15 Things Cannabis Operators Should Lock Down in Q4 2026

Most fourth quarters come down to holiday volume and a clean close. This one also decides how much federal tax a large part of the industry pays for the entire year.

Since April, medical cannabis has been Schedule III and adult-use hasn't, and the rule for splitting the two still isn't written. The hemp ban lands in two steps. Massachusetts votes on repealing adult-use sales. And the usual Q4 pressures haven't gone anywhere. Here are the 15 things to finish before December 31, grouped by where they sit in the business. None of it is tax or legal advice: take the federal items to a cannabis CPA and attorney who know your structure.

Federal and Tax

1. Know which of your licenses are Schedule III

On April 22, the Justice Department moved marijuana sold under a state medical license to Schedule III. Adult-use marijuana is still Schedule I. On September 9, the D.C. Circuit declined to pause the order while a challenge to it proceeds, so for now the line holds. It runs through the middle of a lot of companies. A vertical operator with a medical dispensary in one state and adult-use stores in two others is now in three different federal tax situations. Write down which entities, licenses and locations sit on which side. Items 2 through 5 depend on it.

2. Separate medical and adult-use books before December 31

Treasury has promised guidance on how businesses with both medical and adult-use activity split their expenses. As of late September, it hasn't arrived. Dual-license operators are closing 2026 without the rule.

The operators in the best position when it lands will be the ones whose records already show the split: inventory tracked by channel, labor coded to the activity it supported, separate bank accounts where possible, and shared rent and overhead allocated on a basis someone can explain. Attorneys are giving the same advice for DEA purposes, since registration covers medical activity only. Rebuilding that separation from one commingled ledger next spring will be slow, expensive and harder to defend.

3. Re-run your 2026 tax estimate before the December 15 payment

Treasury and the IRS have said rescheduling "will generally be considered to first apply for a business's full taxable year that includes the effective date." For medical cannabis, that means January 1, 2026. A qualifying medical operator gets a full year of ordinary deductions, not eight months. Payroll, rent, marketing and professional fees that were nondeductible in 2025 can come back into the calculation.

Estimated payments made in April, June and September were probably calculated under the old rules. Calendar-year corporations make their fourth installment on December 15. Have your CPA re-run the provision before then, not in March. The gap between the two numbers is the cost of 280E made visible.

4. Get a written opinion for any position that isn't straight 280E

Adult-use activity is still fully subject to 280E, and the IRS does not accept the argument that it isn't. Tax attorneys report more cannabis audit activity than ever. The case testing the question in Tax Court, New Mexico Top Organics, is fully briefed and still undecided.

If your 2026 return takes any non-280E position, including an aggressive medical/adult-use allocation, the supporting opinion has to meet the "reasonable basis" standard. An argument that is merely arguable won't protect you from penalties. Commission the opinion this quarter, while there's still time to change the position if it doesn't hold up.

5. Check where your DEA registration stands

Medical operators who applied for DEA registration within the 60-day expedited window can keep operating under their state license while the application is pending. DEA said it would try to process applications within six months, which puts the first decisions in Q4. Confirm the application is complete, that the contact on file is someone who reads the mail, and that your facility and records still match what you told DEA. A question from DEA in December is easy to answer if the documentation is already assembled.

6. Don't build 2027 around a federal change that hasn't happened

Two things will be pitched to you as imminent: adult-use rescheduling and banking reform. Neither belongs in your base-case budget.

The DEA hearing on moving all marijuana to Schedule III ended July 15, and the administrative law judge's recommendation has no deadline. The optimistic path puts a final rule in late 2026 or early 2027. Legal observers put real operator impact 12 to 24 months out. The SAFE Banking Act was reintroduced this year as S. 4942 and H.R. 9471 and, as of this summer, had no committee vote. Budget adult-use on full 280E and today's banking costs. If either changes, it's upside.

Books and Inventory

7. Count everything and reconcile it to Metrc before the close

For adult-use operators, cost of goods sold is still the only deduction 280E allows, which makes the year-end inventory count one of the most valuable numbers on the return. It's also a compliance number. A count that doesn't match Metrc is a variance a regulator can find on their own, and it gets harder to explain the longer it sits. Run the count in early December, not on December 31, so there's time to investigate variances and correct them in the system before the books close.

