PT.27 and PT.28 explained: the records a licensed shop must keep

Most licensed cannabis shops in Thailand worry about the prescription. The form that now decides more renewals is the monthly report. Since June 2026 a missing PT.27 or PT.28 is a suspension, and since April 2026 a suspension can cost the licence at renewal.

Where the forms come from

The PT forms are set by DTAM, the Department of Thai Traditional and Alternative Medicine, under the Thai Traditional Medicine Wisdom Act B.E. 2542 (1999), the law that licenses cannabis flower as a controlled herb. DTAM's forms notification for the PT series was gazetted on 18 January 2023. Estimated

There are three forms most shops deal with:

• PT.27, the record and report of the controlled herb the business takes in: what it received, from whom and in what quantity.
• PT.28, the record and report of what the business does with that stock, including what leaves it and to whom.
• PT.33, the prescription. It is issued by a qualified practitioner, not by the shop, and every flower sale needs one since 26 June 2025. See PT.33 explained.

Guides published by firms and advisers describe the exact fields differently, and some mention a further form for sales. Use the current DTAM version of each form, not a template copied from someone else, and check it with your provincial public health office if in doubt.

Two duties, not one

The penalty guideline announced on 22 June 2026 names both duties: preparing the reports and keeping them at the premises, and submitting them to the registrar. Estimated A shop that fills in a notebook but never files has still breached the rule. So has a shop that files but cannot show the records when an officer visits.

What a breach costs

The same guideline grades breaches of the 2025 controlled-herb notification:

• Not preparing, not completing or not filing PT.27 or PT.28: a 30-day suspension.
• A false PT.27 or PT.28: revocation of the licence.

A revoked licensee cannot apply for any licence under the Act for two years. Verified And under Ministerial Regulation No. 2, in force since 30 April 2026, a suspension on the record lets the authority consider not renewing. A missed form is now a renewal question, not a 30-day inconvenience. See the licence renewal checklist.

How to keep the records clean

• Match stock in to source documents. Every delivery should tie to a certified source: a GACP-certified farm or a laboratory certificate of analysis for that harvest. A receipt alone is not enough.
• Match stock out to prescriptions. Every sale should tie to a PT.33 kept at the shop. A sale with no prescription is a separate breach, a 90-day suspension under the guideline.
• Reconcile monthly. Stock at the start, plus what came in, minus what went out, should equal stock at the end. A gap you cannot explain is the first thing an inspector will ask about.
• File on a fixed day. Pick a day early in each month, file, and keep proof of filing.
• Keep everything at the premises. Paper or digital, the records must be available to an officer on site.
• Never correct a report by rewriting it. A false report is revocation. Correct errors openly and keep the original.

Why this matters before December

Licences issued in 2024 expire on 31 December 2026, and the Prime Minister directed on 22 October 2026 that licences be renewed only after inspection. An inspection will look at the reports first, because they are the easiest thing for the authority to check against its own records.

The full renewal test, with its sources, is in Section 3 of the report, free to read. To have your records checked before you file, book a call.

A monthly routine that works

1. Every delivery: record what arrived, from whom and how much, and file the supplier's certificate with the invoice.
2. Every sale: keep the PT.33 evidence, and record what was sold and to whom.
3. Month end: count the stock and reconcile it with what came in and what went out.
4. Early in the next month: complete and file the reports, and keep proof of filing.
5. Same day: store the filed reports with the month's supporting documents at the premises.

The errors inspectors find most easily

• A month with no report filed.
• Stock on the shelf that does not appear in what was received.
• Sales recorded with no matching prescription.
• Supplier records with no certificate for the batch.
• Reports rewritten after the fact, which turns a gap into a false report.

Paper or digital

Either can work, provided the records are complete, available at the premises and match what was filed. A digital system makes reconciliation faster and leaves an audit trail of changes. Whatever you use, keep the original of anything you file and correct mistakes openly rather than overwriting them.

Operators with more than one shop

Each licensed shop keeps and files its own records. Moving stock between sites needs to be recorded at both ends, and each site's reports must stand on their own. Shared head-office records do not replace what each site must keep on its premises. Estimated

Who should own the records

Give one person, ideally the DTAM-trained worker or the manager, clear responsibility for the reports, with a named deputy for holidays. Most missed reports happen when everyone assumes someone else filed them. See the DTAM-trained worker rule.

What a complete entry looks like

Whatever the format, each entry should let an inspector follow the cannabis from the supplier to the customer without asking anyone. For stock received, that means the date, the supplier, the product, the quantity and the certificate that goes with the batch. For stock sold, it means the date, the product, the quantity and the prescription the sale relied on. For the month, it means the opening stock, what came in, what went out and the closing stock, and an explanation for any difference. Estimated

Records when the business changes hands or closes

Records do not stop mattering when a shop is sold or closed. A buyer will ask for them during due diligence, and an authority may ask about past months after the shop has changed. Keep the full set, including filed reports and their proof of filing, in a safe place, and agree in any sale contract who holds them and who can access them. See closing a cannabis business properly.

If you find an error in a report already filed, correct it openly with a dated note explaining the change, and keep both versions. A correction made in the open shows control; a quiet rewrite looks like concealment.

Finally, test the routine. Once a quarter, pick a few sales and a few deliveries at random and trace each one through the records. If someone outside the shop could not follow them, an inspector will not either.

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
• Juslaws, Amendment to cannabis law on 25 June 2025
• 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.