What SB 1064 and AB 179 Predict About DCC’s Combined Activities and Ownership Rulemaking

DCC’s “Combined Activities License & Ownership Updates” rulemaking is calendared for Summer 2026. Per DCC: SB 1064 (2024) “creates a new license type … and modifies ownership requirements”; AB 179 (2024) “removes the fingerprint requirement for certain owners.” It touches 4 CCR § 15002 and § 15003 among 15 affected regulations; no text has posted on DCC’s rulemaking page. AB 179 changes owner disclosure for every California cannabis licensee; SB 1064 reshapes combined applications.

The two statutes

SB 1064 (Ch. 991, 2024) added Bus. & Prof. Code § 26001(m) authorizing two or more cannabis activities at one premises (testing excepted); amended § 26051.5(a)(1)(G) to add (iii): “an owner shall not be required to resubmit owner-related information previously provided”; and extended § 26070(a)(3)(B) so DCC “shall establish a process by which an applicant for a … combined activities license can demonstrate compliance.”

AB 179 (Ch. 997, 2024 trailer; Section 5.5 governs) narrowed § 26051.5(a)(1) for every licensee: Live Scan is required only for owners “as defined in paragraphs (1) to (3), inclusive” of § 26001‘s owner definition — the 20%+ aggregate holder, CEO or equivalent, and nonprofit board members. Paragraph-(4) owners are exempt.

Neither amends § 26001(aq)‘s four-part definition or § 15003‘s parallel regulatory owner categories.

The purpose constraint

SB 1064’s SEC. 1(f): “to … promote efficiency … and reduce barriers to entry into the legal, regulated market.” DCC’s § 26012 rulemaking runs through California’s APA. Under Gov. Code § 11342.2, a regulation must be “reasonably necessary to effectuate the purpose of the statute”; under § 11342.1, “within the scope of authority conferred.” DCC’s SB 1064 implementation is bound by that purpose; its AB 179 implementation cannot exceed § 26051.5(a)(1)‘s narrowed scope.

What DCC’s proposed § 15002 and § 15003 will likely include

For SB 1064’s combined-activities piece:

1. A single § 15002 owner-submission package for the combined premises — one filing per owner, not one per activity.
2. A prior-submission certification path. An owner already on file certifies the on-file information is current in lieu of resubmission — signed certification, defined content list, look-back window.
3. A paired update rule. The certifying owner notifies DCC of changes within a defined window — likely 14 calendar days, matching DCC’s existing ownership-change cadence.

For AB 179’s fingerprint narrowing:

• A conforming amendment at § 15002(c)(16)(K) — DCC’s current Live Scan hook — narrowing the requirement to owners defined in paragraphs (1) to (3) of § 26001(aq).

What DCC will not likely propose: expansion of the § 26001(aq) definition, a lower 20% threshold, additions to § 15004 financial-interest categories, or Live Scan reach-back onto paragraph-(4) owners. Each exceeds scope.

Four drafting moves

For every California cannabis licensee (AB 179):

• Flag paragraph-(4) owners on your schedules. Managers and operational leads remain owners under (aq)(4) but no longer submit Live Scan. Stop Live Scan for them; keep it for (1)–(3) owners.
• Add unchanged-ownership reps and 14-day covenants. In operating agreements and shareholder agreements, each owner represents DCC-filed information is current and covenants to update within 14 calendar days. This tracks DCC’s ownership-change cadence.

For operators seeking a combined activities license (SB 1064):

• Consolidate your § 15002 records across licenses. The resubmission carve-out only saves refiling when previously-filed information is complete and consistent. Audit and reconcile now.
• Structure the combined application as one owner package. When you assemble the combined activities license application, build one § 15002 filing for the combined-premises entity — not stapled per-activity filings.

Read both statutes to read DCC’s next rulemaking package in advance.