This time last year, Panama was on track to legally sell its first medical cannabis product before the end of 2024 and – as in all new markets – the frenzy of preparations was hectically underway. New laws and lengthy regulations had private investors spending in a hurry to ensure compliance with all the legal requirements.

There was doubt regarding which route Panama would explore. Would it take the wait-and-see approach that had permitted Panama to incorporate concepts from neighbouring countries while remaining faithful to its strategic geographical advantages when carefully considering and regulating the use of medical cannabis in, and from, Panama? Or would it take a direct-action approach and accept the growing pains that accompany such an approach?

The next 24 months were to be critical in determining whether Panama embraces or squanders this opportunity. Now that the first 12 months have passed, the author can confirm two things: much has changed yet nothing has.

The approach Panama took has been unexpected. The government decided to:

• completely stop, without any justification, everything related to medical cannabis;
• keep patients waiting while the regulations are completely and unilaterally rewritten by the local authorities, with no feedback from the government to patients or licensees; and
• suddenly, without much preview and on a Friday afternoon, publish the new regulations.

In the midst of all this, Panama opted to legalise hemp – although it remains unregulated. Panama also chose to eliminate the prohibition of the use of synthetic tetrahydrocannabinol (THC) in medical cannabis. One can look to more mature markets to investigate the effects of allowing synthetic THC in medical products; it has resulted in a flood of litigation.

The most recent update to the regulation of medical cannabis in Panama – Decree 6 of 4 April 2025 (“Decree 6”) – appears intent on committing the same mistakes as were made in the US and Canadian markets, including delving into all the confusion and litigation currently being waged between the medical cannabis industry and the hemp industry. Before exploring this further, it is worth providing updated responses to two important questions: “How does Panama define medical cannabis?” and “How did Panama reach this point?”.

Definition of Medical Cannabis in Panama

Panama considers cannabis to be a “controlled substance”. Panama defines a controlled substance as any substance mentioned in one of the two international conventions – namely, the United Nations’ 1961 Single Convention on Narcotic Drugs (in which cannabis is specified) and its 1971 Convention on Psychotropic Substances. 

The main laws and regulations governing this subject in Panama define medical cannabis as any product that is derived from the cannabis plant and contains at least 1% THC. Products containing cannabidiol (CBD) but maintaining THC below 1% levels are not considered to be controlled substances. Products containing synthetic THC of any type, as of April 2025, are not prohibited.

The Story So Far in Panama

On 4 April 2025, with no prior notice or consultation with the medical cannabis industry in Panama, the rules regarding medical cannabis use, sale, production and so forth ‒ in or through Panama ‒ were completely rewritten. How did Panama reach this point? After much pressure from local patients’ associations and doctors, Panama took the following steps, leading up to Decree 6.

• October 13 2021 ‒ Law 242 of 13 October 2021 (“Law 242”) is passed by Panama’s legislative branch. Law 242 declares that its purpose is “to regulate the medicinal and therapeutical use of cannabis and its derived products”.
• 1 September 2022 ‒ Executive Decree 121 of 1 September 2022 (“Executive Decree 121”), which regulates Law 242, is published by the Health Ministry of Panama (Ministerio de Salud de la República de Panamá, or “MINSA”).
• 25 September 2023 ‒ a total of 14 companies presented their application to obtain one of the seven available medical cannabis licences in Panama.
• 17 January 2024 ‒ MINSA published Resolution 008, listing the seven companies that were approved for the first seven licences.
• 29 January 2024 ‒ MINSA announced that three out of the seven companies not granted approval for a licence in Panama have presented their first legal recourse, a “reconsideration” of the 17 January 2024 resolution.
• 12 March 2024 ‒ MINSA announced that it was maintaining its previous decision as detailed in its 17 January 2024 communication.
• 28 March 2024 ‒ MINSA announced that all three companies that had presented their unsuccessful reconsideration had presented their second and final executive recourse, an appeal to the Health Minister himself.
• 2 May 2024 ‒ MINSA resolved the appeals presented on 28 March 2024 and declared that Resolution 008 of 17 January 2024 is valid.
• 24 March 2025 ‒ Law 464 of 24 March 2025 (“Law 464-2025”) is passed by Panama’s legislative branch. This law is aimed at “regulating the production, commerce and export of hemp in the Republic of Panama” (see 1.4 Challenges for Market Participants (Legal Uncertainty) for further details).
• 4 April 2025 ‒ Decree 6, which regulates Law 242, overturned Executive Decree 121, Executive Decree 61 and Resolution 925. Decree 6 was published by MINSA.

