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Nov 12, Dec 11, or Neither? Every Date on Your Florida Dispensary's Q4 Compliance Calendar [2026]

August 17, 2026

Nov 12, Dec 11, or Neither? Every Date on Your Florida Dispensary's Q4 Compliance Calendar [2026]

Update — September 3, 2026: The biggest open date on this calendar is settled. The House passed H.R. 6500 on September 1, 370–48, and the President signed it September 2: most federal hemp-THC restrictions now take effect December 11, with products containing cannabinoids the plant can't naturally produce still losing hemp status November 12. The table and hemp section below are updated; full countdown playbook: the hemp ban date is final — here's the 14-week plan.

Between today and New Year's, at least five separate regulatory triggers will land on Florida dispensaries — and not one of them arrives on a date you control. The federal hemp ban now takes effect December 11 (most products) and November 12 (synthetic cannabinoids) — settled by the funding bill signed September 2. The DEA's rescheduling judge now has everything he needs to issue a recommendation, on no particular schedule. Twenty-two new MMTC licenses issued September 11, starting a year-long clock. The rules that have governed the program since 2017 are being rewritten into permanent form, comment window by comment window. And Tallahassee's committee weeks start this fall.

You can't plan a quarter around debates. You can plan one around triggers: for each date, decide now what changes in your store the day it hits, so the news lands on an execution day instead of a meeting. This page is that calendar — what's coming, what each item actually changes for an operator, and the screen-level move for each one. We'll keep it updated as dates resolve.

The calendar at a glance

When What Status (Sep 23)
Since Jul 27 Registry blocks card renewals without a current certification Live
Aug 17 Rescheduling briefing record closes Done — DEA's own brief urged Schedule III
Sep 2 Hemp-delay bill signed into law Done — H.R. 6500 signed; date settled
Sep 11 Final order on 22 new MMTC licenses Done — issued; $5M financial assurance due Sep 25, appeal window to ~Oct 11
Sep 14 Listed comment period ends on proposed permanent marketing rule 64-4.227 Done — effective date TBD; 180-day compliance clock runs from it
Sep 28 Registry logins require multifactor authentication Fixed — OMMU notice; scope for MMTC accounts unconfirmed
Oct 2 Listed comment period ends on proposed licensing rule 64-4.214 Fixed — does not itself open a licensing round
Oct 15 Square's deadline: hemp/CBD items off seller catalogs Fixed
Rolling OMMU permanent-rulemaking comment windows Underway, rule by rule
Nov 12 Cannabinoids not naturally producible by the plant lose hemp status Fixed — the delay doesn't cover these
Dec 11 Main hemp-THC restrictions take effect Fixed — signed into law Sep 2
Dec 11 Government funding expires — next appropriations fight Same day as the hemp date
Fall → Mar 2027 Committee weeks, then the 2027 session Committee weeks begin this fall

Now the detail — in the order the dates arrive.

Already in effect: the July 27 renewal rule is quietly costing you regulars

The one item on this calendar that's already live. Since July 27, the Medical Marijuana Use Registry won't let a patient complete a card renewal without a current or scheduled physician certification with open orders. The failure happens early and silently — a patient gets stopped mid-application, doesn't notice until the card lapses, and simply stops showing up. With card and certification clocks running on different cycles, this compounds all quarter. The screen move is a standing one: keep a "check your certification date before you renew" slide in rotation with a QR to the Registry. It costs you one slot and protects repeat revenue every single day of Q4.

August 17: the rescheduling record is closed. Now comes the quiet part.

Update, Aug 24: the briefs are in — and the DEA's own attorneys urged Judge Julius to "expeditiously recommend" moving marijuana to Schedule III, arguing it "can no longer remain in Schedule I." The agency that spent the hearing looking adversarial is now formally on record for the transfer.

August 17 was the deadline for parties in the DEA's marijuana rescheduling proceeding to file post-hearing briefs — optional, up to 50 pages — along with corrections to the hearing transcripts. That closes the evidentiary record. From here, Chief ALJ Derek Julius issues a recommended decision on whether marijuana broadly moves to Schedule III. There is no deadline for that recommendation; most observers expect late 2026. It's advisory — the DEA Administrator makes the final call after that.

