New Hampshire Therapeutic Cannabis License Types: A Complete Guide for Operators (2026)

New Hampshire operates an exclusively medical cannabis program called the Therapeutic Cannabis Program (TCP), established in 2013 under RSA Chapter 126-X. The program took effect in 2016 when the state's first licensed dispensaries opened. The New Hampshire Department of Health and Human Services (DHHS) administers the program and issues all ATC registrations. As of 2026, New Hampshire remains the only New England state without legal recreational cannabis. Adult-use bills have passed the House in recent legislative sessions, most recently HB 186 in January 2026, but the current governor has stated opposition to any legalization measure.

New Hampshire's licensing framework is notably different from most other medical cannabis states in two structural respects. First, the state issues a single license type the Alternative Treatment Center (ATC) which covers all commercial cannabis activity. There are no separate cultivation, manufacturing, and dispensary licenses. Each ATC is a vertically integrated entity authorized to cultivate, process, transport, and dispense cannabis under one registration. Second, every ATC must be organized and operate as a non-profit corporation registered with both the New Hampshire Secretary of State and the New Hampshire Attorney General's office as a charitable trust for the benefit of qualifying patients.

New Hampshire has three licensed ATCs currently operating seven dispensary locations across the state. The three entities are GraniteLeaf Cannabis (formerly Prime ATC), Sanctuary ATC, and Temescal Wellness. DHHS is not currently accepting applications for new ATC registrations. No new ATCs have been licensed in years the department will issue a Request for Applications (RFA) when it determines that existing ATCs are insufficient to meet patient needs.

All ATCs use BioTrack as the required seed-to-sale tracking system. There is no state sales tax on medical cannabis in New Hampshire.

The Alternative Treatment Center (ATC) License

The Alternative Treatment Center license is the only cannabis business license issued in New Hampshire. A registered ATC is authorized to acquire, possess, cultivate, manufacture, deliver, transfer, transport, sell, supply, and dispense cannabis and related supplies and educational materials to qualifying patients, designated caregivers, visiting qualifying patients, and other ATCs. No entity other than a registered ATC may engage in any commercial cannabis activity in the state.

Vertical Integration and Facility Structure

Every ATC must handle all stages of the cannabis supply chain within its own registered entity. An ATC cultivates cannabis at a dedicated cultivation location defined under He-C 402 as a locked, indoor, and enclosed site secured with commercial-grade locks and security devices. Cultivation must occur indoors in an enclosed, locked facility. The cultivation location may be at a separate address from the dispensing location, and ATCs may apply for approval of a secondary site for cultivation and processing distinct from the primary dispensary. Both locations must be individually inspected and approved by DHHS before becoming operational.

Non-organic pesticides are prohibited in ATC cultivation operations. This is not limited to synthetic pesticide products the restriction applies broadly to any pesticide that is not certified organic, consistent with the program's public health-focused regulatory approach.

Geographic Areas and Dispensary Location Structure

Under RSA 126-X:7, New Hampshire divides the state into four geographic areas for ATC coverage. Each geographic area is served by one registered ATC. One ATC may be registered in more than one geographic area, which is how three entities currently serve all four areas statewide. An ATC registered in a geographic area may operate only one dispensing location within that area, unless DHHS determines that a second dispensary location is necessary to adequately and effectively meet the needs of qualifying patients in that area. When DHHS does authorize a second dispensary location, that location must be limited to dispensing and patient education it may not be used for cultivation or production.

DHHS is required, to the greatest extent practicable, to ensure that ATCs are geographically positioned to best serve patients across the state. In reviewing any application for a new ATC or a second dispensary location, DHHS evaluates the geographic convenience of the proposed location relative to where qualifying patients reside.

ATC Registration Requirements

ATC applicants go through a multi-stage process. DHHS first issues a Request for Applications when it determines additional ATC capacity is needed. Applicants compete through an RFA process, and selected entities then proceed to a formal registration process under He-C 402.05 before becoming operational.

The initial registration fee is $20,000, payable within 10 days of DHHS notice that the entity has been selected from the RFA process. Failure to pay within this window results in forfeiture of the selection and bars the entity from reapplying in the same application cycle. Following fee payment, the entity submits a full application package. DHHS issues registration approval after a facility inspection confirms full compliance with RSA 126-X and He-C 402. A conditional registration certificate may be issued to allow the entity to begin cultivation and processing in anticipation of achieving full operational status.

Every applicant must provide the following as part of its registration application under He-C 402.05: a Certificate of Good Standing from the New Hampshire Secretary of State authorizing the ATC to do business as a not-for-profit corporation; proof of registration with the NH Attorney General's office as a charitable trust under RSA 7:19 et seq. for the benefit of qualifying patients; results of federal and New Hampshire state criminal background checks for all corporate officers, board members, and executive employees; a list of all persons or entities with direct or indirect authority over management or policy; and a list of all persons contributing $5,000 or more of initial capital, including capital in the form of land or buildings.

ATCs are required to maintain $2 million in liability insurance coverage covering bodily injury and property damage at the dispensary premises and errors and omissions by the ATC and its employees. This coverage must be in place before operations begin and maintained throughout the license term.