Current Legislative and Regulatory Landscape

As the foregoing list of developments chronicles, at the beginning of 2024, there were two main bodies of law regulating medical cannabis in Panama (ie, Law 242 and Executive Decree 121). Currently, in 2025, there are four main legal documents that govern this yet-to-operate industry in ‒ namely, Law 242, Decree 6 (overturning Executive Decree 121), Law 464-2025, and Law 419 of 1 February 2024 (“Law 419-2024”) that “regulates medicines and medical devices intended for human use”.

Law 419-2024 was regulated by Executive Decree 27 of 10 May 2024 and reformed all previous laws that regulated medicine for human consumption and the public procurement of medicines, including medical equipment, consumables and devices. Law 419-2024 indicates that medicine that has a valid registration from the pharmacopoeiae of Germany, Argentina, Spain, Greece, Japan, Mexico, China, the EU, the USA and several other territories can expect to receive a Panama Sanitary Registration within ten days of presenting the complete forms and documents to MINSA. Law 419-2024 should, in theory, reduce the waiting time to obtain a sanitary registration from years to days and ‒ in so doing ‒ also reduce the retail cost of drugs and favour patients.

There are multiple other legal documents that can be applied to medical cannabis, such as:

• Law 28 of 28 October 2014 (“Law 28-2014”) and its modifications, also known as the “Rare Diseases Law”, which entails a guarantee of treatment to patients of rare or infrequent illness;
• Law 14 of 19 May 2016  (“Law 14-2016”), which regulates the production, transportation and usage of controlled substances as described in the products included in the United Nations’ 1961 Single Convention on Narcotic Drugs and the 1971 Convention of Psychotropic Substances; and
• Law 203 of 18 March 2021 (“Law 203-2021”), which regulates telehealth.

Although there are many other decrees, resolutions and the like related to this industry in Panama, this section will only concentrate on the most important laws and regulations that relate to medical cannabis: Law 242 and Decree 6. Navigating through newly installed laws that have zero jurisprudence may seem complicated, so it is worth trying to break them down as much as possible to simply matters, as follows.

• Law 242 dictates the four “W”s when it comes to medical cannabis in Panama – ie, “What?” (products can be sold or purchased), “When?” (can it be sold and purchased and for how long), “Where?” (can it be sold and purchased and where can it not), and “Who?” (can sell or purchase medical cannabis).
• Decree 6 dictates the “How”s of Law 242 – ie, how to control, report, grow, produce, import, export, deliver, transport, secure, prescribe, dispense, and so forth.

The reader should not be under the impression that the regulation of this industry is lax in Panama. On the contrary, the regulations are aimed at making sure medical cannabis is not used recreationally.

Law 242 ‒ “What?”

The government of Panama has approved the investigation, production, transformation, importation, exportation, re-exportation and domestic sale of medical cannabis for consumption in Panama and internationally in all of its current forms, with some prohibitions (such as vapes). Further information regarding vapes in 1.4 Challenges for Market Participants (Product Uncertainty).

Law 242 stipulates that there will be two types of licences: fabrication licences and investigation licences. For the first five years, a maximum of seven fabrication licences will be issued.

Current regulations authorise those with fabrication licences to produce, grow, transform, import, export, re-export and commercialise flowers, edibles, pills, beverages and topically used products containing 1% or more THC ‒ all of which are permissible for medicinal use. The list of illnesses for which they can be prescribed has been eliminated via Decree 6, allowing the final decision to be taken by the medic while treating the patient. Consumption of medical cannabis is limited to patients that hold a valid prescription issued by a trained medic.

It is prohibited to produce or sell:

• beverages that combine alcohol and cannabis ‒ the only exclusion to this regulation applies to beverages that use alcohol as a solvent;
• medical cannabis produced in attention-grabbing shapes – no cannabis products in the shapes of animals, people, fruits, or any other shape that may draw the attention of minors;
• promotion/marketing ‒ none is allowed (neither online, nor via traditional channels), with the only exception being educational material that does not directly promote the sale of any specific product, brand or strain; and
• vapes containing medical cannabis.

Growing and transforming cannabis in Panama has been regulated bearing two main objectives in mind: quality and control.

Quality

Panama will only permit the growth and consumption of medical cannabis that is free of harmful chemical products such as pesticides, fungicides, herbicides, and/or chemical solvents or products that may harm public health. Any medical cannabis produced in Panama will require Good Manufacturing Practice (GMP) standards and all fabrication licensees must ensure their operations are compliant with modern GMP guidelines.

Several regulatory bodies are entrusted with powers to inspect and verify strict compliance to quality standards. As one government official recently told the author: “Panama has the world’s best coffee; now we aim to have the world’s best medical cannabis.”

Similar GMP guidelines apply for the transformation of flower cannabis into other products such as edibles, creams and pills.

Executive Decree 121 prohibited the use of any sort of synthetic THC in medical cannabis produced, used or sold in Panama. Decree 6 eliminated the prohibition of using synthetic THC in Panama, paving the way for litigation similar to that found in the USA, Canada and other mature markets concerning the use of Delta-9 and other synthetic psychoactive THC products.

