By Sara Gullickson, Founder & CEO, The Cannabis Business Advisors
The DEA registration process for state-licensed medical cannabis operators is shining a light on an often-overlooked part of compliance: standard operating procedures. Many operators expected the biggest challenge to be gathering all the documentation needed to complete their registration. Instead, the process prompted a more important question:
Do our standard operating procedures still reflect how our business actually operates today?
DEA registration is now part of the conversation, and the application process requires operators to gather and submit a significant amount of business, licensing, facility, ownership, and operational information. While the next steps in federal policy are still uncertain, the lesson is already clear: cannabis businesses should not wait for a regulator, auditor, investor, or federal agency to discover that their documentation is out of date.
Across the country, businesses developed SOPs to satisfy state licensing requirements. Those documents helped secure licenses, pass inspections, and establish compliant operations. But businesses don’t stand still, and not every state-required SOP aligns with the level of documentation operators may need as they evaluate federal DEA registration.
Teams grow. Technology changes. Processes improve. Facilities expand.
Many operators have invested in new inventory systems, updated security procedures, or changed how products moved through their facilities. The operational improvements happened quickly because they strengthened the business. Months later, many realized their written procedures still described the old way of doing things. The business had simply evolved faster than its documentation.
It’s a form of documentation drift: the gradual disconnect between how a business actually operates day to day and what its written procedures say.
The DEA registration process gave many businesses a reason to compare written procedures against their current operations. Some found opportunities to strengthen recordkeeping. Others revisited inventory controls, chain-of-custody documentation, surveillance review procedures, employee training records, or routine compliance practices.
For many operators, the process became less about completing an application and more about determining whether their documentation accurately reflected the business they were running.
What many discovered wasn’t a lack of compliance. It was an opportunity to bring their written procedures back in line with the business they had built. That distinction matters.
Over the past several years, cannabis operators have invested heavily in technology. Seed-to-sale platforms, digital inventory systems, surveillance technology, electronic training records, and compliance software have fundamentally changed how many facilities operate.
Those systems aren’t separate from compliance anymore. They’re how compliance happens every day.
Those investments make businesses stronger. As operations change, written procedures should evolve with them.
SOPs are most effective when they’re treated as living operational tools rather than static compliance documents. They should support employee training, create consistency, reduce organizational risk, and accurately describe how work is performed throughout the organization.
One frequently asked question is how often SOPs should be reviewed.
There isn’t a universal answer because every operation evolves at its own pace. Implementing new technology, expanding a facility, introducing a new product line, changing security protocols, or redesigning workflows are all good reasons to revisit existing procedures.
The more valuable question isn’t, “Do we have an SOP?”
It’s, “If someone walked through our facility today, would our SOPs accurately describe what they would see?”
That shifts the conversation from checking a compliance box to building a stronger operation.
The operators who navigate inspections, audits, investor due diligence, and regulatory reviews most successfully aren’t the ones with the largest compliance manuals. They’re the ones whose written procedures accurately reflect how the business operates every day.
Federal policy and technology will continue to evolve. Successful operators will evolve too.
The best time to identify documentation gaps isn’t when an inspector, auditor, investor, or regulator points them out. It’s while you’re making operational improvements.
Strong documentation isn’t about preparing for the next inspection.
It’s about making sure the business you describe on paper is the same business you’re running day-to-day.
About Sara Gullickson
Sara Gullickson is the Founder and CEO of The Cannabis Business Advisors, a cannabis consulting firm specializing in licensing, compliance, operational readiness, DEA registration support, SOP development and strategic growth. Sara has spent more than a decade helping cannabis businesses navigate complex regulatory requirements and build the systems, documentation, and operational infrastructure needed to operate successfully in a rapidly evolving industry.
For information, visit www.thecannabisbusinessadvisors.com
