What will the ACMD medicinal cannabis review change?

What is the ACMD reviewing?

Whether the 2018 rescheduling worked. The Advisory Council on the Misuse of Drugs published a call for evidence on GOV.UK on 17 September 2025, open from 10:45am that day until 11:59pm on 17 October 2025. It described the exercise as support for the ACMD's review of changes to legislation on the use of cannabis-based products for medicinal use, or CBPMs. The review will examine the impact of the 2018 changes to the Misuse of Drugs Regulations 2001, consider whether the legislation had the intended impact, and identify unintended consequences.

The audience list tells you the breadth. The ACMD asked for evidence from healthcare professionals, researchers and academics, importers and manufacturers, people with lived or living experience, patients and their families, and regulatory and enforcement bodies. That is a review of a market, not only of a molecule. The GPhC's themed review of dispensing pharmacies, published on 9 October 2025, records that the Home Office asked the ACMD in June 2025 to carry out a further review of CBPM supply.

It is not the first attempt. By February 2019 the Home Office had asked the ACMD to assess the impact of moving medicinal cannabis from Schedule 1 to Schedule 2. It was to say whether further legislative amendments were needed, with a deadline of November 2020, according to the Pharmaceutical Journal at the time. The market the ACMD is now examining is far larger than the one that existed then, and the 2025 call for evidence starts the exercise afresh.

What did the 2018 rescheduling do?

It moved cannabis-based products for medicinal use in humans from Schedule 1 to Schedule 2 of the Misuse of Drugs Regulations 2001, so that they could lawfully be prescribed, supplied and possessed. The change followed a two-stage review in 2018. Dame Sally Davies, then Chief Medical Officer, reported clear evidence from respected research institutions that some cannabis-based medicinal products have therapeutic benefits. On 20 July 2018 the ACMD advised rescheduling, saying there was now evidence of medicinal benefit for some cannabis-based products in certain conditions. It attached conditions: products meeting standards set by the DHSC and MHRA, a framework of checks and balances for prescribing, and further trials. Home Secretary Sajid Javid had said on 19 June 2018 that if both stages recommended rescheduling, the government intended to reschedule.

The instrument was SI 2018/1055, in force from 1 November 2018. Its explanatory note records three things beyond the schedule move. It introduced a legal definition of a cannabis-based product for medicinal use in humans. It restricted ordering and supply to three cases. They are a special medicinal product used in accordance with the prescription or direction of a specialist medical practitioner, an investigational product in a clinical trial, or an authorised medicinal product. And it allowed the Secretary of State to waive licence fees under the 2010 fees regulations. The GPhC's 2025 review restates the prescribing rule in practice: an unlicensed CBPM must be initiated by a specialist doctor on the GMC Specialist Register with expertise in the condition being treated.

Why is the review happening now?

Because the market grew faster than the framework built for it. The GPhC's themed review, published on 9 October 2025, cites the CQC's 2024 annual update for a 130% rise in CBPM prescriptions between March 2023 and March 2024. More than 99.5% were issued in private healthcare settings. The same report notes that 98% of all CBPM products in England were supplied by ten registered pharmacies in that period. A market of that shape, private, fast-growing and concentrated, is exactly what an advisory council is asked to look at. Our analysis of the size of the UK medicinal cannabis market sets out the numbers in more detail.

The GPhC's own findings are the most concrete evidence the ACMD will receive from pharmacy. The regulator identified 25 pharmacies regularly supplying CBPMs through a desk-based review of its inspection pages, 24 of them still registered, and 17 supplying CBPMs as their main or only service. Most were meeting the standards for safe procurement, storage and dispensing. But five of the 17 core-service pharmacies and three of the eight others had failed to meet all standards. Across the group, seven failures were under governance, three under staffing, one under premises and six under service delivery.