Control

There is plenty of control in Panama. Every plant will be traced from seed to harvest and every product will be inventoried per piece or weight. CCTV systems with face recognition software are an obligation in every room that produces, processes, stores, transports or sells a medical cannabis product, including dispensaries. Under the new regulations, dispensaries are considered as a standard pharmacy and must obtain the same permits and government authorisations as any other pharmacy.

Transporting medical cannabis in Panama will require closed and tagged parcels. Each parcel must have a Global Positioning System (GPS) tracking device and each car that transports the parcels must have a GPS tracking device. A manifesto must accompany each transportation of medical cannabis in Panama and all of the foregoing is subject to review and inspections by the regulatory authorities.

Decree 6 presents minor yet cost-increasing changes in the transportation of medical cannabis. By way of example, prior to Decree 6, containers containing medical cannabis concentrates such as oil could only weigh 4.5 kg at most; Decree 6 changes the maximum weight of each container to 0.5 kg.

Industry employees must be vetted prior to being incorporated on a licensee’s payroll.

One of the main benefits of Panama’s regulations is the authorisation of licensees to import, export and re-export medical cannabis products. Keeping true to its historical nature as the tax-free crossroads of the world, Panama has the potential to develop – in the short term – into the world’s premier tax-free medical cannabis hub, which in turn should facilitate an increase in the amount of products international clients can offer their patients. 

International commerce of medical cannabis is tightly controlled and is only approved to be B2B. This means a licensee from Panama can only purchase from, or sell to, a licensee from another country.

There is no limit on THC or CBD percentages nor cannabis strains permitted for medical use.

Law 242 – “Who?”

This section will concentrate on three “Who”s – namely, who can purchase, who can participate in the industry, and who can sell.

Who can purchase medical cannabis?

In a nutshell, patients and medical establishments (including pharmacies) are permitted to purchase medical cannabis products. Wholesale medical cannabis can only be purchased in Panama by fabrication licence holders (selling among licensees) and pharmacies that have a licence to sell controlled substances.

The retail purchase of medical cannabis is limited to patients with a valid prescription. The prescription can be valid for a maximum period of 90 days and patients will need to register in the National Medical Cannabis Registry (the “National Registry”) and validate their prescriptions. Inclusion in the National Registry has been doubled through Decree 6 and, under the new regulations, membership must be renewed every two years. The National Registry will be synchronised and updated constantly. This will guarantee that a patient cannot purchase more medical cannabis than has been prescribed to them.

Prescriptions may be filled by any pharmacy. Pharmacies, hospitals and dispensaries must retain on file a copy of each prescription they fulfilled, either completely or partially. They are obligated to hold the copy on file for five years.

Who can participate in the medical cannabis industry?

i) Doctors

Doctors have been among main benefactors of Decree 6, for the following reasons.

• Training – previously, all licensed doctors were obligated to take an extensive, and yet to be determined, training course before they could be authorised to prescribe cannabis to patients. Decree 6 eliminates this training completely and transfers the decision and responsibility of prescribing medical cannabis to the doctor. Keeping medical decisions within the doctor–patient relationship is something many in the medical industry will applaud.
• Limitations of prescriptions – previously, Executive Decree 121 listed 23 specific illnesses and “other illnesses that the Medical Cannabis Technical Board will recommend” as candidates for medical cannabis. Decree 6 simplifies this by stipulating that any doctor or veterinarian may prescribe medical cannabis and eliminates the need for the approval of any medical board.
• Patients’ clinical file – Decree 6 simplifies the clinical file doctors keeps for each medical cannabis patient, placing minimums of what information must be held by the doctor instead of burdening doctor with requirement’s  that previously only existed for Medical Cannabis.

ii) Licensees

As previously mentioned, holders of fabrication licences are authorised to produce, transform, import, export, re-export, and domestically sell medical cannabis. Meanwhile, holders of investigation licences cannot commercialise medical cannabis in any of its forms; these licensees can only use cannabis for investigative purposes. The investigation licence is aimed at universities and regional investigation centres and laboratories located in Panama. They will certify the quality, THC and CBD content, and other requirements regarding medical cannabis produced in Panama.

Decree 6 now stipulates that to obtain a fabrication licence one must first obtain an “operations licence” from MINSA. After obtaining an operations licence, the licensee must obtain a “pharmacy licence” for retail distribution of medical cannabis. If the licensee intends to proceed with international distribution, a third “distribution agency licence” might be necessary. If a licencee intends on growing any medical cannabis plants, several Ministry of Agriculture (Ministerio de Desarollo Agropecuario, or “MIDA”) licences will be required.

