Cannabis Rescheduling to Schedule III: What Businesses and Financial Institutions Need to Know

Yesterday, President Trump signed an executive order to reclassify cannabis from Schedule I to Schedule III of the Controlled Substances Act.

This executive order marks one of the most significant federal policy shifts in the history of the regulated cannabis market.

For cannabis businesses, banks, and credit unions, this executive order raises important questions around compliance, risk management, taxation, and access to financial services. Understanding what Schedule III means and how to prepare will be essential in the months ahead.

Why Cannabis Rescheduling Matters

Moving cannabis to Schedule III fundamentally alters how cannabis is treated under federal law. While it does not legalize cannabis outright, rescheduling does meaningfully reduce barriers and reshapes how cannabis businesses operate, and how financial institutions assess risk.

Key areas to be impacted include:

• Federal tax treatment and deductions
• Commercial lending to cannabis operators
• Compliance obligations for cannabis operators
• Risk assessments for banks and credit unions
• The expansion of cannabis banking programs

As this regulatory environment evolves, proactive legal guidance will be critical.

How Cogent Law Is Supporting Cannabis Businesses and Financial Institutions

Cogent Law has assembled a team of experienced attorneys focused on cannabis law and cannabis banking law to help clients navigate the implications of rescheduling and prepare for what comes next.

Cannabis law partners Joshua Radbod, Adrienne Dean, and Suehiko Ono are advising cannabis businesses on regulatory strategy, compliance considerations, and how to position themselves to take advantage of new opportunities created by Schedule III.

In parallel, Chris Van Dyck, a former regulatory attorney and financial institution general counsel, is working with banks and credit unions to develop and strengthen compliant cannabis banking programs and expand into commercial lending. His experience helps financial institutions evaluate risk, update policies, and respond confidently to a shifting federal framework.

Preparing for a Changing Regulatory Landscape

Rescheduling does not eliminate complexity, but it does create meaningful opportunities for those who are prepared. Cogent Law's attorneys are committed to keeping clients informed as developments unfold and to providing practical, actionable guidance tailored to each client's role in the cannabis ecosystem.

Our deep understanding of cannabis regulation and the financial institutions that support the industry allows us to guide clients through this rapidly changing environment with clarity, confidence, and strategic foresight.

Looking Ahead

As the industry prepares for this transformative moment, now is the time to assess your legal and compliance posture. Whether you are a cannabis operator evaluating the impact of Schedule III, or a financial institution considering cannabis banking opportunities, experienced counsel can help you navigate what's ahead.

Explore our cannabis law practice and cannabis banking services for more on how Cogent Law advises operators and financial institutions. For related analysis, read our article on the state of cannabis banking in 2026.