this disclosure as an enforcement tool against state-licensed operators — that's why the question is survivable. It's not why the question can be skipped or shaded.
This is the question on the application most worth running past counsel before you submit. The yes-answer narrative matters.
In a narrow technical sense, yes. The application puts on the federal record activity that was, before April 28, federally unauthorized handling of a controlled substance. That record exists now in a way it didn't before.
The exposure is heavily mitigated by three things working in operators' favor. First, DOJ has explicitly said it does not intend to use this process to enforce against state-licensed operators. Second, the rescheduling itself prospectively legalizes the activity going forward — the conduct being disclosed is now permissible activity for a state-licensed medical operator. Third, the rule's structural presumption in favor of granting registration means the disclosure is the path to federal cover, not a trap.
The exposure is not zero. Operators with unusual fact patterns — prior federal investigations, criminal records of principals, activity that went beyond what state license authorized — face higher residual risk and should engage counsel before filing. For the typical operator running clean under OMMA, the disclosure carries the protection of the broader regulatory design around it.
Yes — multiple signals, all pointing the same direction.
The rule preamble itself indicates DOJ does not intend the registration process as an enforcement tool against state-licensed activity. Acting AG Blanche's statements at the time of signing reinforced the same point. And the structural design of Section 1301.13(k) — cooperative federalism with the state, automatic suspension tied to the state license, the presumption of granting registration — is consistent with a posture of integration rather than enforcement.
None of these signals are legally binding. They're policy, not law. A future administration could take a different posture toward the same disclosed information. The signals are reasons to file with confidence; they aren't guarantees.
No formal safe harbors. No non-prosecution agreements. The protections for state-licensed operators come from two places: the rescheduling itself, and DOJ's enforcement priorities.
The rescheduling is structural and durable. It changed federal law and the federal characterization of state-licensed medical activity. That protection isn't going anywhere short of the order being overturned in court or repealed by Congress.
Enforcement priorities are discretionary. They can shift with an administration change. Today's posture is favorable to state-licensed operators; the same posture is not guaranteed forward.
Operators who want belt-and-suspenders protection beyond the structural protections sometimes seek individualized opinions of counsel, or in unusual cases, pre-filing consultation with DOJ. Those are case-by-case calls for operators with specific concerns, not standard practice.
Limited registrant information shows up in the DEA's public registrant database: name, address, DEA number, registration type, activity, expiration date. That's the standard transparency for any DEA registrant.
The substantive application content — financial information, personnel disclosures, criminal histories, ownership detail, supplier lists — is not generally public. It sits inside the agency.
That said, it isn't locked away. Information in the application can be reached through specific legal processes: FOIA requests (subject to redactions), subpoenas in litigation, regulatory inquiries, congressional oversight. The application should be treated as a document that may eventually be examined by parties beyond DEA review staff — not as a confidential filing.
Severe. Three categories of consequence.
Criminal. False statements on the application are federal crimes under 18 U.S.C. § 1001 and 21 U.S.C. § 843. Each carries potential imprisonment and substantial fines. The certification you sign in Section 7 puts the consequences on the record.
Civil. Immediate registration denial or revocation. If a false statement is discovered after the registration is granted, the registration is revocable and the path back to good standing is long and uncertain.
Reputational. Revocation orders are public record. The DEA publishes them. For an OMMA-licensed operator depending on banking relationships, vendor relationships, and patient trust, a public DEA revocation is a structural problem that extends well beyond the federal registration itself.
The combination of severity and the verifiability of the application makes shading the answers a worse decision than honest disclosure with counsel-managed framing. The disclosure questions can be survived. False answers can't.