Decree 6 simplifies and deregulates some aspects of the medical cannabis industry in Panama, but manages to cause confusion regarding others. What was previously one “all inclusive” licence has transformed into an array of options and licences.

iii) Industry associates

Until recently and irrespective of which type of licence a licensee had, all industry employees were obligated to obtain a special Labour Code Identification Number prior to being employed. Decree 6 eliminates the need for this registration of all employees, thereby lowering onboarding costs.

Complete disclosure of every licensee’s corporate structure, shareholders, strategic international partners, and financial capacities ‒ including any changes to these – remains a licensee obligation.

iv) Training entities

Decree 6 eliminates the need for training and education regarding this industry for employees prior to being hired. Whereas Executive Decree 121 mandated  the implementation of a “Suppliers Training Registry” and the obligation for all industry employees to pass lengthy training, Decree 6 takes a more logical approach by eliminating the need to train employees that do not have contact with medical cannabis. No more lengthy medical cannabis training for licensee accountants, auditors, tech support or administrative employees in general.

Who can sell medical cannabis?

Fabrication licensees can sell wholesale to pharmacies, hospitals, and other licensees. They can also distribute on a retail level through their own dispensaries. Pharmacies, hospitals and dispensaries can only sell medical cannabis on a retail level.

Any other sales channels are considered illegal and may constitute an administrative and/or criminal offence.

Law 242 – “When?”

Law 242 stipulated that, once the seven licence winners have been chosen, each of them would have 60 days within which to comply with Executive Decree 121 in respect of security, hygiene, legal paperwork, and GMPs regulating the production, storage and transportation of medicinal products, as well as to request an inspection that will be headed jointly by MINSA and Panama’s Ministry of Security (Ministerio de Seguridad Pública de Panama, or “MINSEG”). Those 60 days have long since passed and, even though the licence winners have passed all inspections, still no licences have been granted.

During the first 24 months of each licence, the licensee will be permitted to import any medical cannabis product from any international supplier, provided the supplier is an authorised medical cannabis seller in their home country. This 24-month period is permitted so that the licensees can promptly attain local supply of medical cannabis and satisfy the local medical cannabis market in Panama.

After these initial 24 months, all medical cannabis products that are sold in Panama must be produced in Panama. This limitation does not apply to importing and re-exporting cannabis products through Panama’s tax-free commerce zones.

If, after the initial ten years, a fabrication licensee is interested in extending their licence, they must request an extension of their licence.

It is worth mentioning that many of the licensees invested hastily and heavily in complying with the allotted 60-day window in order to comply with the now overturned Executive Decree 121. Most of the licensees have passed multiple inspections by MINSA and MINSEG and still have not received their license. Decree 6 does not stipulate this 60-day window for the licensee to be ready for inspection; it would be useless, as all inspections have been completed.

Currently, there is no confirmed date for when medical cannabis will be available for sale in Panama, as no licences have been emitted. Based on previous current local trends, in 2024 the author dared to forecast that the first licensees would be operational before the end of that year. As of spring 2025, the author’s forecast has not materialised. For further details, please refer to 1.4 Challenges for Market Participants.

Law 242 – “Where?”

As regards where medical cannabis can be sold in Panama, the answer is simple: anywhere controlled substances can be sold either B2B or by retail.

Pharmacies, hospitals and licensees are approved for selling medical cannabis. Doctors can neither sell medical cannabis nor prescribe a specific brand.

Delivery via commercial couriers is strictly forbidden. However, patients that cannot fulfil their prescription personally may empower one person at a time to do so on their behalf.

As regards where cannabis may be grown in Panama, only controlled and pre-approved areas such as greenhouses or warehouses will be authorised to grow cannabis. Cultivation sites must be approved by MIDA and MINSEG.

If a fabrication licensee intends on re-exporting medical cannabis, they must be located in a tax-free zone. The fabrication licensee must also re-export from a pre-approved location.

As for the consumption of medical cannabis in Panama, use is intended to be private. Consumption in public spaces such as roads, parks, restaurants, theatres, clubs and the like are prohibited. At work, if an employer approves the use of medical cannabis on their property and has a designated area in which to do so, then the patient may consume their medical cannabis at work.

Decree 6 ‒ “How?”

Decree 6 mandates the “How?”s in terms of Law 242. Most importantly for the local government, Decree 6 determines how to control. In simple terms, Panama’s path to control is through software and technology.

Decree 6 regulates how every medical cannabis product will be grown, imported, produced, exported, sold or investigated in Panama. It regulates the operation of the software and subjects licensees to supervision by the relevant regulatory bodies and to a surveillance system. This system is known as the Tracking and Traceability System (the “System”). The complexities of those regulatory bodies ‒ as well as how they interact with the System, among themselves, and with licensees ‒ are discussed in 1.2 Regulatory Bodies.

