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The April 2026 rescheduling
The April 23, 2026 order is short on paper and long on consequence. The questions below cover what the order did, who signed it, when it took effect, and how to read the documents themselves.
17 questions
Your 2026 tax position
§ 280E was the tax provision that effectively taxed cannabis operators on gross profit rather than net income. The April 28 rescheduling ends that treatment for state-licensed medical operators. Tax year 2026 is the first relief year. The questions below cover what changed, what didn’t, and what to do before the return comes due.
13 questions
Should you register?
The April 23 order created a new federal registration pathway specifically for OMMA-licensed operators. The registration is what converts your state license into federal-law authorization to handle a Schedule III controlled substance. The questions below cover what it is, who needs one, and what the 60-day window actually means.
17 questions
Filling out the application
The § 1301.13(k) application is more involved than most operators expect. It has seven sections, requires documentation that takes time to assemble, and contains two questions with real legal stakes. Plan one to two weeks of prep time before you sit down to file. The questions below walk through every section.
19 questions
Life as a federal registrant
Registration isn’t a one-time event. It comes with ongoing federal obligations — recordkeeping, inventory, security, labeling, inspections. Most of them are satisfied by what OMMA already requires. A few have federal-specific elements. The questions below map the post-registration compliance landscape.
13 questions
Banking, capital & valuation
The rescheduling is the first material federal change to cannabis-sector banking and capital access since the industry started operating. The change is incremental, not transformative — and registered medical operators are positioned to benefit before anyone else. The questions below cover what to expect from banks, payment processors, insurers, lenders, and investors as the new regime takes hold.
8 questions
Looking ahead
The April 23 order addressed state-licensed medical and FDA-approved drug products. A separate DEA proceeding starting June 29, 2026 will address the broader question — whether recreational and other currently-Schedule-I cannabis activity should move to Schedule III. Litigation challenging the medical-side order is being prepared. The questions below cover what comes next, what could go sideways, and how to think about durability over the longer horizon.
9 questions