Running a Cannabis Dispensary in Thailand Without Losing Your Licence: Inspections, Staff Cover, Renewal, Online Rules and the Adverse-Event Log (Part 2 of 2)

Thai cannabis dispensaries now face surprise inspections every few months. Most licence problems come from three things: no trained person on duty, mismatched addresses and incomplete records. This guide covers six topics: how inspections run, how to plan staff cover, how to renew safely, what compliance costs, what you may post online, and how to keep a complaint and adverse-event log.

Since April 2026, a licence to sell cannabis flower in Thailand requires four things. You need a qualifying licence (a hospital, pharmacy, herbal-product or similar licence). A trained person must be on duty during all opening hours. Every licence must show the same address, and stock records must be up to date. DTAM, the Department of Thai Traditional and Alternative Medicine, runs the cannabis-handling training that staff must complete. Flower may only be sold against a PT 33 (ภ.ท.33) prescription, for at most 30 days. Breaking these rules can lead to suspension or revocation of the licence.

This is Part 2. Part 1: Running a Cannabis Dispensary in Thailand Without Losing Your License

Translator’s note: This guide is general information, not legal advice. For decisions about your own licence, ask a Thai lawyer who works with cannabis licences.


How inspections work

Who inspects, and how often

Inspectors come from three bodies: DTAM, the Food and Drug Administration (FDA, อย.) and provincial public health offices. Since the April 2026 tightening, visits have become much more frequent. Operators in Bangkok and Chiang Mai report visits every 1–3 months in 2026. In 2023–2024 they came about twice a year. These figures are operator reports cited in the original article, not official statistics.

Almost all inspections are unannounced. No rule requires advance notice. Operators visited several times report no pattern in the timing.

What to do: assume an inspector could walk in today. Keep all licence documents in one folder at the counter, so any staff member can hand them over without searching.

What inspectors check, in order

According to the original article, inspectors follow the same order every time. This order comes from operator reports. We could not find it in any published DTAM document.

  1. Licence on display. The current licence must be visible from the entrance without asking staff. If it is not, that alone is a finding.
  2. Qualified person present. The inspector asks to see the DTAM certificate, or the pharmacist’s, physician’s or traditional-practitioner’s licence. If nobody qualified is present, that is a violation.
  3. Storage. Flower must be in a dedicated, labelled, locked cabinet, off the floor and apart from other goods.
  4. PT 27 and PT 28 up to date. The PT 27 (ภ.ท.27) records where your flower came from. The PT 28 (ภ.ท.28) records how it was used or sold. The inspector compares them with a count of the shelf. A difference triggers an investigation for false reporting.
  5. PT 33 records. Every sale needs a matching prescription. The inspector may sample 10–20 entries and compare them with the sales recorded in the PT 28.
  6. Address match. Every document on file must show the same address. The inspector checks it against your business registration certificate (ทะเบียนพาณิชย์) and your qualifying licence.

None of these six can be fixed once the inspector is in the shop.

What to do: run this six-point check yourself every week, in the same order. Any problem you find yourself can still be put right before an inspector finds it.

What happens after a finding

When an inspector finds a violation, they issue a written notice (หนังสือแจ้ง). The notice states:

  • which provision you broke
  • the suspension period (30 or 90 days), or a referral for revocation
  • the date by which you must submit a remediation report, which explains how you have fixed the problem

Translator’s note: Section 52 of the Thai Traditional Medicine Protection Act B.E. 2542 (1999) allows a suspension of up to 90 days per order.

During a suspension, you may not sell cannabis. Equipment and other non-cannabis stock can still be sold if the business holds a separate licence for that activity. This matters for growshops that also hold a registration to sell cannabis accessories.

Translator’s note: Section 78 of the 1999 Act covers continuing the business while suspended (Section 52, paragraph 2). The penalty is up to 1 year in prison, a fine of up to 20,000 baht, or both. On the day a suspension starts, lock the cannabis cabinet and record the stock count. The record shows that no cannabis was sold during the suspension.

If you face revocation, submit your documents and explanation in writing, with a lawyer’s help. The June 2026 DTAM guideline says that repeating the same violation after a suspension leads to revocation, so there is little room for discretion.

Translator’s note: under Section 70 of the 1999 Act, you can appeal an order within 30 days of being notified. The appeal goes to the Committee for the Protection and Promotion of Thai Traditional Medicine Knowledge. The appeal does not stop the order, and under Section 71 the Committee’s decision is final. Section 54 deals with revocation. After a revocation, you cannot get a licence under the Act again for two years. After that, a new licence is at the licensor’s discretion. The 2016 licensing regulation, Clause 8(1)(e), applies the same two-year ban to the company. It also applies to the company’s directors, managers and other responsible persons. Setting up a new company with the same people does not avoid the ban.

