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Florida compliance hub

Florida dispensary compliance and the hemp ban: what’s changing, and when.

Every date that changes how a Florida dispensary runs in 2026 — the December 11 federal hemp deadline and its November 12 carve-out, two Registry rule changes, OMMU’s permanent rulemaking, the 22 pending licenses — on one page, kept current, with the in-store playbook for each and a printable Q4 checklist.

Updated September 7, 2026. General information for dispensary operators, not legal advice — confirm current requirements with your counsel.

Registry MFA required

Sep 28

Multifactor authentication on every Medical Marijuana Use Registry login — patients renew cards there, staff record dispensations there.

The carve-out date

Nov 12

Cannabinoids the plant can't naturally produce lose federal hemp status. The delay doesn't cover them.

The federal hemp deadline

Dec 11

Total-THC test and the 0.4 mg per-container cap take effect. A Friday, two weeks before Christmas.

The timeline

Thirteen dates, one page.

In the order they arrive. Each row links to the post that covers it in full; the status tells you whether the date is settled, still moving, or already live.

  1. In effect

    MMTC advertising rule 64ER25-6 in full effect

    One exterior sign, marketing displayed only inside the facility, content limited to qualified patients and medical use — the rules every in-store screen has to live inside.

    What you can display in-store

  2. In effect

    State-licensed medical marijuana moved to Schedule III

    The DOJ's April 23 order took effect April 28: marijuana sold under a state medical license is Schedule III, with the 280E relief that follows. The broader rescheduling question is still in the DEA's hands.

    What actually changes day to day

  3. Pending

    ALJ recommended order on the 22 new MMTC licenses

    The recommended order proposed score adjustments for eight applicants; the Department's final order — which starts winners' 180-day clock to request cultivation authorization — is still "any week."

    The opening-day tech checklist

  4. In effect

    Delivery-device rule 64ER25-5: single solid color or clear

    Vape pens, cartridges, and batteries must be a single solid color or clear, with branding limited to the approved trade name and logo, manufacturer, and device name.

    Marketing and display rules

  5. In effect

    Registry blocks card applications without a current certification

    The Medical Marijuana Use Registry now stops an initial or renewal card application unless a current or scheduled physician certification with open orders is on file. Patients find out when the card lapses.

    Why this is silent churn

  6. Pending

    DEA rescheduling record closes

    Final briefs were due August 17 — the DEA's own attorneys urged a move to Schedule III. Chief ALJ Julius's recommended decision has no deadline; most observers expect late 2026.

    The Q4 compliance calendar

  7. Rolling

    OMMU proposes permanent rule 64-4.227 (MMTC advertising and marketing)

    Florida's emergency rules are being converted to permanent ones under Chapter 64-4 — advertising, trade names and logos, packaging, website purchasing — each with its own comment window. The first real chance since 2017 to shape the display rules.

    Rolling rulemaking, explainedFlorida Administrative Register, Chapter 64-4

  8. Done

    H.R. 6500 signed — the federal hemp dates are set

    The House passed the funding bill 370–48 on September 1 and the President signed it September 2. Most federal hemp-THC restrictions now take effect December 11; the non-naturally-producible carve-out stays on November 12.

    The 14-week countdown playbookH.R. 6500

  9. Fixed date

    Registry logins require multifactor authentication

    OMMU's notice: Registry users must use MFA via an authenticator app or email notification. Whether MMTC dispensing accounts are covered is unconfirmed as of September 7 — confirm through your Registry executive user.

    The three-week planOMMU notice

  10. Fixed date

    Square's deadline: hemp and CBD items off seller catalogs

    Square told sellers on August 7 to remove every CBD and hemp item by October 15 — regardless of what Congress does. The payments layer moves before the law does, and displaced customers start shopping around early.

    Why the payments layer moved first

  11. Fixed date

    Cannabinoids the plant can't naturally produce lose federal hemp status

    The delay doesn't cover them. A narrower slice of the gas-station shelf exits on the original date — a smaller, earlier wave of displaced customers and the soft-launch date for a patient-education campaign.

