Cannabis Staffing Rules: The On-Site Practitioner Requirement

Staffing is the requirement that closes the most cannabis shops in Thailand. Since January 2026, at least one DTAM-certified practitioner must be physically present throughout all operating hours of a cannabis establishment. This is not a paperwork formality — a gap in coverage is grounds for non-renewal, and it is one of the leading reasons renewals fail.

This guide explains who qualifies, exactly what the hours rule means, and the consequences of getting it wrong.

The rule in one line

Ministerial Regulation No. 2 B.E. 2569 (Article 8/1(4)) requires at least one DTAM-trained staff member present “throughout the time the establishment is open.” In practice this means a qualified practitioner has to be on the premises every single hour you are open for business — not on call, not part-time, not “usually around.”

Who qualifies as a practitioner

Sources from law firms and DTAM list the following qualifying practitioner types. Note: the exact list conflicts across sources — confirm with DTAM before you hire.

• Medical doctors
• Thai traditional-medicine practitioners
• Applied Thai traditional-medicine practitioners
• Pharmacists
• Dentists
• Traditional Chinese-medicine practitioners (per Tilleke/DTAM)
• Licensed folk healers (per Tilleke/DTAM)

Every one of them must hold DTAM cannabis-prescribing certification. The certification, not just the profession, is what makes a practitioner eligible to supervise cannabis dispensing and issue PT 33 prescriptions.

Source conflict to verify: some listings (including older versions of our own material) include veterinarians (for animal treatment only) in place of traditional Chinese-medicine practitioners and folk healers. The authoritative Tilleke/DTAM list uses the seven categories above. Because this is material for hiring, confirm the current list with DTAM before signing an employment contract. See the PT 33 prescription guide for the prescriber detail.

What “all operating hours” really means

The rule is coverage, not presence for part of the day. Three practical consequences:

1. Your hours are capped by your practitioner’s hours. A single practitioner working a normal shift cannot legally cover a shop open from morning to late night. Long hours require more than one qualified practitioner, or shorter operating hours.
2. Breaks and absences count. If your practitioner steps out and you keep selling, you are operating out of compliance during that window.
3. Coverage must be documented. Inspectors check for the practitioner’s presence during operating hours, and DTAM issues identification and training records that tie a certified person to the establishment.

The cleanest way to stay compliant is to align your posted opening hours to the hours you can actually guarantee certified coverage, and to have a backup practitioner arrangement so a single illness does not force a closure or a compliance gap.

The cost — and why it decides survival

The certified practitioner is usually the single largest recurring cost of a compliant cannabis business, and it is the cost that pushed thousands of shops out of the market when the rule took effect. Budget realistically.

Figures are planning estimates, not quotes — confirm current rates and any certification fees with DTAM and the practitioner.

Consequences of getting it wrong

• Non-renewal. A gap in practitioner coverage is explicit grounds for refusing to renew your license.
• Criminal exposure. Dispensing cannabis without proper authorization can carry up to one year’s imprisonment and/or a THB 20,000 fine under the Traditional Medicine Act B.E. 2542.
• Administrative action. Suspension, closure, and revocation follow breaches of operational rules. A license previously suspended for non-compliance cannot be renewed.

The full penalty framework is in our cannabis law overview.

How staffing fits the bigger picture

The on-site practitioner requirement is one pillar of the conversion from open-market shop to regulated medical establishment. It sits alongside facility standards, GACP-sourced supply, and prescription-only dispensing. To see how it connects:

• Dispensary-to-clinic conversion guide — the full April 2026 mandate
• License renewal 2026 — why staffing gaps sink renewals
• Compliance checklist — staffing in the context of every other requirement
• Medical cannabis section — the clinical side your practitioner operates within
• Cannabis license guide and the business hub

This guide is general information, not legal advice. The practitioner list and hours interpretation should be confirmed with DTAM and a licensed Thai legal professional before you hire or open.