The Blank Prescription Problem: What the June 2026 PT 33 Crackdown Changes for Dispensaries

GOOD_BUDS · October 16, 2026, 3:58am

In late June 2026 the Department of Thai Traditional and Alternative Medicine (DTAM) said it had found PT 33 cannabis prescription forms that practitioners had allegedly signed blank and handed to retailers, who filled in the patient and diagnosis details later. DTAM said it would pursue forgery charges under the Criminal Code against the individuals, retailers, healthcare facilities and medical professionals involved. It also said it would refer practitioners to their professional councils and move towards digital verification of prescriptions. Compliant dispensaries should pay attention too, because this changes what “we have the prescription on file” is worth.

1. What was found and what DTAM said

Sources: Thai press (Hfocus) and Khaosod English, both 27 June 2026. We could not find the original DTAM press release on dtam.moph.go.th.

The practice: practitioners allegedly signed blank PT 33 forms. Retailers then completed the patient and diagnosis details and, according to reports, used the forms as supporting evidence in their mandatory usage reports on form PT 28.

DTAM’s announced response:

It said it would pursue forgery charges under the Criminal Code, working with police and security agencies
These were aimed at individuals, retailers, healthcare facilities and medical professionals
Practitioners would be referred to their professional councils, which could suspend or revoke their licences
It plans digital verification and electronic prescription databases, reportedly to flag duplicate document numbers and invalid reference codes
Reports can be made through Traffy Fondue

Two features of that response are worth pausing on.

Criminal, not only administrative. Until now, enforcement against cannabis retail has been administrative: suspension, revocation and fines. Forgery charges, if brought, attach to people, not to licences, and a company cannot absorb them the way it absorbs a fine. DTAM did not say which Criminal Code sections would apply. That depends on the facts and is a question for a Thai lawyer.

Liability named in four directions. The announcement names the practitioner who signed, the retailer who filled the form in, the healthcare facility and the individuals involved. In our reading, that leaves a shop little room to present itself as a mere recipient of someone else’s fraud.

2. Why this changes things for dispensaries that did nothing wrong

The old defence is now weaker. Under the Notification of the Ministry of Public Health Re: Controlled Herbs (Cannabis) B.E. 2568, a dispenser must keep every prescription for at least one year and produce it on demand to DTAM or police (Tilleke & Gibbins).

A file of prescriptions used to be the answer to an inspection. After a forgery investigation, a prescription in your file is only as good as its provenance. If a practitioner who supplied your shop is investigated for signing blank forms, every prescription of theirs in your records becomes a question rather than an answer.

You may not be able to tell a blank-signed form from a genuine one. A form signed in advance and completed carefully later looks, on paper, like one completed during the consultation. In our view, the deciding fact is when the signature was applied relative to the patient details, and the document does not show it.

So the risk sits in your practitioner relationships, not in your paperwork. A dispensary with immaculate records and one compromised prescriber is more exposed than one with untidy records and a prescriber who was always physically present.

3. Where this sits in the enforcement picture

DTAM’s 22 June 2026 penalty guideline puts selling without a qualified practitioner’s prescription in the 90-day suspension tier; see topic 1295 and bai246. Under DTAM’s 2026 establishment guide, a previous suspension can count against renewal; see bai209. As of June 2026, press reports counted 1,247 establishments inspected (Khaosod English). On renewals, 8,636 licences expired during 2025 and 1,339 renewal applications were filed (Nation Thailand, figures as of 28 December 2025). That counts applications against expired licences, many belonging to shops that closed. It is not an approval rate.

4. What a blank-signed form leaves empty

The signature, and often the practitioner’s name and licence number, are already on the form. That is why it looks genuine. What is left for someone else to fill in:

date of prescription
patient identity
diagnosed condition
product, daily dose, duration (30 days at most) and total quantity

For who may prescribe, the single-use and 30-day rules, and record-keeping, see topics 1358 and 1291. DTAM publishes the official forms here.

5. What a dispensary should do about it

These are our recommendations, not legal advice. If you have serious exposure, take them to a Thai lawyer.

Know your prescribers individually and verify their licences yourself. The form carries the practitioner’s licence details. Check them against the professional council rather than just copying them. A prescriber you cannot identify and verify is your largest single exposure.

Prefer prescriptions written on site, in front of you. This is the only arrangement that structurally cannot produce a blank-signed form. If your model depends on prescriptions arriving from elsewhere, that dependency is now the thing to redesign. Separately, DTAM’s 2026 establishment guide requires at least one staff member who has completed DTAM-recognised training to be on site whenever the shop is open.

Never complete any field on a form you did not receive complete. Filling in a detail on a signed form, even correctly and even to be helpful, is the conduct DTAM has said it will pursue as forgery.

Record the consultation, not just the prescription. Note the time and which prescriber was present, and keep the diagnostic evidence. A record made at the time of the consultation is something a blank-signed form cannot produce.

Get ready for electronic checks early. A shop whose records reconcile cleanly against a central database has little to fear from one. A shop with transcription errors and gaps will generate flags that look like fraud. Reconcile your records now, while a discrepancy is still an administrative fix.

6. Update, as of October 2026

Prosecutions: we found no public report of a prosecution brought specifically over blank-signed or forged PT 33 forms.
Advance signing: in August 2026 the government publicly warned dentists against signing PT 33 forms in advance without examining patients.
Electronic prescriptions: we found no announcement that an electronic PT 33 system has gone live. DTAM’s 2026 guide still describes paper forms.
The law: the Cannabis Control Act is still a draft. The Cabinet approved it on 22 September 2026 and sent it to the House, and the PT 33 regime could change under it. The two Ministerial Regulations of B.E. 2569 tightened licensing but did not change the PT 33 prescription rules.

7. What we could not verify

The original DTAM press release, in Thai. The hotline number given in English-language reports could not be confirmed against DTAM, so we have left it out.
Which Criminal Code sections would apply.
Any prosecution or outcome under the forgery announcement.
The design or timeline of the electronic prescription database.
Any instrument requiring a prescriber to be on site, as distinct from trained staff.
Any published DTAM figure for PT 33 prescriptions issued.

8. The short version

A prescription in your file no longer proves itself. Its value now depends on the prescriber’s integrity and on your ability to show the consultation happened. The structural fix is a prescriber who is physically present. The documentary fix is a record of each consultation made at the time. The thing to do this month is to reconcile your own records before a central database does it for you.

Has anyone here been asked to produce prescriptions during an inspection? What exactly did the inspector look at: the form, the diagnostic evidence, the prescriber’s licence, or all three? As of June 2026, 39 appeals against suspension or revocation had reportedly been reviewed, so the process is live, yet nothing about what inspectors actually check has been published. One first-hand account would be worth more to licence holders than every summary of the rules.

Related reading: licence suspension and revocation in Thailand; licensing and compliance: permits, audits and penalties.

This article summarises published reporting and DTAM guidance and is not legal advice. We could not read the original DTAM announcement and did not consult Royal Gazette texts directly. Confirm anything here with a qualified Thai lawyer or with DTAM before acting on it.