One major difference between Executive Decree 121 and Decree 6 is that the previous regulations ordered the entire medical cannabis industry in Panama to operate under one System. Which System was a point of contention, producing dozens of options and valid candidates; Decree 6 changes this. As of April 2025, each licensee can contract the System of their preference, provided the System abides by the regulations of Panama and is approved by the Ministry of Health.

Law 242 and Decree 6 mandate six regulatory bodies to directly and actively oversee the medical cannabis industry. An additional three regulatory bodies will be involved, albeit in a more passive form.

The six active regulatory bodies are:

• MINSA;
• MIDA;
• MINSEG;
• the Ministry of Commerce (Ministerio de Comercio e Industrias, or “MICI”);
• the Customs Authority (Autoridad Nacional de Aduanas, or “ADUANA”); and
• the National Innovation Authority (Autoridad Nacional de Innovacion Gubernamental, or “AIG”).

The three passive regulatory bodies are:

• the Bank Superintendency (Superintendencia de Bancos, or “SUPERBANCOS”); and
• the Insurance Superintendency (Superintendencia de Seguros, or “SUPERSEGUROS”); and
• the Superintendency of Non-Financial Regulated Subjects (Superintendencia de Sujetos No Financieros (SSNF)).

These responsibilities of these regulatory bodies sometimes overlap, as follows.

MINSA

MINSA is the legal governing body supervising and regulating all health-related issues involving humans, including controlled substances. Hospitals, protocols, vaccines, medicines, nurses, pharmacies, medicine approval and Medical Competency Certificates are all encompassed under MINSA’s jurisdiction.

MINSA executes its responsibilities related to medicine for human consumption through the General Directorate of Drugs and Pharmacies (Direccion General de Farmacias y Drogas (DGFD)), which has been designated by MINSA to oversee the complete medical cannabis commercial cycle in Panama. It is the DGFD’s responsibility to oversee the importation, production, transformation, transportation, commerce and local dispensing of medical cannabis for human consumption.

With regard to medical cannabis, MINSA will specifically be responsible for:

• educating doctors and the general public about the positive and negative effects of medical cannabis;
• issuing the licences;
• supervising all stages of medical cannabis in Panama, including growth, production, importation and sale;
• approving the criteria for the System;
• supervising the correct implementation of the System;
• establishing criteria for laboratory tests that will be applied to medical cannabis products sold in Panama;
• receiving the exports estimate from each fabrication licensee – under Executive Decree 121, the estimates were yearly, whereas Decree 6 now requires estimates to be done on a three-year basis;
• receiving the quarterly reports from each investigation licensee;
• developing a national programme for investigating medical cannabis and its uses;
• approvals of the National Registry, including the requisites a patient must complete before being added to the National Registry, as well as the issuance of the special identification all patients must have in order to fulfil their prescriptions;
• establishing criteria regarding which patients can apply for inclusion in the National Registry, as well as how to proceed if a patient is not a Panamanian citizen;
• regulating the prescriptions required for the purchase of medical cannabis – prescriptions are only valid for 90 days;
• approving the importation of any medical cannabis requested by an investigation licensee; and
• approving every exportation of any medical cannabis product produced in Panama, prior to the shipment leaving the country.

Under Executive Decree 121, there were several offices in MINSA that would attend to the medical cannabis industry. The new Decree 6 streamlines the vast majority of MINSA’s responsibilities into the remit of two main offices: the office of the Director General of the Ministry of Health and the office of the DGFD.

MINSA, through Decree 6, eliminated the additional burden imposed on the labelling of medical cannabis products. Previously, there were multiple special requirements for labels of medical cannabis products, whereas now these products must abide by the same labelling requirements as all other medical products.

MINSEG

MINSEG is the legal governing body supervising and regulating all security-related issues such as the police force, the border patrol, the naval services, immigration, illegal drugs, and all things related to firearms. Due to Panama not having an army, navy or air force, MINSEG fills in those voids on a national level.

In terms of medical cannabis, MINSEG will specifically be responsible for:

• supervising the correct implementation of the System;
• approving and ensuring that licensees comply with the security standards described in the regulation;
• approving the security protocols that will be implemented in any establishment that stores medical cannabis;
• verifying that medical cannabis residues or expired products are weighed before they leave storage and are correctly disposed of;
• inspection of the private, in-house version of the System that each licensee must operate, basically validating that all inventory is accounted for;
• approving the external security measures of establishments that will store medical cannabis;
• assisting MINSA and MIDA in their (notified or not) inspections of fabrication licensee’s cultivation and storage areas;
• reviewing industry-wide employee background checks, including employees related to the international strategic partner;
• conducting any necessary criminal record checks on industry employees and, in the case of bedridden patients, the person the patient sends to a dispensary or pharmacy to fulfil their prescription;
• validating the approval of the importation of any cannabis seeds or plants into Panama, provided they have already been pre-approved by MIDA;
• approving every exportation of any medical cannabis product produced in Panama, prior to the shipment leaving the country; and
• receiving reports from licensees in the event they become aware of any plans or actions by third parties aimed at the theft, misuse or illegal sale of medical cannabis products.