Board of Directors Requirements

The non-profit board of directors of every ATC must include at least one licensed physician, advanced practice registered nurse (APRN), or pharmacist licensed to practice in New Hampshire, and at least one patient who is qualified to register as a qualifying patient under the Therapeutic Cannabis Program. A majority of board members must be New Hampshire residents. A medical professional serving as a board member may not maintain any ownership interest in the ATC the role is purely advisory and governance-focused. No ATC employee or agent may have been convicted of a felony or a felony drug-related offense. There is no exemption for cannabis-related convictions.

Distance and Location Restrictions

No ATC dispensary location may be established within 1,000 feet of a pre-existing designated drug-free school zone or school property. Applications must include documentation of the distance in feet from the proposed premises to any designated drug-free school zone located within 1,320 feet of the site. ATCs may operate in any municipality in New Hampshire but must comply with all applicable local zoning ordinances and obtain required local approvals before DHHS will issue or approve a registration for that location.

Operational Requirements

Only certified ATC technicians may dispense cannabis or cannabis-infused products (CIP). Every patient or caregiver seeking to purchase must present a valid, active registry identification card and valid photo identification. All dispensing records must document transactions by registry identification number, not by patient name, to protect patient confidentiality under RSA 126-X and the applicable provisions of HIPAA. ATCs must track all dispensing in the BioTrack seed-to-sale system and maintain these records in compliance with state regulations.

ATCs must provide patients with educational materials at each dispensing, including information about available strains, dosing, and the risks and therapeutic effects of cannabis. They are also required to collect information that patients voluntarily provide about strains' effectiveness and side effects, contributing to the program's quality improvement framework.

Security requirements under He-C 402.24 cover interior and exterior lighting, physical security measures including commercial-grade locks, video surveillance systems, alarm systems, duress alarms, measures to prevent loitering, and on-site parking. All security systems must meet DHHS specifications, and all recordings and access logs must be made available to DHHS and law enforcement upon request.

All cannabis cultivated and processed by an ATC must be tested by a laboratory licensed by DHHS under RSA 151 before it is dispensed to patients. Testing covers potency, contaminants, pesticides, and other safety parameters. ATCs may not dispense untested product.

Advertising by ATCs is tightly restricted. ATCs may maintain signage at their licensed locations and operate an official website but may not advertise on television, radio, billboards, or in print media. Digital advertising beyond the ATC's own website is heavily restricted. No advertising may target individuals under 21 or make therapeutic claims that are not supported by evidence.

Patient Possession and Purchase Limits

Qualifying patients may possess up to two ounces of cannabis at any one time. Patients may purchase up to two ounces from any ATC location within a 10-day period. The two-ounce limit applies across all ATC locations in the state a patient may purchase from any NH ATC dispensary, and the combined amount across all purchases within the 10-day period may not exceed two ounces.

Home cultivation of cannabis is not permitted in New Hampshire for any patient or caregiver, regardless of medical status.

Visiting Patients from Out of State

Effective October 1, 2024, under HB 1278, visiting out-of-state patients who present documentation that they are authorized to possess cannabis for therapeutic purposes in their home state or province may purchase from NH ATCs at the same frequency as New Hampshire qualifying patients. This removed the prior three-visit-per-year cap for out-of-state visitors and applies regardless of the qualifying medical condition. Visiting patients from Canada are also eligible under the same terms. Visiting patients may not cultivate cannabis in New Hampshire or obtain cannabis from a New Hampshire patient or caregiver.

Qualifying Conditions

Effective October 1, 2024, under HB 1278, New Hampshire significantly expanded patient eligibility. Any NH-licensed medical provider with prescriptive authority may now certify adult patients 21 years of age or older for "any debilitating or terminal medical condition or symptom for which the potential benefits of using therapeutic cannabis would, in the provider's clinical opinion, likely outweigh the potential health risks for the patient." For patients under 21, a specific qualifying condition is still required. Generalized Anxiety Disorder was added as a named qualifying condition in September 2024. The expanded provider types who may now certify patients include dentists, podiatrists, optometrists, and naturopathic doctors, in addition to physicians, APRNs, and physician assistants. All certifying providers must hold an active NH license in good standing with DEA prescriptive authority.

Adult-Use Legislative Context

New Hampshire is the only New England state that has not legalized recreational cannabis. Legislative efforts to create an adult-use market have continued through multiple sessions. HB 1633 passed both the House and Senate in 2024 under a state franchise model but did not become law. In January 2026, HB 186 passed the House 208-135, which would legalize adult-use possession and create an independent Cannabis Commission to regulate both therapeutic and adult-use cannabis. The bill faces significant opposition from the current governor's office. Because New Hampshire has no citizen ballot initiative process, legalization requires both legislative approval and gubernatorial signature or a constitutional amendment requiring 60% approval in both chambers and two-thirds voter approval. HB 54, which would allow existing ATCs to restructure as for-profit entities, passed the House unanimously in January 2026 and, if enacted, would be the first statutory change to the ATC structure since the program launched.