What happens if your cannabis licence expires: can you reapply?

5 in 6 Thai cannabis licences due in 2025 were not renewed. If your licence has expired, for whatever reason, the options are narrower than many owners expect.

Renewal ends at expiry

A shop licence runs to 31 December of the third year from its year of issue, and the renewal must be filed in the sixty days before expiry. Verified After expiry there is nothing left to renew. The holder must apply for a new licence.

A new application is a new test

A new application is judged under the rules in force on the day it is decided. Since 30 April 2026 that means the eligibility list of Ministerial Regulation No. 2: a qualifying underlying licence or certificate, or a supplying cultivation site. DTAM can also refuse on the premises, the location or other grounds. Verified See what the 30 April 2026 rules changed.

The risk of trading on

Selling flower without a licence carries up to 1 year in prison, a fine of up to THB 20,000, or both. Verified The bigger risk is what follows: a record that makes the next application harder, and inspections that the Prime Minister directed on 22 October 2026. See why some dispensaries are still open.

If you filed in time

A licensee that has filed within the sixty-day window may keep trading until the licensor refuses, on the reading of the published texts. Whether a shop that filed in time may trade between expiry and the decision is not settled in the published texts. Estimated Keep proof of the filing date.

What to do now

• Check the expiry date on your licence today.
• If it is still valid, file in the sixty days before expiry. See the licence renewal checklist.
• If it has expired, stop selling flower and prepare a new application that meets the eligibility list.

Section 3 of the report, free to read, sets out the licence term and the renewal test.

Four situations, four answers

• The licence is valid and the window has not opened: prepare now and file as soon as the sixty-day window opens.
• You filed in time and are waiting for a decision: keep proof of filing, keep the shop compliant and expect an inspection. You may keep trading until the licensor decides, on the reading of the published texts, though the point is not settled. Estimated
• The licence has expired without a filing: stop selling flower and prepare a new application under the current rules.
• The licence was revoked: no licence under the Act can be applied for until two years from the revocation, and after that the licensor may decide either way. Verified

Building a new application

• The credential: a medical facility licence, a herbal product or drug licence, an extract licence, a folk healer certificate or a supplying cultivation site.
• The premises: held by ownership or possessory right, away from prohibited places, with separate storage and an odour and smoke removal system.
• The staff: a DTAM-trained worker on duty.
• The company: registration, shareholding and directors in order, with no nominee arrangements.
• The history: be ready to explain any past breach and what has changed.

See company registration before a licence application and premises rules.

Alternatives to reapplying

• Partner with a qualifying business, such as a licensed clinic, so the activity sits under its credential. Take advice on how the arrangement is structured.
• Sell the business assets that still have value, such as the lease or fit-out, to a buyer who can qualify.
• Close properly, dealing with stock lawfully and closing the company if it is no longer needed. See closing a cannabis business properly.

The risk around 31 December

Licences issued in 2024 all expire on the same day. Applications and inspections will bunch up around it, and the Prime Minister directed on 22 October 2026 that renewals follow inspection. A shop that files early and is ready for a visit is in a far better position than one that files at the last minute. See the licence renewal checklist.

What to tell the people around the business

• Staff: what they can and cannot sell from the expiry date, and what happens to their jobs while a new application is prepared.
• Landlord: whether the lease continues, and whether a new application needs a fresh consent.
• Suppliers: stop flower deliveries that the shop cannot lawfully sell, and settle what is owed.
• Customers: a short, honest notice. Do not promise a reopening date you cannot control.

What happens to the stock

Flower held when a licence has ended is the most sensitive part of an expiry. It cannot be sold through the shop without a licence. Ask DTAM or a Thai lawyer how the stock should be handled before you move, sell or destroy any of it, and keep a written record of whatever is done. Estimated

Questions to answer before you decide

• Can the business meet the eligibility list today, or only after a partnership or a new credential?
• How long can the business carry rent and staff costs without flower sales?
• Would a buyer who already qualifies pay more for the lease and fit-out than the business could earn by reapplying?
• How would the draft Cannabis Control Act, if passed, change the answer?

There is no single right choice. The right one depends on the credential, the premises and the cash the business has. A short review of those three before you act is cheaper than a refused application. See what a compliance audit checks.

A realistic order of work for a new application

1. Confirm the credential the application will rely on, and obtain it first if the business does not hold it.
2. Check the premises against the location and storage rules, and fix what is missing.
3. Put the company records in order: shareholding, directors and registered objects.
4. Confirm a DTAM-trained worker and set up the record-keeping routine before opening.
5. File the application with a short explanation of any past breach and what changed.

Each step depends on the one before it. Filing before the credential is in place only produces a refusal, and a refusal is one more thing the next application will have to explain. Estimated

Time matters in both directions. Moving too fast produces a weak application; waiting too long uses up the cash that carries the business while it cannot sell flower. Set a decision date and work to it.

Whatever you decide, write it down with the reasons and the date. If you reapply later, a clear record of what happened and what you changed is part of a credible application, and it costs nothing to keep.

Sources

• Section 3 of the 2026 report, The rules in force (free to read)
• Thairath, DTAM guideline on administrative orders for cannabis shops, 22 June 2026
• The Star (Bernama), Thailand to tighten cannabis controls and propose tougher penalties, 22 October 2026
• Nation Thailand, Thai cabinet endorses draft cannabis control bill for medical use, 22 September 2026

This article is market intelligence, not legal, tax or immigration advice. Rules change by notification; check the current text with the relevant authority or Thai counsel before you act.