The security standards imposed on every licensee are stringent and include the following.

• All entries and exits of places where medical cannabis is stored must have interior and exterior cameras.
• All areas where medical cannabis is weighed, packed, transported or labelled must have cameras.
• One camera must specifically monitor the entrance to secure areas of buildings where medical cannabis is stored.
• All cameras must be high resolution so employees, as well as the products they manipulate, can be easily identifiable.
• Cameras must be able to record the facial features of all (eg, patients, visitors, employees) who enter a place where medical cannabis is stored.
• GPS tracking must be in place for all medical cannabis products, including plants.
• All industry security protocols must be updated.
• Legal action must be taken in the event that protocol violations by licensees or patients merit criminal investigations.

When necessary, the coercive enforcement of the Law 242 and Decree 6 will be one of the responsibilities MINSEG has assumed.

MIDA

MIDA is the legal governing body supervising and regulating all issues related to the national food supply, national agriculture and farm animals. This includes veterinarians and the products they use.

MIDA can and does offer local producers tax incentives, reduced interest rates on farm related loans, and other financial policies aimed at incrementing Panama’s consumption of locally grown products, as well as the exportation of locally produced agricultural products.

In terms of medical cannabis, MIDA’s main responsibilities will be: 

• approving all cannabis seeds and plants prior to their arrival in Panama;
• developing procedures and approving protocols for the use and investigation of cannabis seeds and plants, as well as medical cannabis for veterinarian use;
• authorising each fabrication licensee’s cultivation plan (including location), as each licensee must present a yearly estimate of their expected cultivation yield ‒ per strain ‒ prior to planting a seed;
• analysing, preventing and mitigating the risk of plagues arriving in Panama through the importation of cannabis seeds and plants;
• establishing the phytosanitary protocols that will be followed by the fabrication licensees;
• executing inspections of medical cannabis production sites to ensure phytosanitary protocols are followed and that licensees have proved MIDA with correct information;
• supervising the quarantine of cannabis plants or seeds, in case it is deemed necessary;
• including cannabis seeds in the National Seed Commission database, which registers all seeds (and their importers) in Panama;
• verifying that the licensees comply with the technical sheet for imported plants or seeds, as well as ensuring no harmful pesticides or chemicals are used by licensees;
• supervising the cultivation of medical cannabis in Panama and ensuring GMP standards are upheld;
• supervising the System;
• approving any products containing cannabis that are intended for veterinary use; and
• issuing a Certificate of Agricultural Exports for any medical cannabis product produced in Panama, prior to the shipment leaving the country.

MICI

MICI is the legal governing body that administers Panama’s commercial and overall industrial aspects, including the national and international promotion of Panama-based commerce. It also supervises, approves and regulates all the tax-free commercial zones in the country; these tax-free commercial zones should be thought of as huge bounded warehouses (some of which are the size of smaller cities). The Colón Free Zone, the largest such zone on Panama’s Atlantic coast, is the world’s second-largest tax-free zone. In 2024, it boasted commercial transactions totalling more than USD25 billion dollars.

MICI now has two specific roles to play in this industry:

• approving the incorporation of a licensee into a tax-free commercial zone; and
• promoting medical cannabis products that originate in Panama or take advantage of Panama’s strategic geographic position and tax incentives, using the country as the logistical hub it is.

Decree 6 specifically indicates that only fabrication licensees that are established in a tax-free zone can re-export medical cannabis products.

AIG

The AIG has one specific role to play in the medical cannabis industry: ensuring the System and the National Registry is secure and online. This includes data security related to patient confidentiality and rights, System and National Registry access, and maintenance.

During the reign of Executive Decree 121, the AIG had a much more “hands on” approach. It was in charge of creating or contracting the System and working on its smooth implementation in Panama. In the three years between the publication of Executive Decree 121 and the publication of its replacement, Decree 6, the AIG failed to accomplish its specified goals.

By 2025, three years after the publication of Executive Decree 121, no System had been created, purchased or contracted. Nor was there any sign of the AIG moving forward on anything related to the System. Decree 6 took all control over decisions related to the System from the AIG and transferred it to the licensees ‒ all of which have declared their intent to use established software that is currently in use in other countries.

SUPERBANCOS, SUPERSEGUROS and SSNF

These three more passive governing bodies will oversee the medical cannabis industry just as they oversee almost all national industries. There is one exception, however; fabrication licensees can expect additional scrutiny, at least initially.

