Third Party Relationships
Senate Bill 74 — Third-Party Relationships
Senate Bill 74 was passed during the 2025 legislative session, effective October 1, 2025. The bill contains the following language in Section 5 (7):
“A licensee may contract or otherwise engage a third party to perform work on behalf of any aspect of a marijuana business. All third-party relationships must be disclosed to the department before a third party can begin performing work on behalf of any aspect of the marijuana business. An individual performing work for any aspect of a marijuana business must secure a worker permit pursuant to 16-12-226. A licensee is responsible for ensuring a third party is compliant with marijuana laws and is liable for any violations.”
Disclosure Requirement
All licensees must disclose the status of any third-party relationships (business and/or individual) associated with their licensed business.
Note: If no such relationships exist, the licensee must attest accordingly.
Submit in the TransAction Portal (TAP) by October 1, 2025
All disclosures and attestations must be submitted through our secure TransAction Portal (TAP) and received no later than October 1, 2025. With the launch of this new online feature, licensees may not only submit the required disclosure but can also view or update third-party relationship information at any time.