The Most Exciting US Market 

No cannabis market in the United States has experienced a more compelling growth trajectory over the past two years than New York. After a halting and often-criticized launch, the state’s legal adult-use market has accelerated at an unmatched pace. 

In 2023, New York generated a paltry $100 million in legal cannabis sales, far short of its expected market potential of (at least) $5 billion. In 2024, that figure expanded to approximately $900 million, nearly a tenfold increase. By 2025, sales climbed again to almost $1.8 billion, nearly doubling year over year.

Looking ahead, cannabis sales have the potential to approach $2.5 billion in 2026, reinforcing New York’s position as the most exciting growth market in U.S. cannabis. But rapid growth at the market level does not guarantee success for individual operators. 

In fact, the very forces driving New York’s expansion are also introducing a set of structural risks that cannabis businesses must be prepared to navigate.

Growth Fueled by Store Proliferation, and the Consequences

New York’s sales surge has been driven primarily by the rapid expansion of retail access. At the start of 2024, the state had approximately 50 licensed dispensaries open for business, far too few to adequately serve a state with a population of 20 million people.

By the end of 2024, that number had grown to more than 275 dispensaries, more than a fivefold increase. That torrid growth continued the next year; by the end of 2025, there were more than 525 dispensaries open in New York. Projections suggest the state will have more than 750 licensed stores by the end of 2026.

This dramatic increase in storefronts has undeniably improved consumer access, grown the legal market, and helped displace illicit sales. But it has also begun to strain retail economics. According to the New York Office of Cannabis Management (OCM), annualized retail sales per store declined from roughly $5 million in Q3 and Q4 of 2024 to approximately $3.8 million in Q2 and Q3 of 2025. 

Whether this decline persists remains to be seen. And it may be that there are other factors besides additional dispensaries driving the reduction in per-store sales. However, the recent decline has been significant and suggests that competition on a per-store basis may be intensifying faster than demand is growing.

If so, the implication is clear: simply opening a dispensary is no longer sufficient for financial success in New York. Retailers now face a much more competitive environment in which weak business practices, poor inventory management, undifferentiated product selection, or subpar customer experience can quickly threaten viability. 

The next phase of New York’s market will reward operators who invest in brand, service quality, and customer loyalty, and punish those who assume market growth alone will carry them forward.

Supply-Chain Risk and the Danger of a Credit Bubble

Notably, retail pressure may not stay confined to the retail tier. As some New York dispensaries struggle to maintain margins and cash flow, downstream effects are already emerging. In some cases, retailers have fallen behind on payments to distributors and manufacturers, creating stress across the cannabis supply chain.

The industry has seen this movie before. In California, the collapse of distributor HERBL in 2023 sent shockwaves through the market, leaving cultivators and manufacturers with millions in unpaid receivables. Many of these businesses ended up folding along with HERBL.

Perhaps this is too alarmist. New York, one might argue, is not California. But the risk is analogous. Some distributors in New York are already reporting difficulties collecting from retailers, raising concerns about a potential credit bubble forming beneath the surface of the market’s headline growth.

As such, all participants (retailers, distributors, brands) need to exercise caution in choosing partners, setting payment terms, and managing credit exposure. Growth without discipline can quickly become destabilizing, especially in a young market where balance sheets are still fragile. 

At a minimum, New York operators should monitor the OCM delinquency list, also known as the “C.O.D.” (cash on delivery) list, to identify businesses that have failed to pay suppliers on time and help ensure they do not become entangled with business partners that are not creditworthy.

Discounting Comes With Rules

In November 2025, New York’s Cannabis Control Board (CCB) approved updated marketing rules that allow dispensaries, for the first time, to offer traditional retail promotions, including discounts, coupons, loyalty programs, reward points, bundled pricing, and temporary sales. As they face increased competition, New York retailers may attempt to remain competitive through this newly allowed practice of discounting. 

But discounting in New York is far from a free-for-all, and operators who misunderstand the rules risk costly compliance violations. For instance, cannabis products may not be sold below their “market value”, defined as the minimum retail price, set at 1.5 times the wholesale price paid by the retailer for the discounted product. 

In addition, when a product is discounted, the retail excise tax must still be calculated on the pre-discounted price. If a $10 item is discounted to, say, $8, the excise tax is still applicable to the pre-discounted price of $10.