8. Mark your flower to what it would actually sell for

Packaged flower averaged $3.62 a gram in June, down 5.7% from $3.84 a year earlier. The national wholesale spot price sat around $1,003 a pound in mid-June, and October's outdoor harvest has historically pushed wholesale lower. Inventory carried at what you paid last spring is probably overstated. Writing it down to realistic value before the close shows you the margin you actually have, and keeps an inflated asset away from a lender, buyer or auditor who will find it anyway.

9. Clean up receivables before year-end

Every open invoice on the December 31 balance sheet is a claim that the money is coming. Go through the aging report account by account. Write off what isn't coming back, move stalled 60-day balances into a real escalation process, and put accounts that keep sliding on prepay before holiday orders ship. In New York, check the aging against OCM's 90-day payment rule. A Q1 cash forecast built on receivables that won't be collected is wrong before January starts. The five AR metrics worth tracking are a good place to start the review.

10. Close December as if a buyer were going to read it

Whether or not you plan to sell, the December close is the set of numbers lenders, investors and acquirers ask for first. What raises a sale price is also what makes an ordinary business easier to run: a store-level P&L, reconciled bank and inventory accounts, no suspense balances, and no open tax or compliance issues. For medical operators, 2026 is the first tax year after rescheduling. These financials become the baseline every future year gets compared against.

State and Cost Changes

11. Plan for the hemp ban on two dates

Federal restrictions on intoxicating hemp were set to take effect November 12. A funding bill signed September 2 moved the date to December 11 for naturally derived products, which will be capped at 0.3% total THC by dry weight and 0.4 milligrams of total THC per container. Synthetic and converted cannabinoids like delta-8 and HHC are still banned on November 12.

Demand now served by gas stations, smoke shops and liquor stores will need somewhere to go, with beverages and gummies first in line. Plan for it in assortment and marketing. Don't commit heavily to inventory against a date Congress has already moved once, with four hemp regulation bills still pending.

12. Massachusetts: have a plan for Question 8 either way

On November 3, Massachusetts voters decide Question 8), which would repeal adult-use sales and home cultivation while keeping the medical program. Polling favors the industry: a University of Massachusetts Amherst and WCVB survey in August found about 55% of voters planning to vote no. That isn't a reason to skip the contingency plan. Know what happens to leases, inventory, loan covenants and staff if it passes, and which locations could run as medical. If it fails, the same work shows you where you're exposed to the next attempt.

13. Load January 1 cost changes into the 2027 budget

Several changes hit on the first day of next year. California's minimum wage rises to $17.40, Connecticut's to $17.48 and Michigan's to $15.00. States that index to inflation, including Arizona, Colorado, New Jersey, New York, Ohio, Oregon and Washington, typically adjust on January 1 as well. For a store with 20 full-time budtenders, a 50-cent raise is about $20,800 a year before payroll taxes.

Maine's sales tax on adult-use cannabis rises from 10% to 14% on January 1, which will come out of either margin or shelf price. California's 15% excise rate holds through June 2028. Build the budget on the rates that take effect, not the ones you're paying now.

14. Put expansion dates on the calendar

If new markets are in the 2027 plan, the dates have moved. Virginia's budget, enacted in June, sets adult-use retail sales to begin July 1, 2027, with up to 350 stores and the Cannabis Control Authority accepting license applications from February 1, 2027. That window opens five weeks into Q1, so the applications, sites and capital are Q4 work. Pennsylvania passed its budget without legalization, despite the governor proposing sales starting January 1, 2027. Plan Pennsylvania as a medical market for 2027.

Holiday Retail

15. Plan Green Wednesday for margin, not just volume

Green Wednesday is November 25 this year. In 2025, U.S. dispensaries did $113.5 million that day, 1.7 times an average day and second only to 4/20. Black Friday added $107.5 million.

Not all of it is new money. In Headset's 2023 data, Thanksgiving Day sales ran 70% below a normal Thursday, the week finished 8% below the prior four-week average, and the average discount during Thanksgiving week rose from 17.9% to 25%. Set a discount ceiling before the promotions get built. Then stock for December, when edibles and vapes peak: New York's edible sales hit $9.8 million last December, the highest month of the year. Clean up duplicate SKUs before the traffic arrives, not during it.

The Q4 Calendar

If you only get to three items, make them 2, 3 and 7. The separation, the tax estimate and the count all have hard deadlines, and each one gets harder to fix after December 31.