What the 30 April 2026 licence rules changed for shops

The most important cannabis rule of 2026 was not the draft Cannabis Control Act. It was a ministerial regulation signed on 29 April and in force the next day. Ministerial Regulation No. 2 B.E. 2569 (2026) decided which shops can keep their licence when it next expires. Verified

This article sets out what the regulation does, what a renewal must now pass and what is still open.

What it does, in three parts

The regulation amends the rules for licensing controlled herbs under the Thai Traditional Medicine Wisdom Act B.E. 2542 (1999), called the Act below. For cannabis flower it does three things.

• An eligibility list. A flower licence, new or renewed, is open only to an applicant that holds one of six qualifying routes.
• Licence conditions. Conditions on premises, storage, staffing and odour travel with every flower licence.
• A renewal discretion. After a suspension for breaching a controlled herb notification, the authority "shall consider not renewing" (clause 11 as amended).

The eligibility list

The six routes are 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; or a cultivation site used to supply licensees. Verified

The list is a licence condition. It is not a list of who may prescribe. A shop with no other regulated identity cannot get a new flower licence under these rules, and the same test applies at renewal.

The licence conditions

• Premises. Held by ownership or a possessory right. A lease satisfies this. An owner who is not the applicant gives written consent at renewal.
• Storage. Flower stored separately and off the floor.
• A DTAM trained worker on duty, who need not be a prescriber. See the DTAM trained worker rule.
• Odour and smoke. An effective removal system for every flower licensee. Article 4 of the amending regulation adds this duty (clause 10).

The regulation carries no nationality or shareholding test on the licensee. Foreign ownership is judged separately, under the Foreign Business Act. See can a foreigner own a cannabis business in Thailand.

Who it reaches, and when

The regulation does not reach into licences already issued. One article keeps existing flower licences valid until they expire. Another applies the new criteria in clause 8/1 at renewal, and a third brings applications pending on 30 April 2026 under the amended rules. Verified

Because a licence runs to 31 December of the third year from its year of issue, every licence in force today meets this test by 31 December 2028. Verified See the three licence expiry waves.

The filing window

A renewal must be filed in the sixty days before expiry (clause 11 as amended). Verified

Why it matters more than the bill

The draft Cannabis Control Act is not law. The Cabinet approved it in principle on 22 September 2026, and it is with the Council of State for review. This regulation is already in force, and it sets the renewal test for licences expiring on 31 December 2026, 2027 and 2028.

Conversion to a medical facility with a resident doctor is the Public Health Minister's stated plan for when the bill takes effect, in statements made most recently on 22 to 23 September 2026. It is not a clause of any law in force. Estimated See the licence renewal checklist and how the Cannabis Control Act becomes law.

Five questions to ask about your shop

1. Which of the six routes will the renewal rely on, and is it in the licensee's name?
2. Can you prove the right to the premises with a lease or title, and the owner's consent?
3. Is the flower stored separately and off the floor?
4. Is a DTAM trained worker on duty in every opening hour, with the certificate on file?
5. Has the licence ever been suspended, and if so, what has changed since?

A no to any of the first four is a gap to close before the window opens. A yes to the fifth is a risk to plan around.

What the regulation does not settle

Several points are not answered in the published texts. Indicative

• Whether suspensions before 30 April 2026 count towards the renewal discretion.
• Whether the suspension record follows the licensee, the premises or the people behind them.
• Whether a successful appeal clears a suspension from the record.
• How the term of a renewed licence is counted. Confirm with the licensor.

A shop that filed in time may keep trading until the licensor decides, on the reading of the published texts, though that point is not settled. Estimated Plan for the cautious answer to each until the authority says otherwise.

How it works with the penalty guideline

The regulation supplies the renewal discretion. The guideline announced on 22 June 2026 supplies the suspensions that trigger it. A missing monthly report is a 30 day suspension, and a sale without a prescription is a 90 day suspension. Estimated See suspension vs revocation.

Inspection before renewal

On 22 October 2026 the Prime Minister directed that licences be renewed only after inspection. Verified No new rule was published with it, but the checks above are likely to be tested on site. See what a compliance audit checks.

Common misreadings

• "My licence is valid until it expires, so nothing changes until then." The test applies at the next renewal, and the suspension record built up during the term feeds into it.
• "A trained worker is enough to qualify." The trained worker is a condition of operating. It is not one of the six routes.
• "Renewal is automatic if I file in time." Filing in time keeps the door open. The authority still decides, and it has been directed to inspect first.

If you own, fund or lend to a shop

1. Pull the licence, lease, training certificates and monthly reports into one folder, and check them against the five questions above.
2. Diarise the start of the sixty day filing window, and fix gaps while the licence is valid.
3. If a renewal is refused, read the grounds, check the appeal deadline and take Thai legal advice quickly. See what happens if a licence expires.

Section 3 of the report, free to read, walks through each check with its sources. If you want the licence calendar applied to a business you are looking at, start with a call.

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 and 49
• Ministerial Regulation on Licensing of Controlled Herbs, 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.