The themes will be familiar to anyone who has read our guide to the rules for dispensing cannabis-based medicinal products. The GPhC found limited access to the clinical records needed to screen prescriptions, insufficient collaboration between prescribing clinics, suppliers and pharmacies, and quantities routinely above the 30-day best-practice maximum. Some pharmacies relied entirely on their partner clinics for identity checks. Several refused to supply where the patient withheld consent for the GP to be told. The GPhC said it would share the findings with the ACMD, government departments and professional bodies. In other words, the review's evidence base now includes a regulator's account of where the pharmacy layer is weakest.

Could medicinal cannabis move out of Schedule 2?

Legally, yes; practically, only through a process the Home Office controls. Section 31(3) of the Misuse of Drugs Act 1971 says the Secretary of State shall not make any regulations under the Act except after consultation with the Advisory Council. That is the ACMD's whole constitutional role here. It advises. It cannot reschedule anything. The 2018 change itself followed that path: ACMD advice on 20 July 2018, a ministerial decision, and regulations in force on 1 November 2018.

Three outcomes are possible in principle. The ACMD could advise that Schedule 2 remains right, which leaves the safe custody, register and prescription-writing requirements as they are. It could advise moving some or all CBPMs to Schedule 3 or 4, which would relax safe custody or register rules for those products while keeping them controlled. Or it could advise tightening, for example on quantities, prescriber requirements or the definition itself. Nothing in the call for evidence points to any of the three; its stated task is to assess impact and unintended consequences. Any shift would change the daily mechanics of dispensing set out in our guide to building a compliant CBPM dispensing workflow, from the private CD prescription formalities to the CD register.

The licensed products already show how scheduling follows evidence. Sativex, Epidyolex and nabilone are licensed medicines with their own schedules and are prescribed under ordinary rules. The unlicensed specials that make up the private market sit in Schedule 2 under the 2018 definition. An ACMD recommendation that distinguished between product types would not be a departure from the existing framework; it would be an extension of it.

Will GPs be able to prescribe medicinal cannabis?

Not without a change to the 2018 regulations, and none has been proposed. The restriction to a specialist medical practitioner is written into the instrument, so widening initiation to GPs would need new regulations, made after consultation with the ACMD under section 31(3). The ACMD's call for evidence asks whether the 2018 changes had their intended impact. Whether specialist-only prescribing has limited access is a legitimate part of that question, and patient groups will argue it has. Whether the ACMD, a body concerned with harms, will recommend loosening the gate is another matter.

For pharmacies the practical point is narrower. Under the current rules every unlicensed CBPM prescription you dispense should trace back to a specialist on the GMC Specialist Register with expertise in the condition. The GPhC has just checked whether pharmacies can show that. If the rule ever changes, the volume of prescriptions and the number of prescribers you deal with would rise sharply. The clinic-to-pharmacy information sharing the GPhC found lacking would matter even more.

When will the ACMD report, and what happens after?

No reporting date had been published by 26 March 2026. The ACMD's 2026 work programme, published on 11 March 2026, is the closest thing to a timetable, and the council's new chair, David Wood, was announced on 3 December 2025. Between the close of the call for evidence and the date of this article, the ACMD published an updated review of ketamine on 28 January 2026. The government responded to three ACMD medicines reports on 23 February 2026. Nothing appeared on CBPMs.

Each step has taken months in the past. The 2018 sequence ran from the ACMD's advice on 20 July to commencement on 1 November, and that was a government in a hurry. A pharmacy planning its year should assume the current framework for the whole of 2026 and treat any ACMD publication as the start of a process, not the end of one.

How should medicinal cannabis pharmacies prepare?

By closing the gaps the GPhC has already described, because those gaps are now in the ACMD's evidence base. The regulator recommended thorough risk assessments, better information sharing with clinics and access to clinical records. Its findings on quantities and identity checks are specific enough to audit against this week.

One more thing is within your control: the evidence. The call for evidence has closed, but the government response and any consultation on draft regulations will invite views again. A pharmacy with clean data on patients, prescribers, quantities and interventions will have something to say. One without it will be described by others.

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