DEA Calls for Registration of Medical Marijuana Licensees – Portal is Open Through June 22, 2026

If you have a state-issued license to cultivate, produce, distribute, transport, and/or sell or buy wholesale or retail medical marijuana, the U.S. Drug Enforcement Administration (DEA) wants you!

June 22, 2026, Hard Cutoff Date

DEA is calling for all such licensees to register with DEA to permit the licensee’s handling of now-rescheduled medical marijuana. The registration period ends June 22, 2026. Registration provides a ‘safe harbor’ to licensees who timely register, meaning that the licensee may continue its state-licensed medical marijuana operation while DEA reviews its application, but failure to timely register may subject a licensee to federal enforcement actions.

Benefits and Burdens of Registration

To register or not…that is the question. Registration comes with benefits, such as permitting the licensee to take general and administrative expense deductions. The ability to take ordinary business deductions could result in substantial tax savings, and for many operators, that benefit alone may outweigh the burdens associated with registration.

However, registration also carries risks and obligations. These include an annual registration fee of $794, ongoing compliance with both federal and state regulatory requirements, disclosure of business and operational information, onsite inspections, and product testing. Some of the required registration information may raise privacy concerns, including the distribution of a licensee’s contracts, the personal information of owners and managers, and Freedom of Information Act disclosures to the public. For example, applicants must provide detailed information about supplier relationships and other business operations that are typically treated as confidential. Licensees should carefully consider whether they are comfortable sharing this level of information with federal regulators (and potentially their competition and the public) and assess their confidence in how that information will be maintained and protected.

The broader regulatory landscape also remains uncertain. While the April 23, 2026, rescheduling order issued by the Acting U.S. Attorney General is widely viewed as a significant step forward, it was influenced by sustained advocacy from large multi-state operators and industry stakeholders with deep pockets and resilient budgets not typically available to small and regional operators.

Rescheduling does not legalize marijuana at the federal level — recreational marijuana businesses operating under state law remain illegal under federal law. Mere registration of a state-licensed marijuana business with the DEA may result in the public disclosure of business secrets, the initiation of enforcement actions against state-licensed businesses that are also handling recreational marijuana, and/or the resumption or intensification of enforcement actions against state-licensed adult use licensees.  Note that the registration calls for the applicant to name all owners and managers who have engaged in handling marijuana in the legacy market or by other means outside the state’s licensing program.  This question is asked of the applicant without any time parameters; many current owners or managers of licensed marijuana operations got their start in the legacy market decades ago. Does any licensee applicant dare disclose its owners and managers with roots in the black market?

Additionally, registration signals a shift toward a more traditional controlled substances framework. Schedule III substances are typically subject to FDA oversight, including requirements for clinical testing, product approval, and prescription-based distribution through licensed healthcare providers and pharmacies. If similar requirements are imposed on medical marijuana, licensees must consider whether they are prepared to operate within that structure. In effect, DEA registration could begin to transform a state-issued medical marijuana license into something more akin to a federal controlled substances registration, with corresponding regulatory expectations.

What a Licensee Needs to Register. The following documentation and information is required to register:

1. Business and personal contact information.
2. Licensee’s Social Security Number or Tax ID.
3. Whether there has been a change of ownership over the past 12 months (why is this relevant, we wonder).
4. Whether the licensee has a controlled substances registration with the DEA and the licensee’s experience in handling controlled substances.
5. The type of marijuana licensee intends to handle or dispense:
6. Marijuana or marijuana extract in a Food and Drug Administration (FDA) approved product, or that is subject to a state medical marijuana license, or
7. Naturally derived delta-9-THC in an FDA-approved product or that is subject to a state medical marijuana license.
8. Whether licensee will handle or dispense recreational marijuana (so that when DEA visits the medical facility, it can also observe the recreational operation?).
9. Licensee’s state license number, the state of issuance, and expiration date.
10. Whether licensee and its suppliers/handlers[1], officers, partners, shareholders or proprietors have ever (no period of time mentioned):
11. Criminal controlled substances convictions,
12. Professional licensing or controlled substances registration suspensions or revocations, or
13. Past ownership or operation of manufacturing, distribution, or dispensing of unregistered controlled substances (this appears to require legacy market disclosure).
14. Product suppliers’ names and DEA registration number(s).
15. Whether licensee repackages or relabels marijuana.
16. Whether licensee has standard operating procedures (SOPs) on ordering, receiving, inventories, storage, security, dispensing (including delivery), distributing, destruction/disposal, theft and loss reporting, due diligence (including supplier, patient, and practitioner verifications), records maintenance, and corresponding responsibility.
17. Security measures for each location for which registration is sought.

Online registration commenced on Wednesday, April 29, 2026, at 9 a.m. (EST): https://mmapplication.diversion.dea.gov/registration-instructions, and there’s a hard stop to registrations on June 22, 2026.  PayPal is the only digital payment platform accepted at this time, so applicants need to open an account to pay the registration fee. A confirmation of submission will be emailed by the DEA to the licensee applicant, and applications are expected to be reviewed by DEA before the end of this year.

Janet Jackim, Chair of the Cannabis Business Industry Group, is a well-seasoned cannabis and business attorney whose practice focuses on cannabis transactions, litigation, commercial real estate, mergers and acquisitions, and litigation involving the foregoing. She can be reached at jjackim@fennemorelaw.com.

Questions? Please contact us for more information about our Cannabis Law practice and legal advice tailored to your specific situation. 

Notes

States and territories having medical marijuana programs are: Alabama, Alaska, Arizona, Arkansas, California, Colorado, Commonwealth of Northern Mariana Islands, Connecticut, Delaware, District of Columbia, Florida, Georgia, Guam, Hawaii, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, New York, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Puerto Rico, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont, Virgin Islands, Virginia, Washington, West Virginia, Wisconsin, and Wyoming, according to Normal.org.  Each state’s laws differ – please consult local legal counsel.

The suppliers/handlers phrasingwould appear to require anyone in the medical marijuana chain — from cultivation to sale to the public — to provide bad act reporting to the licensee so that licensee can, in turn, report such acts to the DEA.