This requirement means retailers must ensure their POS systems are properly configured to handle discounted pricing without underpaying taxes. This is a nontrivial operational challenge for businesses already stretched thin.

The Illicit Market Still Looms Large

Even as the legal market grows in New York, the continued presence of unlicensed cannabis retailers remains a major threat to legal operators. Illicit stores continue to siphon demand, depress legal prices, and undermine the regulated market’s ability to fully realize its potential. 

By the OCM’s own admission, enforcement against illicit cannabis operators stalled in 2025 – with just 2,017 “enforcement actions” undertaken in 2025, compared to 5,215 such actions undertaken in 2024. 

The OCM has cited the completion of a well-funded 2024 multi-agency enforcement task force as a key reason for the dip in enforcement in 2025. This lack of enforcement against unlicensed activity helps explain much of the 25% decline in annualized retail sales per store – from $5 million to $3.8 million – that occurred in New York in 2025.

Given this concerning reality, legal operators must immediately press policymakers, particularly Governor Kathy Hochul and New York City Mayor Zohran Mamdani, to enforce existing laws against illegal cannabis sales. Such a commitment was glaringly absent from Governor Hochul’s “State of The State” address on January 13th, where other cannabis priorities were mentioned but New York’s growing illicit cannabis market was not.

And the case for enforcement should not be framed solely as an industry concern. Under the Marijuana Regulation and Taxation Act (MRTA), passed with much fanfare in March 2021, legal cannabis tax revenue is earmarked for non-profits, community organizations, and social programs. And so, any lapse in enforcement that politicians enable directly jeopardizes those commitments.

Legal cannabis businesses should be proactive in communicating this message, in partnership with the local non-profits and social organizations that depend on cannabis tax revenue. Working together, these parties should make clear that enforcement against illegal activity is essential to delivering on the social justice goals that political leaders like Governor Hochul and Mayor Mamdani so frequently and poetically invoke in their discussion of cannabis policy on the campaign trail.

And they should make clear that rhetoric alone is not enough from politicians. They must insist, vocally, that sustained enforcement is the only way to protect the legal cannabis supply chain and the long-promised public benefits tied to it.

METRC, Product Inversion, and the Integrity of the Supply Chain

Another looming challenge is the continued risk of product inversion, cannabis from outside New York entering the legal supply chain. This threatens compliant operators, particularly in-state brands that are already operating with limited capital and thin margins.

The ongoing implementation of METRC, currently being challenged by a recently filed lawsuit, is essential to protecting the integrity of New York’s market. But it must be handled carefully. 

Going forward, the state needs to provide operators, especially smaller ones, with adequate guidance, training, and technical support to comply with the METRC system. A chaotic or poorly supported rollout could disrupt the supply chain and inflict irreparable harm on businesses that are attempting to follow the rules.

At the same time, indefinite delays in METRC implementation would prove problematic. Without a fully operational track-and-trace system, bad actors will be able to continue to invert illegal product and legal operators would be disproportionately harmed. New York must thread the needle: implementing METRC effectively, without perpetual delay, while ensuring it does not become another unintended obstacle to legal commerce.

In addition, S.8951, a bill recently introduced by Senator Jeremy Cooney, can also help keep illicit cannabis out of New York’s regulated market. As the Empire State Green Standard Alliance, which advocates for New York cannabis consumers, has noted, the bill clearly defines cannabis inversion, makes it explicitly illegal, and backs enforcement with real consequences, including major financial penalties, license revocation, lab accountability, personal liability for responsible executives, and strong whistleblower protections.

Taken together, these measures, if successfully implemented, can help address the inversion that has tainted New York’s legal cannabis market.

A Market Worth Betting On, With Eyes Wide Open

The growth in New York’s cannabis market over the past two years has been extraordinary, and the runway ahead remains long. But this is no longer a market where every operator will rise with the tide. The next phase will separate disciplined, well-capitalized, customer-focused businesses from those unprepared for competition, compliance, and financial pressure.

For operators willing to navigate these challenges thoughtfully, New York remains one of the most important cannabis opportunities in America. For those who mistake growth for inevitability, it may prove far less forgiving.

The post New York’s Cannabis Boom Is Real, But So Are the Risks appeared first on Cannabis Industry Journal.