5 Things Your Colorado Marijuana Business Should Plan for Under the New MED Rule Changes (Effective Jan 5, 2026)
By Genevieve Meehan
Dec 30, 2025
The Colorado Marijuana Enforcement Division (“MED”) has adopted and filed permanent rule revisions with the Secretary of State. When they take effect on January 5, 2026, they will materially impact daily operations across the regulated marijuana industry.
The new rules impact licensing, recordkeeping, surveillance, testing, and core operational procedures across the regulated marijuana industry. As the implementation deadline approaches, proactive planning is critical to avoid compliance gaps, operational disruptions, and enforcement risk.
Vicente’s team is ready to support you with targeted review, practical analysis, and hands-on implementation guidance in each area. Get ahead of the changes. Book a flat-rate compliance audit with Vicente’s experts today and enter 2026 with confidence.
1) Re-Evaluate Your Employee & Business Licensing
The revised rules narrow the scope of employees required to hold an employee license, transition identification credentials to digital formats, and adjust background check requirements. With the phased rollout of the unified application system beginning in 2026, now is an appropriate time for businesses to reassess their licensing structure and confirm that all required roles are appropriately documented.
Our firm can support businesses in reviewing licensing rosters and timelines, identifying gaps or unnecessary licenses, and preparing for the shift to unified applications to minimize administrative disruption.
2) Audit & Update Your Books and Records
Although the new rules streamline several aspects of recordkeeping and eliminate certain redundancies, many businesses will still face the practical challenge of reconciling years of accumulated documentation. This may include duplicative binders, outdated templates, and records that METRC already captures.
We assist clients with comprehensive books-and-records reviews, including restructuring compliance binders, organizing retained documents, and establishing systems that align with the revised framework and reduce the long-term administrative burden.
3) Review Your Surveillance System and Optimize for What’s Actually Required
The rules significantly reduce the number of areas requiring continuous video surveillance, presenting an opportunity to simplify systems and reduce costs. However, businesses must still confirm that required areas remain under compliant surveillance coverage.
We can evaluate existing surveillance layouts, identify where adjustments are needed under the new requirements, and help streamline systems while maintaining full regulatory compliance.
4) Reassess Facility Testing Procedures
The updated regulatory framework includes several changes to testing obligations, including definitional updates, production batch clarifications, and expanded testing requirements. Given the regulatory and financial consequences associated with testing noncompliance, businesses should ensure that operational and documentation practices reflect the revised rules.
We work with clients to review testing workflows and documentation, identify areas requiring adjustment, and ensure alignment with the updated regulatory standards.
5) Conduct an On-Site Compliance Audit
Regulatory transitions are an opportune moment to evaluate overall cannabis compliance readiness. An on-site compliance audit can reveal gaps, outdated procedures, or inconsistencies that may lead to challenges under the new rules.
Our team conducts detailed on-site compliance audits aligned to the 2026 regulations and provides clients with prioritized recommendations and implementation guidance.
Learn more: Vicente LLP Federal Cannabis Schedule III Updates & Resources Hub
Rule Rollout Audit
For businesses seeking a structured and cost-predictable way to prepare for the January 5 implementation date, we are offering a flat-rate audit. This audit provides a comprehensive assessment of compliance readiness and a clear roadmap for any necessary updates.
Contact Vicente LLP
We are committed to helping your team ensure compliance with all regulatory state and local requirements. Vicente’s Compliance Team closely monitored these rule changes and is ready to support you with the on-site implementation of procedures and systems to meet these new standards. Click here to schedule a meeting with a member of our Compliance Team to discuss any questions or concerns.