Regular Session
Government Affairs & Regulatory Compliance Analysis
HB46 is effective immediately as of June 20, 2025, mandating a significant expansion of the Texas Compassionate-Use Program (TCUP) through new dispensing licenses, authorized satellite locations, and pulmonary inhalation products. The legislation imposes a critical July 1, 2025 application deadline for the first tranche of new licenses and establishes strict pre-employment vetting protocols that fundamentally alter hiring practices for all dispensing organizations.
Rep. Ken King·House Bill·Regular Session
Department of Public Safety (DPS) - Licensing & Operations • Department of State Health Services (DSHS) - Condition Petitions • Health and Human Services Commission (HHSC) - Medical Rules & Inhalation Devices
This legislation has regulatory implications for the following Texas businesses and organizations:
Significant regulatory changes (effective 2025-06-20). Review with your legal and compliance teams to understand implications.
Affected business types:
highSignificant operational investment may be required.
JD Key Consulting provides government affairs and regulatory strategy services. We help businesses navigate Texas agencies, understand legislative impacts, and advocate for their interests.
JD Key Consulting provides strategic guidance on Texas regulatory compliance and legislative impact for your business.
Key implementation requirements and action items for compliance with this legislation
JD Key Consulting specializes in Texas regulatory compliance strategy. Work directly with James Dickey—former Chairman of the Republican Party of Texas—to understand this bill's impact on your operations and develop an actionable compliance plan.
Schedule a ConsultationInformation presented is for general knowledge only and is provided without warranty, express or implied. Consult qualified government affairs professionals and legal counsel before making compliance decisions.
This bill's path through the Texas Legislature
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Common questions about HB46
HB46 is effective immediately as of June 20, 2025, mandating a significant expansion of the Texas Compassionate-Use Program (TCUP) through new dispensing licenses, authorized satellite locations, and pulmonary inhalation products. The legislation imposes a critical July 1, 2025 application deadline for the first tranche of new licenses and establishes strict pre-employment vetting protocols that fundamentally alter hiring practices for all dispensing organizations.
HB46 was authored by Texas Representative Ken King during the Regular Session.
HB46 was signed into law by Governor Greg Abbott on June 20, 2025.
HB46 is enforced by Department of Public Safety (DPS) - Licensing & Operations, Department of State Health Services (DSHS) - Condition Petitions and Health and Human Services Commission (HHSC) - Medical Rules & Inhalation Devices.
The regulatory priority for HB46 is rated as "critical". Businesses and organizations should review the legislation to understand potential impacts.
The cost impact of HB46 is estimated as "high". This may vary based on industry and implementation requirements.
HB46 addresses topics including crimes, crimes--drugs, health, health--other diseases & medical conditions and mental health & substance abuse.
Key dates for HB46: Effective date is 2025-06-20. Rulemaking: Adopt rules necessary to implement changes to Chapter 487 (Health and Safety Code), including satellite location security and application review timelines. (2025-10-01); Adopt rules regarding medical devices for pulmonary inhalation and establishing THC equivalence. (2025-10-01). Consult with legal counsel regarding applicability.
HB46 establishes the following penalties: administrative penalty of License Revocation for Failure to begin dispensing low-THC cannabis within 24 months of license issuance, or discontinuing dispensing during the license term.; administrative penalty of License Transfer Prohibition/Denial for Attempting to transfer a license before the transferee and all associated directors/owners/employees pass criminal background checks and are registered.; administrative penalty of Regulatory Violation for Dispensing products containing >1g of THC per package/device or containing non-phytocannabinoids (synthetic cannabinoids).. Consult with legal counsel for specific applicability to your situation.
HB46 primarily affects healthcare providers and medical facilities. These businesses should review the legislation with their legal and compliance teams to understand potential impacts.
JD Key Consulting is an Austin, Texas-based government affairs firm led by James Dickey, former Chairman of the Republican Party of Texas. We specialize in Texas regulatory compliance and legislative strategy for data centers, energy, banking, and manufacturing.
