What are the three Thai cannabis licence expiry waves to 2028?

Every cannabis licence in force in Thailand reaches its statutory expiry by 31 December 2028, under section 46 of the Thai Traditional Medicine Wisdom Act B.E. 2542 (1999). Verified Expiry always lands on 31 December, so the calendar has three waves: 31 December 2026, 31 December 2027 and 31 December 2028. 37.5% of licences in force face renewal on the first date. Verified

This article explains why the dates fall where they do, what each wave means for operators and what it means for landlords. How the waves are sized is in the report.

Why the dates fall on 31 December

Cannabis flower is a controlled herb under the Act, called the Act below. Section 46 requires a licence for commercial sale or processing, for export and for research. It also sets the term: a licence runs to 31 December of the third year from its year of issue, counting the year of issue as year one. Verified

The rule is calendar based, not anniversary based. A licence issued in March and one issued in November of the same year end on the same day. That is why the calendar has three fixed dates instead of a spread across the year.

The three waves

Working from the section 46 formula, a licence first issued in 2024 expires on 31 December 2026. One first issued in 2025 expires on 31 December 2027. One first issued in 2026 expires on 31 December 2028.

• First wave: expiry on 31 December 2026.
• Second wave: expiry on 31 December 2027.
• Third wave: expiry on 31 December 2028.

The figure published here is for the first wave only: 37.5% of licences in force face renewal on 31 December 2026. Verified Sizes for the later waves are in the report.

To find your wave, read the year of issue on your licence and apply the formula. If the date printed on the licence and the formula disagree, follow the licence. Confirm with the licensor how the term of a renewed licence is counted.

Why a three date calendar matters

Because expiry falls on one day, licences in the same wave reach the licensor together, and filings arrive together. That is a practical point, not a rule in the law, but it matters to any operator that relies on a quick decision.

The 2025 round shows what a renewal round can do. 5 in 6 licences due to renew in 2025 did not complete renewal. Verified The 2026 wave is the first under the renewal rules in force since 30 April 2026, which makes it a different test. See what the 30 April 2026 rules changed.

The filing window

A renewal must be filed in the sixty days before the licence expires (clause 11 of the regulation as amended). Verified Section 49 lets a licensee that files before expiry carry on until the licensor decides. On the reading of the published texts that holds for a shop that filed in time, though the point is not settled. Estimated See Section 49: can you keep trading while your renewal is pending?

What each wave means for operators

First wave, 31 December 2026. The renewal must be filed in the sixty day window and is judged against the premises, storage, credential, trained worker and odour control conditions. See the licence renewal checklist for 31 December 2026.

Second wave, 31 December 2027. Operators in this wave can watch the 2026 round first. The rules in force, the bill and any guidance on pending renewals should be clearer by then. The longer lead time matters for anything that depends on another authority, such as a qualifying credential.

Third wave, 31 December 2028. This is the last statutory expiry for licences now in force. The Cabinet approved the Cannabis Control bill in principle on 22 September 2026, and the draft is with the Council of State for review. Silk Legal's commentary says public reporting does not indicate that the draft would shorten existing licence terms. Estimated That should be checked against the final text. See how the Cannabis Control Act becomes law.

What the calendar means for landlords

A lease and a licence rarely end on the same day. The practical point is to know which wave the tenant's licence is in and what the lease says if the licence is not renewed.

Under Ministerial Regulation No. 2 B.E. 2569 the applicant must hold the premises by ownership or a possessory right, and a lease satisfies that. An owner who is not the applicant must give written consent at renewal. Verified A tenant that needs a consent letter at renewal will need the landlord. See what landlords should check before leasing to a cannabis shop.

Where to file

DTAM's guide of 1 May 2026 says applications go to DTAM in Bangkok and, elsewhere, to the provincial public health office where the premises are. Verified Confirm the office early.

Common misreadings

• "My licence runs for three full years." It runs to 31 December of the third year from the year of issue, so it is shorter than three years from the issue date.
• "My licence expires on its anniversary." Expiry is a calendar date, not an anniversary.
• "The 2028 date is the only date that matters." The first wave falls on 31 December 2026.
• "Filing a renewal ends the risk." Whether a filing keeps a shop trading is read from the published texts, and the point is not settled. Estimated

If you operate, lease or lend against a licence

1. Find the year of issue and the expiry date on your licence, and name your wave.
2. Diarise the start of the sixty day filing window and prepare the file before it opens.
3. List what the renewal will test: premises, storage, credential, trained worker and odour control. Note which items depend on a separate authority.
4. Landlords: compare each tenant's licence expiry date with the lease term and the consent letter the tenant will need.
5. Review the calendar after every rule change and after each step of the bill.

Section 3 of the report, free to read, sets out the rules in force with their 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
• Guide to establishing a medical cannabis service under the 2026 ministerial regulation (Thai), Division of Medical Cannabis, DTAM, 1 May 2026
• Silk Legal, Thailand's Cabinet Approves a Medical Only Cannabis Control Bill, 5 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.