SUPERBANCOS will be influential in deciding how much access the medical cannabis industry will have to the banking industry, including national accounts, international accounts, financing, and payroll and credit card processing. Even though a year has passed since the previous instalment of this guide, SUPERBANCOS has yet to clarify its policy on the medical cannabis industry. As such, licensees have been left guessing as to how they will charge patients and pay employees and suppliers once they start operations.

SUPERSEGUROS will be important in the regulating of private medical insurance companies and their coverage of medical cannabis. The latter is currently unclear.

The SSNF will oversee the adherence of fabrication licensees to local compliance and KYC norms. However, the SSNF will not play a specific role with regard to medical cannabis.

Given that Panama’s medical cannabis industry is still on paper and not yet operational, self-regulatory bodies as such are yet to take on any active powers in the industry. The closest thing to self-regulatory bodies in Panama are several organisations that have supported patients’ claims to access medical cannabis, assisted in the creation and implementation of Law 242 and Executive Decree 121, and remain active in promoting medical cannabis in Panama.

Involvement of these groups in the creation of Decree 6 was neither requested nor permitted; Decree 6 was an executive decision that consulted none of these or other patient- or industry-related groups. Four groups, including the industry guild, deserve special mention and are listed in the chronological order in which they became active in promoting medical cannabis.

Fundación Luces (Lights Foundation)

Founded by Panamanian-born epilepsy specialists renowned as worldwide leaders in their field, this non-profit foundation has one aim: to assist epilepsy patients in overcoming their illness through education and innovative treatments. Several of the Lights Foundation’s members are or were practising medics in the USA’s best hospitals and had been prescribing medical cannabis to their patients for several years, reporting extraordinary successful outcomes for their patients.

The Lights Foundation was the pioneer in medical cannabis legislation in Panama and instrumental in getting legislation finally approved. It donated doctors’ time to meet with governmental authorities, elected officials, lawyers, and ‒ of course ‒ patients.

The reputable board of directors of the Lights Foundation was key to capturing the attention of three different Panamanian Presidents, three distinct legislative branches, and hundreds of doubtful local doctors. The Light Foundation has the support of several patient associations, local celebrities, a wide array of doctors, and ‒ through continuous educational efforts combined with real case success ‒ managed to apply enough pressure to get cannabis even considered as a viable medicine alternative for patients.

The Lights Foundation has been actively involved in the legislative process concerning medical cannabis in Panama for almost ten years. It is expected to remain involved once the industry starts operating.

ANPEMUFA

A few years after the Lights Foundation started pressuring local authorities to approve legislation related to medical cannabis, the National Association of Multiple Sclerosis and Neuromyelitis Optica Patients (Asociación Nacional de Personas con Esclerosis Múltiple, Familiares y Amigos, or “ANPEMUFA”) joined the cause and has been an active player ever since. As a non-profit organisation, ANPEMUFA states its primary goal as “ensuring that people who suffer from the illness have access to alternative treatments and solutions to the challenges of living with multiple sclerosis”.

ANPEMUFA, composed mainly of patients and their families with the support of national and international doctors, has also invested time and effort in explaining the need for regulating medical cannabis to uninformed doctors, lawyers and government officials. More importantly, ANPEMUFA provides living proof that many patients report better and faster results using cannabis than using certain pharmaceutical products.

If the Lights Foundation is constituted mainly by renowned medics looking at options to help their patients, ANPEMUFA is ‒ on the contrary ‒ constituted mainly by vocal patients looking at options to help their medics legally prescribe medical cannabis. ANPEMUFA is expected to remain involved in the industry once it is operational with regard to verifying quality, supply and pricing.

National Lawyers Union

Panama does not have a Bar Association as in other countries; the closest thing is the National Lawyers Union (Colegio Nacional de Abogados, or CNA), which is a non-profit union of lawyers. The CNA is commonly called on for advice by law-makers and private citizens and assists in fine-tuning legislations and forecasting difficulties in applying laws. Any work done by a lawyer for the CNA is pro bono, non-political, and should have altruistic intentions. The CNA operates through commissions and each commission has its own board of directors that report directly to CNA’s president.

In early 2024, for the first time in its history, the CNA formed the Commission for Medicinal Controlled Substances. This commission has two main goals ‒ namely, to assist patients in legally obtaining access to the medicines that their doctors prescribe (especially medicines that are controlled substances) and to ensure local laws that assist patients’ rights are duly enforced.

The CNA’s Commission for Medicinal Controlled Substances has held multiple meetings with patients, doctors, law-makers and industry leaders. In doing so, it serves as a neutral meeting ground to present contrary opinions, discuss each perspective and reach common ground.

The CNA should remain active in their support for patients, patient rights, and doctors throughout the next few years. It is also expected to propose potential beneficial modifications to the current regulations.

