Thailand’s new cannabis regulations, approved in December 2025, represent the most substantial shift in national cannabis policy since decriminalization in June 2022. However, these rules do not replace all earlier ministerial directives or create a unified cannabis law. Thailand now operates under a hybrid regulatory framework that combines a structured medical-use system with fragmented rules issued between 2022 and 2024. Understanding this dual structure is essential for operators preparing for the 2026 re-licensing cycle.
1. Background (2022–2024)
When cannabis was removed from the narcotics list in 2022, no Cannabis Act, licensing system, or central governing authority was introduced. The draft Act stalled in parliament, producing a regulatory vacuum filled by ministerial directives, controlled-herb notifications, temporary circulars, local zoning orders, and consumer-protection rules.
Issuing authorities
- MOPH — Public health rules, public smoking, retail restrictions
- DTAM — Controlled-herb notifications, seller registration, supply-chain documentation
- Ministry of Interior / Provincial Governors — Temporary circulars, operating hours, local bans
- Local Authorities — Zoning, distance-from-school rules
- Consumer Protection Board — Advertising and promotion restrictions
This fragmented approach resulted in inconsistent enforcement, unclear sourcing rules, no national traceability, no consumption-room rules, and contradictory local interpretations.
2. The 2025 Rules: Shift to a Medical-Use System
The 2025 framework shifts cannabis into a formal medical-clinic system with:
- Prescription-only sales
- On-site medical personnel
- Mandatory traceability reporting to DTAM/MOPH
- Controlled, approved formulations only
- Clinic-grade facilities and records
This ends the consumer-retail model that existed from 2022–2024.
3. The 2025 Rules Do Not Replace All Previous Regulations
Several earlier directives continue to apply:
- Controlled-herb notifications (DTAM)
- Sourcing & supply-chain documentation rules
- Advertising bans
- Public-smoking prohibitions
- FDA packaging and product standards
- Local zoning & operating-hour rules
Operators must comply with both the 2025 medical framework and all unrepealed directives issued from 2022–2024.
4. Re-Licensing, Renewal & Ownership Transfer
Existing licences remain temporarily valid, but any renewal, ownership change, or relocation triggers a full reassessment under 2025 clinic rules.
- Retail-style shops may not qualify as clinics
- On-site medical staff required
- Full clinic infrastructure required
- POS system must support medical traceability
- Sourcing must be fully GACP-compliant
This creates a “soft grandfathering” regime: continue operating for now, but renewal becomes the compliance bottleneck.
5. GACP Traceability & Mandatory POS Integration
Clinics must implement full-chain traceability, including:
- cultivation licence & batch number
- processing & harvest records
- transport records
- prescription number & prescriber ID
- patient ID, dosage & sale date
Sales cannot be completed unless all required documentation is present.
6. On-Site Consumption Rooms
2022–2024: On-site consumption was illegal because public-smoking rules covered commercial premises.
2025 onwards: Consumption rooms are permitted only inside licensed medical clinics and must meet strict criteria:
- patients only (prescription required)
- consumption logged in treatment notes
- supervision by medical staff
- isolated, ventilated, non-visible rooms
- no recreational or walk-in use
7. Remaining Gaps
Thailand still lacks a single cannabis law, unified licensing authority, enforcement framework, harmonised definitions, and a complete penalty structure. These gaps remain until the Cannabis & Hemp Act passes parliament.
Conclusion for Clients
- Existing licences remain valid, but renewal requires meeting full medical-clinic standards.
- GACP/POS traceability is mandatory.
- On-site consumption now has a lawful pathway under clinical controls.
- Operators must comply with both 2025 rules and remaining 2022–2024 directives.
- A unified cannabis law will only exist once the Cannabis & Hemp Act is enacted.