What operators sometimes miss: the operational change already happened. The April 23 order placed state-licensed medical marijuana in Schedule III months ago, with the 280E tax relief that follows — we covered what that changes day to day. What's left in this docket is the broader question, and for a Florida MMTC the honest calendar entry is: expect a headline sometime this quarter or next, expect customers to ask about it the same day, and have the "what this means here" answer ready. That answer belongs on your waiting-room screen before it's in the group chat.

September 2: the House voted, the President signed — your biggest date of the year is set

Resolved, September 3: this was the hinge of the quarter, and it swung. The House passed H.R. 6500 on September 1, 370–48 — the same bill the Senate approved 90–6 in August — and the President signed it into law September 2. Most federal hemp-THC restrictions now take effect December 11; products with cannabinoids not naturally producible by the plant still lose hemp status November 12. The White House has signaled no further extensions — and note the bill funds the government only through December 11, so the ban's effective date and the next funding fight share a deadline.

What's still genuinely open is the shape, not the date: Congress bought the month explicitly as time to negotiate a regulatory framework — age limits, testing, packaging instead of the 0.4 mg cap — and bills like the Beverage Regulatory Parity Act are circulating. Plan for the law as written; treat a framework deal as upside to react to, not a scenario to build around.

The operator move: the go-date variable is filled. Two-stage campaign — soft launch around November 12's narrower non-naturally-producible exit, full push for December 11. The week-by-week version is in the countdown playbook.

One date on this calendar, though, doesn't answer to that vote at all: October 15, when Square requires its sellers to pull every hemp and CBD item from their catalogs — whatever Congress does. The payments layer moving early means hemp retail starts contracting, and displaced customers start shopping around, weeks before any legal deadline.

September 11: the 22-license final order landed — and started the clock

Resolved, September 23. The final order on 22 new MMTC licenses — projected for June or July, then "any week" — was entered September 11. The Department licensed the same 22 applicants it selected in November 2024 and declined to adopt the ALJ's proposed rescore; OMMU's directory now lists them at "Initial Licensure," and its September 18 weekly table carries 49 licensed MMTCs, up from 27. The clocks in Florida's rules run from that date: $5 million in financial assurance within ten business days (September 25), a cultivation-authorization request within 180 calendar days, processing within 270, and dispensing within 365 — each request triggering an inspection the licensee has to be ready to pass. Denied applicants have 30 days to seek review at the First DCA, so the order isn't beyond challenge until the second week of October. The full post-licensure calendar, and what it means from inside a store that's already open.

If you're an incumbent, the calendar entry hasn't changed: it was a news-cycle day, and your customers will read "nearly double the licenses" without the context that new stores are a year-plus away — none of the 22 can request a dispensing location before it clears cultivation and processing. If you're one of the 22 — the tech checklist linked above was written for you, and the dispensing request is the deadline it's for.

September 28: a second lock on the Registry

Added September 7. OMMU has posted a notice that, beginning September 28, Registry users must use multifactor authentication — "via an authenticator application or email notification" — to access the Registry, citing the state's cybersecurity standards. Patients renew cards, pay the fee, and check orders in the Registry; MMTC staff record dispensations there. OMMU's notice says "users," hasn't said whether MMTC accounts are included, and hasn't published setup instructions yet — confirm scope through your Registry executive user before the 28th. The retention risk is the same one the July 27 rule created, one step earlier: the patient who logs in once a year to renew meets the new login cold, in the 45-day window, with the card expiring. Screen move: a "Registry adds MFA Sept 28 — make sure you can access your account and its email; watch OMMU for setup instructions" slide now (interior-facing, through your normal compliance review), swapped for a "trouble getting in? OMMU's guides can help" slide after the 28th. Full breakdown and the three-week plan.