    November 12: the dress rehearsalH.R. 6500, text

  12. Fixed date

    Main federal hemp-THC restrictions take effect

    Hemp switches to a total-THC test, and finished products are capped at 0.4 mg combined total THC per container. A Friday, two weeks before Christmas — and the same day government funding expires.

    December 11: the main eventSection 781, Public Law 119-37

  13. Fixed date

    Florida Legislature's 2027 session convenes

    Interim committee weeks begin this fall. The state-level response to the federal hemp change — aligning Florida's hemp statutes, or filling whatever gap Congress leaves — takes shape there first.

    Tallahassee gets its turn

On the sales floor

A merchandising calendar, not just a compliance one.

The displaced hemp customer isn’t your current patient — no card, no consultation, format-literate and strain-illiterate. Three moves, in order.

01

Open the patient-education funnel now.

In medical-only Florida a displaced hemp customer can't buy anything until they're a qualified patient. September's job is eligibility: how the program works, qualifying conditions, how long approval takes — on interior-facing lobby and waiting-area screens.

Read more →
02

Build the translation layer in October.

This customer knows beverages, gummies, and vapes — not indica vs. sativa. Category-first menus and a "new to the medical program?" rotation map familiar formats to your shelf, framed as patient education and cleared through your normal compliance review.

Read more →
03

Make the switch-on day a dashboard edit.

November 12 is the rehearsal, December 11 the main event. When a date moves — and half this calendar has moved once already — a POS-synced screen fleet re-points in minutes; printed signage is a reprint per store.

Read more →

The standing slides

Four slots that earn their place all quarter.

Every one of them lives inside Florida’s in-store display rules: interior-facing, addressed to qualified patients and medical use, cleared through your normal compliance review.

"Check your certification date before you renew"

The July 27 rule fails silently at the patient's kitchen table. One slot, a QR to the Registry, and it protects repeat revenue every day of the quarter.

"The Registry adds MFA September 28"

Run it now with the OMMU link; swap to "trouble getting in? OMMU's guides can help" after the 28th. Interior-facing, through your normal compliance review.

"The rules around cannabis are changing this fall — ask us"

Accurate on every date in every scenario, and it makes your staff the people with answers. Keep it in rotation through January.

The first-visit patient offer

Held for the promo slots on December 11. Addressed to qualified patients and medical use — never recreational substitution — and never visible from outside the facility.

The Q4 2026 checklist

What to do, by month.

The same list as the PDF. Print it, pin it in the back office, and cross the rows off as the dates fire.

September.

  • Launch the patient-education loop on interior-facing lobby and waiting-area screens: how the medical program works, qualifying conditions, how long approval takes.
  • Put the "check your certification date before you renew" slide in standing rotation with a QR code to the Registry (the July 27 rule).
  • Add the "Registry adds MFA September 28" slide with the OMMU link; confirm through your Registry executive user whether MMTC accounts are covered.
  • Brief budtenders on the displaced-hemp customer: knows beverages, gummies, and vapes; doesn't know indica from sativa; has never heard of an MMTC.
  • Write the answer to "what does the hemp ban mean for me?" before anyone asks it — one slide, cleared by compliance.
  • Check the Florida Administrative Register (Chapter 64-4) for OMMU's proposed permanent rules and note each comment deadline.

October.

  • Swap the MFA slide to "trouble getting in? OMMU's guides can help" after September 28.
  • Build the translation layer: category-first menu screens and a "new to the medical program?" rotation that maps familiar formats to your shelf — patient-education framing, compliance-reviewed.
  • Pressure-test that every menu updates from the POS automatically; a sold-out SKU on a static sign in December costs you a first-timer.
  • Note October 15: Square sellers must have hemp and CBD items off their catalogs. Expect displaced customers to start shopping around before any legal deadline.
  • Reserve the promo slots you'll use for the first-visit patient offer in December, and draft the slide now.
  • Watch for the Department's final order on the 22 MMTC licenses — a news-cycle day; have the "what this means here" slide ready.

November.