What to do: when you receive a notice, write down the date. Your 30-day appeal period starts then. Contact a Thai lawyer that week, and start the remediation report straight away.


Staff planning for compliance

The DTAM certificate and its limits

The DTAM cannabis-handling certificate has limits:

  • The certificate belongs to the person, not the shop, and cannot be transferred.
  • If a certified staff member resigns, another certified person must be hired and on duty before the shop opens again. The regulation gives no grace period.
  • The certificate covers handling, dispensing and counselling procedures. It does not make the holder a pharmacist or give them the right to prescribe.

Planning cover so the shop never opens without a certified person

The risk is highest in small shops where only one person holds the certificate. The original article suggests three steps.

  • Train two or more staff. Send at least two employees through DTAM training. Then illness, leave or a resignation will not force you to close. The training cost is small compared with a 30-day suspension.
  • Write a substitution rule. It should say that whenever the main certified person is absent, the second must come in, or the shop does not open. Keep proof that this written rule exists. Suppose a violation happens anyway. A written procedure that one person failed to follow suggests an individual mistake. It does not suggest that the whole shop ignores the rules.
  • Keep certificate copies on site. Keep certified copies of all staff certificates in a folder ready for the inspector. Do not rely on an inspector accepting a photo on a phone.

What to do: this month, name a backup certificate holder for every opening day, and write both names on the staff roster.


Licence renewal: the riskiest time

Under the post-2026 rules, renewal is not a formality. The authority checks your shop again against today’s criteria. Shops first licensed under the looser 2022–2024 rules face the highest risk at their first renewal. They must meet the current four criteria, not the ones that applied when they first got their licence.

Renewal checklist

60 days before expiry:

  • Confirm your qualifying licence is valid. This means a hospital, herbal-product, drug, extraction, folk-healer or cultivation licence. Make sure it does not expire before, or soon after, the cannabis licence renewal.
  • Check that the qualifying licence shows exactly the same address as your cannabis licence.
  • If the addresses differ, start the address amendment with the issuing authority now. Do not wait for the renewal date.

30 days before expiry:

  • Submit the renewal application with all supporting documents.
  • Include the current qualifying licence and proof that you own the building. If you rent, include the lease and the owner’s written consent. Also include a photo of the dedicated storage and the DTAM certificates of all qualifying staff.
  • Keep a complete copy of the package together with the submission receipt.

After renewal:

  • Display the new licence immediately.
  • Update the copy at the entrance, the headers of your PT 27 and PT 28 records and your standard operating procedures (the written step-by-step instructions for staff).
  • If the licence number changes, update it on any public material that shows it.

Why renewals are refused

In 2026, the most common documented reason for refusal is an address mismatch between the cannabis licence and the qualifying licence. The second is having no qualifying licence at all. Shops that first applied in 2022 with only a general business registration have nothing to present at renewal.

What to do: today, put two reminders in your calendar, at 60 days and at 30 days before your licence expires.


What compliance costs

A compliant dispensary under the 2026 rules has costs that did not exist in 2022. We could not find a reliable source for cost figures, so the list below gives cost items only. Get real quotes for each one.

Cost item Notes
DTAM training (first time) One-time, for each staff member trained
Keeping the qualifying licence Depends on the licence type
Backup certified staff Cost of a part-time certified backup, weighed against the risk of closure
Record-keeping Software or a manual system, plus staff time
Legal review at renewal Once per renewal cycle, if you use an adviser

These are real operating costs. Shops that left them out of their 2026 budget are the most likely to cut corners. They save on record-keeping and staff cover, which are the two most common inspection findings.

What to do: add each of these lines to your budget for the next 12 months. Use real quotes, for example the actual DTAM training fee and your adviser’s fee.


Online sales and social media

The Notification of the Ministry of Public Health B.E. 2568 clearly prohibits selling cannabis flower online. The ban covers every platform:

  • ordering flows in a LINE Official Account (LINE OA, a business account on the LINE chat app)
  • Facebook Marketplace listings
  • Instagram shop links
  • Lazada or Shopee product pages
  • any LINE group where a price is given and payment is requested

The legal line is not where the payment happens. It is where the offer to sell is made.

Two examples show how this works:

  • A LINE OA chatbot that says “reply ‘1’ to order 10 g” is an online offer to sell, even if the customer collects in the shop.
  • A Facebook post saying “DM for price”, followed by a price sent in a private message, works the same way.