Rolling all quarter: the rules become permanent, and you get a say — briefly

Since 2017, Florida's program has run on emergency rules. That era is ending: OMMU is converting its emergency rules to permanent ones through standard APA rulemaking — licensure renewal, seed-to-sale tracking, dosing limits, and, most relevant to what your store displays: trade names and logos, packaging and labeling, and website purchasing. Proposed rules and workshop notices are appearing in the Florida Administrative Register under Chapter 64-4, each with its own comment window.

Two reasons this belongs on an operator's calendar and not just a lawyer's. First, comment windows are finite — this is the first real chance since 2017 to shape the display and branding rules you live under, including the regime we mapped in the marketing-rules guide. Second, when a permanent rule takes effect, it takes effect everywhere at once — and if it touches what menus may display, screens are the only menu layer that can comply fleet-wide the same day.

Update, September 14: the marketing rule's window is the first to run out. Proposed Rule 64-4.227 — the proposed permanent replacement for emergency rule 64ER25-6 — was published August 24 with a listed 21-day comment period running through September 14; a hearing follows if one was requested in that window or if the Department schedules one. As proposed, it keeps the three permitted channels and the interior not-visible-from-outside rule, but lists a single exterior sign, limits owned social-media posts to six kinds of content, adds a prohibition on depicting risky activities, and gives operators 180 days from the rule's effective date to pull previously approved content that no longer complies. No effective date exists until the Department adopts it. The line-by-line diff and the three audits to run now. A second permanent rule, 64-4.214 on MMTC license applications, was published September 11 with comments open through October 2 — it sets the framework ($146,000 fee, five-day windows) without opening a round.

November 12, no matter what: the synthetic carve-out

Whatever happens in September, products containing cannabinoids that can't be naturally produced by the cannabis plant lose federal hemp status on November 12 — the Senate's delay explicitly doesn't cover them. A slice of the gas-station shelf near you goes away on the original date regardless, which means an early, smaller wave of displaced customers ahead of the main one. That's your soft-launch date: the switcher campaign's first stage runs in November even in the delay scenario.

This fall through March 2, 2027: Tallahassee gets its turn

Florida's Legislature set its 2027 session dates: interim committee weeks begin this fall, and the regular session convenes March 2, 2027. Whatever survives Congress in September, the state-level response — aligning Florida's hemp statutes with the federal definition, or filling whatever gap Congress leaves — takes shape in those committee rooms first. If your Q4 goes according to plan and you capture the switcher wave, Q1's job is keeping those customers through whatever Tallahassee does next. Committee-week agendas are the early warning.

Running a store off triggers, not debates

Put the rows above on one page — this one — and the quarter gets simpler, because every row resolves to the same operating discipline:

Decide the change before the date. For each trigger, the day it fires should be an execution day. What slide goes up when the rescheduling recommendation drops? What does the menu emphasize the week the hemp date settles? Write those answers in August, not in the news cycle.

Make the date a field, not a fact. Half this calendar is dates that can move. On a digital menu system, a moved date is a dashboard edit; on printed signage, it's a reprint per location. When three of your five triggers are decided in Washington on nobody's schedule, the cost of being current should be zero.

Keep one honest slide up all quarter. "The rules around cannabis are changing this fall — ask us what it means for you" is accurate on every date in every scenario, and it makes your staff the people with answers.

The quarter ahead is unusually dense with dates someone else controls. The stores that come out of it ahead won't be the ones that guessed the outcomes right — they'll be the ones for whom no outcome required a scramble. If re-pointing every screen in your fleet the day one of these triggers fires sounds hard with your current setup, that's the part we do. See how GreenScreens works or get a demo — we'll show you a live store.

Related reading: The hemp ban date just moved (probably) · What Schedule III actually changes for dispensary operations · Florida's 22 new MMTC licenses: the dispensary tech checklist · Florida dispensary marketing rules: what you can display in-store

This article reflects the regulatory calendar as of September 23, 2026, and is general information for dispensary operators, not legal advice. Several of these dates are set by pending legislation or agency action and can move — we update this page as they resolve, but confirm current effective dates with your counsel before acting.

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