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 newly licensed MMTCs — on one page, kept current, with the in-store playbook for each and a printable Q4 checklist.
Updated September 23, 2026. General information for dispensary operators, not legal advice — confirm current requirements with your counsel.
Registry MFA required
Multifactor authentication on every Medical Marijuana Use Registry login — patients renew cards there, staff record dispensations there.
The carve-out date
Cannabinoids the plant can't naturally produce lose federal hemp status. The delay doesn't cover them.
The federal hemp deadline
Total-THC test and the 0.4 mg per-container cap take effect. A Friday, two weeks before Christmas.
The timeline
Seventeen 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.
- 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.
- 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.
- Done
ALJ recommended order on the 22 new MMTC licenses
The recommended order proposed score adjustments for eight applicants. The Department's September 11 Final Order declined to adopt it and licensed the original 22.
- 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.
- 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.
- 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.
- Rolling
OMMU proposes permanent rule 64-4.227 (MMTC advertising and marketing)
The permanent replacement for emergency rule 64ER25-6. As proposed: the same three channels and interior not-visible-from-outside rule, but one exterior sign, six permitted kinds of social-media content, a new content prohibition, and 180 days from its effective date to comply. Part of the Chapter 64-4 conversion of every emergency rule.
- 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.
- Done
Final Order issues the 22 new MMTC licenses
The Department licensed the 22 applicants selected in November 2024 (MMTC-2026-0029 through -0050) and declined the ALJ's proposed rescore; 49 MMTCs are now licensed, 25 hold dispensing authorization. The rules run from this date: $5 million in financial assurance within ten business days, a cultivation-authorization request within 180 calendar days, processing within 270, dispensing within 365 — each request triggering an inspection. Denied applicants have 30 days to seek review.
- Fixed date
Listed comment period ends on proposed marketing rule 64-4.227
Twenty-one days after publication; a hearing follows if one was requested in the window or the Department schedules one. No effective date exists until the rule is adopted; the proposed text gives MMTCs 180 days from that date to discontinue previously approved advertising that no longer complies — so the screen and sightline audits are worth running now.
- Fixed date
Financial assurance due from the 22 new MMTCs
Ten business days after final approval for licensure, each new licensee must have $5 million — a surety bond, an irrevocable letter of credit, or cash — with the Department's Agency Clerk under Rule 64-4.217. The appeal window on the Final Order runs about two weeks longer, to on or about October 11.
- 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.
- Fixed date
Listed comment period ends on proposed licensing rule 64-4.214
Published September 11: the permanent framework for MMTC license applications — batching cycles, five-day application windows, a $146,000 nonrefundable fee, and an August 2026 evaluator manual. It sets the machinery for the next round without opening one; the April 2023 cycle closed with the September 11 Final Order.
What could still change the 22 →FAR notice 31354297 (Vol. 52/177)
- 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.
- 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.
- 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.
- 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.
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.
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 →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 →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.
- Audit every screen loop against Proposed Rule 64-4.227's content list (no whole-flower imagery — photos or illustrations — no unapproved product names, no consumption or risky-activity footage) and every sightline against the not-visible-from-outside rule — the 180-day clock runs from the rule's effective date, not from your next inspection.
- List every exterior sign on the property and flag any that exist only under an emergency-rule paragraph the proposed rule doesn't carry forward (free-standing, hours/URL, instructional); take the list to counsel.
- If you're one of the 22 new licensees: $5 million in financial assurance is due at the Agency Clerk by September 25 (Rule 64-4.217), and the dispensing-authorization request is due within 365 days — plan the retail stack (POS, seed-to-sale, menus, security, network) to be inspection-ready on the day you file it, not after.
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.
- The 22 new MMTC licenses issued September 11 — write the "what this means here" slide now (the program's rules for patients haven't changed; no new store can open before it clears three authorization stages; your store isn't going anywhere), cleared through compliance, so it's ready the day a new licensee announces a location. Watch the First DCA for an appeal through mid-October.
- Watch the FAR for a Notice of Change or adoption of 64-4.227; re-check your social calendar against the proposed six content categories and confirm in writing that your signage and marketing vendors read the third-party clause the way you do.
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.
Did Florida issue the 22 new MMTC licenses?
Yes. On September 11, 2026, the Department of Health entered a Final Order licensing the 22 applicants it selected in November 2024 and declined the administrative law judge's proposed rescore. OMMU's MMTC directory lists them at "Initial Licensure" (MMTC-2026-0029 through -0050). None can open a dispensary until it clears cultivation, processing, and dispensing authorization in that order; Rule 64-4.216 requires the dispensing-authorization request within 365 calendar days of licensure, and each location is then approved individually.
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.
All Florida coverage
Every post in the series.
- Florida's 22 New MMTC Licenses Are Final. What Has to Happen Between September 11 and the First New Dispensary?
- Florida's Proposed Permanent Dispensary Marketing Rule Is Out. What Does It Say About the Screens Inside Your Store?
- Florida's Medical Marijuana Registry Login Changes September 28. How Many of Your Regulars Will Find Out at the Counter?
- The Federal Hemp Deadline Is Now December 11. Your Dispensary Has 14 Weeks — Here's the Countdown Playbook [2026]
- Two Dispensary Brands You've Never Heard of Are Entering Florida's Weekly Numbers. Who's Next? [2026]
- Congress Might Delay the Hemp Ban. Square Isn't Waiting. What the October 15 Shutoff Means for Florida Stores [2026]
- Nov 12, Dec 11, or Neither? Every Date on Your Florida Dispensary's Q4 Compliance Calendar [2026]
- The Hemp Ban Date Just Moved (Probably). What Should Your Dispensary Do With the Extra Month? [2026]
- Florida's Card Renewal Rule Changed July 27. How Many of Your Regulars Are About to Lapse?
- The Hemp THC Ban Hits November 12: Is Your Florida Dispensary Ready for the Customers Coming Back? [2026]
- Florida Dispensary Marketing Rules: What Can You Display In-Store? [2026]
- Florida's 22 New MMTC Licenses: What Does Your Dispensary Tech Stack Need Before Opening Day? [2026]
New rows are added the week a date is announced; posts carry an “updated” date when the facts change. Subscribe to the RSS feed or follow GreenScreens on LinkedIn to catch them.
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