New York Bill Would Recast Labor-Related Requirements for Cannabis Businesses

June 16, 2026

By: Erin M. Callahan and Rebecca J. LaPoint

The New York Legislature recently passed a bill that would amend the Cannabis Law and the Labor Law regarding labor-related requirements for cannabis businesses. The bill, which is currently before the governor for action, would repeal the requirements for license holders and applicants to have labor peace agreements in place, impose new public disclosure obligations regarding ownership and workforce data (including wage ranges), and establish a Cannabis Industry Wage Board to study and recommend minimum wages for the industry, similar to what has been put in place for farm laborers.

Key Statutory Changes

Repealing Labor Peace Agreement Requirements

The bill would eliminate labor peace agreements as express statutory conditions across several key provisions of the Cannabis Law. Cannabis businesses would no longer be required to enter into or maintain labor peace agreements as a condition of obtaining or retaining cannabis licenses, certifications or registrations. However, the bill would preserve broader labor law compliance considerations, including review of New York labor law violations and protection for existing collective bargaining agreements.

Transparency Requirements Related to Ownership and Worker Conditions

The bill would require each applicant or renewal applicant to provide the full ownership structure of the licensee and any management service agreements, including the full ownership structure of any company providing those services. Applicants also would be required to submit a publicly available report identifying the range of salary and hourly rates for each job title and the average number of hours scheduled or offered for each position.

Establishing a Wage Board

The bill would establish a Cannabis Industry Wage Board within the Labor Law framework. Under New York’s Minimum Wage Law, the minimum wage may be raised administratively by the commissioner of labor upon the recommendations of a wage board. The new wage board would consist of one representative of the licensed cannabis industry, one representative of the New York State AFL-CIO and one member of the general public appointed by the commissioner to serve as chairperson. The wage board would be required to hold its first hearing by March 1, 2027.

The wage board would have meaningful investigatory and procedural powers, including the authority to conduct public hearings, consult with cannabis employers and workers and their representatives, administer oaths, issue subpoenas for testimony and records, and take depositions.

The wage board would be required to report to the governor and Legislature with recommendations regarding minimum hourly wages and prospective wage increases for workers in cultivation; processing and packaging; distribution; and retail and delivery. The board also could recommend wages for additional classifications, recommend an industrywide minimum wage for workers not captured within a specific classification, or determine that wages in the industry are already adequate.

When Would the Bill Take Effect?

If enacted, the bill would take effect immediately, except that the disclosure obligations and the Cannabis Industry Wage Board provisions would take effect Jan. 31, 2027. The repeal of labor peace agreement provisions would become operative immediately upon enactment. The wage board’s first hearing would then need to occur by March 1, 2027, and its report would be due by Dec. 31, 2027.

Labor and Employment Implications

While the bill remains subject to the governor’s approval, the bill, if enacted, would remove labor peace agreements as express statutory conditions of cannabis certification, registration, renewal and licensure. Employers that have already entered into labor peace agreements, however, should review them with counsel, as existing agreements remain governed by their own terms, including any ongoing obligations, notice requirements or termination provisions.

Public reporting of pay ranges by job title and average hours by position could subject wage setting, scheduling practices and compensation consistency to increased scrutiny as they are more easily identifiable to regulators, workers, organized labor, competitors and the public. Such increased scrutiny may impact negotiations and pay-rate demands.

The wage board provisions may have the most significant wage-and-hour consequences. The bill does not set a new cannabis-specific minimum wage; rather, it creates a process under which a wage board would hold hearings, collect evidence and issue recommendations regarding minimum hourly wages, prospective increases and sector-specific classifications. Because the wage board may recommend different wage rates for cultivation; processing and packaging; distribution; and retail and delivery, cannabis employers may eventually face a more segmented industry-specific wage structure than under general minimum wage rules. Any such set wages also would become the floor for any collective bargaining negotiations.

More broadly, the proposed Cannabis Wage Board follows the Legislature’s use of similar boards for farm laborers and fast-food workers, signaling a continued pattern of industry-specific wage-and-hour regulation and raising questions about which sector may be next for such treatment.

If you have questions about these proposed amendments, please contact Erin M. Callahan, Rebecca J. LaPoint, any attorney in Bond’s labor and employment practice or the attorney at the firm with whom you regularly communicate.