DTAM inspectors can see public social media. They review it when they investigate complaints.

Permitted: educational content, location and opening hours, product photos without prices, and general descriptions of strain characteristics for information. These limits closely follow the rules for prescription medicines in Thailand.

Triggers immediate scrutiny:

  • price lists on any public or semi-public channel
  • “promotions” or discount codes
  • the words “buy”, “order”, “delivery” or “THC%” in captions or posts
  • paid advertising for cannabis products on Meta, Google or TikTok

All of these are also prohibited under the Notification’s clause on advertising.

Some businesses run a dispensary and a grow-supply business side by side. If yours does, keep two completely separate LINE OA accounts. Use one for agricultural supplies, where the advertising rules are different. Use the other only for patient support. If you mix the two audiences, you create evidence that you market cannabis to recreational users.

Translator’s note: the same law applies on this forum. Flower may not be advertised or offered for sale here, including in the Marketplace sections.

What to do: this week, go through your LINE OA, Facebook, Instagram and online shop pages. Remove prices, order buttons, chatbots that take orders, and the words “buy”, “order”, “delivery” and “THC%”.


The complaint and adverse-event log

An adverse event is an unwanted reaction after using a product. The original article says DTAM’s rules require dispensaries that fill PT 33 prescriptions to log every complaint and adverse reaction a customer reports, and to show the log at inspection. We could not find this requirement in the published rules. A log is still good practice.

A dated paper log is enough. For each entry, record the customer’s presenting condition, the product dispensed and the reported reaction. Leave out the customer’s name, for privacy.

An empty log proves little. Suppose you have filled PT 33 prescriptions for three months and the log has no entries. That does not show that your products caused no problems.

Setting this up takes less effort than most operators expect. Keep a bound notebook at the counter and write one line per customer contact:

  • date
  • product name
  • lot number, if you can trace it
  • the complaint, or “no adverse reaction noted”

Short entries are fine. If you keep the log consistently, it also shows due diligence (that you took reasonable care) if someone later files a complaint against your licence.

Serious adverse events. Examples are severe anxiety, chest pain and loss of consciousness. The original article says these must be reported to DTAM within 72 hours. We could not confirm this rule or its legal basis. Ask DTAM or your provincial public health office how to report a serious reaction, and keep a copy of what you send.

Translator’s note: if a customer has chest pain or loses consciousness in the shop, call 1669, Thailand’s emergency medical number, before anything else. For milder reactions, see the forum guide on THC over-intoxication.

What to do: start the notebook today, and write one line for every sale.


Keeping up with rule changes

Translator’s note: the draft Cannabis Control Act is not law yet. The Cabinet approved the draft on 22 September 2026 and sent it to the House of Representatives. Until it passes, the rules in this guide stay in force. If it becomes law, the requirements may change. Its status is tracked in the forum topic on the draft Cannabis Control Act.

What to do: before each renewal, check the current status of the draft Act and of the B.E. 2569 regulations. If you have questions about inspections, renewal or the log, post them in the replies below this topic.

References

  1. Department of Thai Traditional and Alternative Medicine. (2026, 22 June). แนวทางการออกคำสั่งทางปกครองในการเพิ่มโทษพักใช้และเพิกถอนใบอนุญาต [Guideline on administrative orders increasing licence suspension and revocation penalties]. Announced by the Ministry of Public Health: https://pr.moph.go.th/online/index/news/343199
  2. Ministry of Public Health Thailand. (2025). Notification of the Ministry of Public Health Re: Controlled Herbs (Cannabis), B.E. 2568. Royal Gazette, published 25 June 2025, in force 26 June 2025. https://www.dtam.moph.go.th/sub-law/42864/
  3. Ministry of Public Health Thailand. (2026). Ministerial Regulation on Permission to Study, Research or Export Controlled Herbs, or to Sell or Process Controlled Herbs for Commercial Purposes (No. 2) B.E. 2569 (2026) (unofficial English title). Royal Gazette, in force 30 April 2026. https://ratchakitcha.soc.go.th/documents/114061.pdf
  4. Thai Traditional Medicine Protection Act B.E. 2542 (1999), Sections 52, 54, 70, 71 and 78 (cited in translator’s notes).
  5. Ministerial Regulation on licensing for research, export, sale and processing of controlled herbs, B.E. 2559 (2016). Royal Gazette, vol. 133, part 103 Kor, 9 December 2016, Clause 8(1)(e) (cited in translator’s notes).