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The Federal Cannabis File

Federal cannabis law for state-licensed operators and their advisers: DEA registration, rescheduling, inspections, and what each development means for your license. One issue a week, written by Ryan Kocot.

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I keep telling operators to build a federal file: your application, your correspondence, your records, one place, ready to produce. This is the public one. Every week it carries the federal developments that matter to a state-licensed operator, what to do about them, and the occasional extra that goes to the list first.

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The firm’s articles

Every kocotlaw.com article sorted by state, free, no email required. The same page previews Cannabis Contract Connector, a contracts reference product coming soon from cannabislaw.ai and published separately from the firm.

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The issues

Pulled from the newsletter archive as each issue goes out. Open any issue to read it in full.

Issue 7 · September 30, 2026 The Guidance That May Never Come The rescheduling delay, and what operators are actually waiting on from Treasury, DOJ, and the DEA. Read the issue →

Earlier issues

Issue 6 · September 22, 2026An expanded compliance audit framework that includes federal requirementsThe 109-check framework: state layer, local layer, federal DEA layer, and program hygiene. Read → Issue 5 · September 15, 2026Your state compliance program has been promotedWhy a state compliance program now carries federal weight for medical-channel operators. Read → Issue 4 · September 8, 2026DEA sent dispensaries 26 questions. Here they all are.The questionnaire sent to registration applicants, question by question. Read → Issue 3 · September 1, 2026The checklist I’d carry if I were a DEA inspectorThe eight stops an investigator works, in order. Read → Issue 2 · August 25, 2026How a DEA inspection can go wrongA mock inspection of a fictional retailer, minute by minute, with the fix for every mistake. Read → Issue 1 · August 17, 2026DEA inspections have started. Here’s your starter checklist.The first issue, with the DEA Inspection Starter Checklist in full. Read →

Every issue is also listed under The Federal Cannabis File on the blog. Issues go to subscribers first. Subscribe free to get the next one the day it goes out.

The rest of the file

Everything else published for state-licensed operators, grouped the way the newsletter is. New pieces are added here the week they publish.

▸The federal file (DEA)

DEA registration under 21 C.F.R. § 1301.13(k)What the medical-channel registration is, who qualifies, and how the firm handles it. What my checklist would look like if I were a DEA inspectorThe eight stops an investigator works, in order, with the record they ask for at each. DEA’s 26 questions for marijuana dispensariesThe questionnaire sent to applicants, broken down question by question. The ownership-disclosure mismatchThe lowest-hanging fruit for a federal investigator: state disclosures that do not match the application. The registration window closed. Now what?Options for operators who did not file in the 60-day window. Unregistered and operating: the federal enforcement riskWhat changes for a state licensee that stays outside the federal system. ResourcesThe firm’s articles sorted by state, and a preview of Cannabis Contract Connector, coming soon.

▸California enforcement

The mistake operators make when DCC enforcement arrivesThe first 24 hours, and why improvising them costs the license. DCC embargo notice: what to do4 CCR § 17801.5, the clock it starts, and the response plan. DCC emergency decision and order§ 17815 administrative holds and temporary suspensions, and the three-business-day hearing window. California cannabis recalls: what licensees must do and when§§ 17225 to 17227 recall duties for every link in the supply chain. DCC’s July 1, 2026 regulation updatesWhat changed, and what inspectors will check first. AB 2249 and California cannabis packagingThe packaging rule and the supply-chain responsibility behind it.

▸The practice

Compliance and regulatory counselThe practice behind this page: audits, SOPs, inspections, enforcement response. License and enforcement defenseAccusations, emergency orders, embargoes, and Notices to Comply.

Change log

  • October 22, 2026. The live audit checklist retired from the site; this page became the newsletter’s home, with every issue listed.
  • September 17, 2026. First published. 87 checks across the state layer, the federal DEA layer, and program hygiene.

Attorney advertising. This page and the newsletter are general information, not legal advice. Federal, state, and local requirements vary by operation, license type, and jurisdiction and change often; confirm the current text of every authority before acting. The federal situation is fluid and many legal and tax questions remain unanswered. Reading or subscribing does not create an attorney-client relationship. © 2026 Kocot Law.

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