  • November 12: soft-launch the welcome campaign on the narrower carve-out date. Watch which screens and offers move first-visit conversions.
  • Fix what's clumsy while the stakes are small: menu categories, the education loop, the budtender script.
  • Confirm every location's screens can be re-pointed from one dashboard the same day; time a dry run.
  • Keep the "rules are changing this fall — ask us" slide in rotation; update it if Congress moves anything.
  • Re-check Registry MFA scope and card-processing times before the holiday push.

December.

  • December 11: full campaign on every screen — first-visit patient offer in the promo slots, staff briefed for a floor with more newcomers than regulars.
  • December 12 and after: switch the message from "is this happening?" to "the rules on hemp-THC products changed December 11 — ask us what it means for you." Keep it up through January.
  • Don't claim the alternatives are gone on day one; the statute has no express sell-through period and enforcement will be uneven. Say you're the state-licensed, tested channel for qualified patients.
  • Plan Q1: committee weeks are under way and the Legislature convenes March 2, 2027 — the state response to the federal change starts there.

FAQ

The questions customers are about to ask.

GreenScreens is based in Tampa. We build POS-synced digital menu boards for dispensaries and we write about Florida because we operate here. If your screens can’t pivot a menu and a campaign across every location on a fixed date, that’s the part we do — see a live store.

When does the federal hemp ban take effect?

Most of the new federal restrictions on hemp-derived cannabinoid products take effect December 11, 2026, under H.R. 6500, signed September 2, 2026. Products containing cannabinoids that the cannabis plant cannot naturally produce lose federal hemp status a month earlier, on November 12, 2026 — the delay does not cover them.

Does the law ban hemp?

No. It changes the federal definition of hemp: THC is measured as total THC (capturing THCA), and finished consumer products are capped at 0.4 mg combined total THC per container. Fiber, grain, and products that meet the revised definition stay outside the Controlled Substances Act. "Hemp ban" is industry shorthand for the effect on intoxicating consumable products — delta-8, THCA flower, most hemp-THC beverages.

What is the difference between November 12 and December 11?

November 12 is the original effective date and still applies to products containing cannabinoids not capable of being naturally produced by a Cannabis sativa L. plant. December 11 is the delayed date for everything else — including cannabinoids the plant can produce but that are synthesized outside it, which covers much of the delta-8 market.

Can a Florida dispensary market to former hemp customers?

Only inside Florida's MMTC advertising rules. Marketing materials may be displayed inside the dispensing facility and must not be visible from outside; messaging must address qualified patients and medical use, never recreational substitution. A patient-education campaign about how the medical program works is the compliant shape of this; a "delta-8 is banned, come here instead" campaign is not.

What does a new customer need before they can buy from a Florida dispensary?

A qualifying medical condition, a certification from a qualified physician, entry in the Medical Marijuana Use Registry, and an approved ID card. OMMU's current estimate is about five business days to process a complete application plus five for card printing, and approved applicants can shop with their approval email while the card mails. Add the physician appointment on the front end and a December start is cutting it close to the holidays — which is why the education campaign starts in September.

What changed in the Registry on July 27?

Since July 27, 2026, the Medical Marijuana Use Registry will not let a patient complete an initial or renewal ID card application unless a current or scheduled physician certification with open orders is on file. The failure happens early and silently, so the patient usually discovers it when the card has already lapsed.

What is the September 28 Registry change?

Beginning September 28, 2026, Registry users must use multifactor authentication — via an authenticator application or email notification — to access the Medical Marijuana Use Registry. OMMU's notice says "users" and, as of September 7, has not said whether MMTC dispensing accounts are included or published setup instructions. Confirm scope through your Registry executive user before the 28th.

How do I keep in-store screens compliant when the rules keep changing?

Treat every date as a field, not a fact: decide the slide or menu change before the date arrives, keep one honest "the rules are changing — ask us" slide in rotation, and run campaigns on screens that update from one dashboard across every location. GreenScreens is a Tampa-based dispensary signage company; our menus sync from your POS and our screens re-point fleet-wide in minutes.

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