Licence renewal checklist for 31 December 2026

Every Thai cannabis shop licence issued in 2024 expires on 31 December 2026. Renewal is no longer a form you send in. Since 30 April 2026 it is a test, and a shop that fails it does not reopen in January. This checklist sets out what the rules in force ask for, in the order a renewal is judged.

It covers the rules only. How many shops are likely to pass, and what that means for the market, is in the report.

Know your expiry date and the filing window

Section 46 of the Thai Traditional Medicine Wisdom Act B.E. 2542 (1999), the Act, runs a licence to 31 December of the third year from its year of issue, counting the issue year as year one. A licence issued in 2024 expires on 31 December 2026, and one issued in 2025 on 31 December 2027. Verified Every licence in force reaches its statutory expiry by 31 December 2028, and 37.5% of licences in force face renewal on 31 December 2026. Verified Confirm with the licensor how the term of a renewed licence is counted.

The renewal must be filed in the sixty days before expiry (clause 11 of the regulation as amended). A shop that has filed in time may keep trading until the licensor decides, on the reading of the published texts, though that point is not settled. Estimated See section 49 and trading while a renewal is pending.

A shop whose licence has already expired cannot renew. It must apply for a new licence, and the authority can refuse it. Expiry is not revocation, so the two year bar in section 54 applies only after a revocation. Verified

Checklist: confirm the issue year on your licence, put the opening of the sixty day window in the diary, and file early in it rather than on the last day.

Check that you hold a qualifying route

Ministerial Regulation No. 2 B.E. 2569 (2026) was published in the Royal Gazette on 30 April 2026 and has been in force since that day. Verified A flower licence, new or renewed, is open only to an applicant that holds one of six routes:

• a medical facility licence
• a licence to manufacture or sell herbal products
• a licence to manufacture or sell drugs
• a licence to manufacture Category 5 narcotics limited to cannabis or hemp extract
• a folk healer certificate
• a cultivation site used to supply licensees

A standalone shop with none of these can no longer obtain or renew a flower licence. Article 8 keeps licences issued earlier valid until they expire, and the new criteria apply when they come up for renewal. Article 9 brings applications pending on 30 April 2026 under the amended rules. Verified Start here, because an underlying licence takes time to obtain.

Premises, storage, staff and odour

The premises must be held by ownership or a possessory right, such as a lease, with the owner's written consent where you are not the owner. Flower must be stored separately and off the floor.

At least one DTAM trained worker must be on duty during opening hours. That worker does not have to be a prescriber, so make sure the rota covers every hour.

Every flower licensee also needs an effective odour and smoke removal system. Allowing smoking on the premises is grounds for revocation. See can a dispensary allow smoking on site.

Your suspension record

This is the check most owners miss. If the licence has been suspended for breaching a controlled herb notification, the authority "shall consider not renewing" (clause 11). That is a discretion, not an automatic refusal, but it puts the decision in the licensor's hands. Verified

The penalty guideline announced on 22 June 2026 makes a missing or incomplete monthly report a 30 day suspension. Estimated So a single missed form this year can become a reason to refuse renewal in December. See PT.27 and PT.28 explained.

Expect an inspection

On 22 October 2026 the Prime Minister, after chairing the Narcotics Control Board, said licences would be renewed only after inspection, and that Narcotics Code amendments would raise penalties. Verified No new rule had been published by the time this was checked, but plan for an officer to compare the shop against everything above: the licence, the reports, the prescriptions, the source of the flower and the trained worker.

What the new law changes, and what it does not

The Cabinet approved a draft Cannabis Control Act in principle on 22 September 2026, and the draft is with the Council of State for review. Estimated The Public Health Minister has said, most recently on 22 to 23 September 2026, that once the bill takes effect a licence would trade to its own expiry and then need to convert to a medical facility with a resident doctor to renew. Those are statements, not clauses of any law in force.

Every renewal due on 31 December 2026 is judged under the rules already in force, so prepare for those first. See how the Cannabis Control Act becomes law.

The short version

• File in the sixty days before 31 December. Not after.
• Secure a qualifying route now.
• Clear any gap in your monthly reports before you apply.
• Be ready for an inspection before the decision.

Section 3 of the report, free to read, sets out the full renewal test with its sources. If you want someone to check your shop against it before you file, start with a call.

A working timeline to 31 December

The sixty day window for a licence ending on 31 December 2026 opens in early November.

• Before the window opens: settle which route you rely on and gather the lease, the trained worker's certificate, supplier papers and the last year of monthly reports.
• Early November: file as soon as the window opens and keep proof of the filing date. Since 10 October 2026 applications to sell, process or export flower use the prescribed DTAM form, so confirm with DTAM which form your renewal needs. Verified
• 31 December: the licence expires. A shop that did not file must stop selling flower.

If you cannot meet the eligibility list

The options are to bring the shop under a qualifying route, for example by partnering with a licensed clinic or a supplying farm, to sell the company while the licence is still valid, or to close in an orderly way. Take advice early. See selling a licensed cannabis company and closing a cannabis business properly.

Sources

• Section 3 of the 2026 report, The rules in force (free to read)
• Thai Traditional Medicine Wisdom Act B.E. 2542 (1999), English translation, sections 46, 49 and 54
• Ministerial Regulation on Licensing of Research, Export, Sale or Processing of Controlled Herbs for Commerce, second issue, B.E. 2569, Thai text, Royal Gazette, 30 April 2026
• Thairath, DTAM issues administrative orders increasing penalties for cannabis shops, 22 June 2026
• Nation Thailand, Thai cabinet endorses draft cannabis control bill for medical use, 22 September 2026
• The Star (Bernama), Thailand to tighten cannabis controls and propose tougher penalties, 22 October 2026

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