Medical Cannabis Guild

This organisation is agreed upon, but yet to be formed. The seven fabrication licensees have agreed on forming a guild that aims to guarantee three things: quality, supply and compliance.

The common worry among the seven licensees is that one (or more) of them will commit an offence by design or by mistake, such as falter in compliance, err in reporting, supply low-quality products, or worse. As medical cannabis is new and heavily regulated in Panama, the potential mistakes of one licensee will undoubtedly affect the other six.

Licensees cannot market their products in Panama and are only allowed to promote medical cannabis through the education of the population, including the doctors. For this reason, a particular effort is being placed on promptly training local doctors and reducing the historical stigma that exists in Panama in relation to cannabis. 

If negative media is constantly circulating in Panama regarding the misuse of medical cannabis, or mistakes by the newly allotted licensees, then doctors will shy away from prescribing it. The licensees’ plan to mitigate these risks is to create a guild that shares administrative responsibilities, meets regularly, and ensures and verifies that quality standards are not lowered and that all seven licensees adhere to all laws and regulations.

The most notable challenges that market participants currently face, and will remain facing in the near future, is uncertainty.

Product Uncertainty

Cannabis vape pens represent a significant percentage of the industry’s market share, with numbers varying widely between 15% and 40%, depending on the country or state, market age composition and several other factors. What is agreed upon by most international industry participants is that medical cannabis vape pens are here to stay.

On 30 June 2022 Panama published Law 315, which aims at educating the general population about the hazards of e-cigs and similar products. At the same time, Law 315 prohibits the use or sale of electronic equipment such e-cigs, vaporisers, tobacco heating systems and similar products in Panama. That meant that no vapes can be legally sold in Panama, nor can they be used in public spaces.

Law 315 did not differentiate between nicotine-containing products and products that do not contain nicotine. No distinction was made between a vape device designed for tobacco and one designed for cannabis.

On 11 June 2024, the Supreme Court of Panama declared Law 315 to be unconstitutional. By doing so, the law was nullified. Since June 2024, one can find nicotine and non-nicotine vapes quite easily at gas stations, supermarkets and convenience stores, as well as through delivery services; they all offer a wide array of vape options. Vapes are available at low prices in many flavours and even more colours.

Even though vapes that do not contain cannabis or CBD are available everywhere in Panama, Decree 6 strictly prohibits the sale of medical cannabis vapes. Indeed, it does so twice. The legal basis for permitting the sale of recreational nicotine vapes in Panama, while at the same time prohibiting the sale of medical cannabis vapes in Panama, will be surely challenged in the Supreme Court using similar arguments as the 11 June 2024 ruling.

All of the foregoing is important when considering two things:

• Panama boasts one of the lowest rates of tobacco consumption worldwide, hovering at around 7% of the population; and
• any smoking, especially cannabis, is considered harmful and entails a strong, historical social stigma.

Approximately 30% of Spaniards and Germans smoke cigarettes, as do almost 20% of Americans and Canadians. Panama is at 7% and dropping fast. Smoking is prohibited in restaurants, casinos, concerts and public spaces in Panama. All this means one can visit Panama for a full week and probably only see one or two people per day smoking cigarettes.

Panamanians are not accustomed to seeing people smoke in public, nor are they used to the smell of burnt tobacco in their midst. Smelling cannabis smoke, or seeing a patient smoke cannabis in any place, will immediately draw the attention of passers-by. Given that patients have enough to deal with, adding more stigma to their treatment is not beneficial.

The solution for many patients is medical cannabis vapes. They enable immediate discreet dosage of medical cannabis, with practically no smell, and thereby help to maintain patient privacy.

So, what happens if a specialist prescribes that medical cannabis should be consumed via vape pen instead of in edible or smokable form? This uncertainty is probably going to make its way through the court system in the next few months.

Banking Uncertainty

Panama’s currency is the balboa, which is pegged at par (1:1) to the US dollar. The Constitution of Panama prohibits a central bank or the issuance of paper currency. In short, using bills in Panama means using US dollar bills. When one transfers money into or out of Panama, it is done in US currency.

Panama has 40 “general licence” banks/first-tier banks. Most are Panamanian or regional banks, six are international banks, and two are national, government-owned banks.

The exact same issues that are affecting the cannabis industry in the USA are affecting the industry in Panama. All Panama’s banks depend on their banking correspondents in the USA for access to international markets and the SWIFT (Society for Worldwide Interbank Financial Telecommunication) wire system. If the correspondent bank in the USA is unwilling to open an account for a dispensary in California or Boston, it is far less willing to allow a Panamanian bank to use it to transfer proceeds from medical cannabis to or from Panama.

The two government-owned banks, Banco Nacional and Caja del Ahorro are in a complicated position. Panama has no federal system; therefore, the same government that charges the licensees for their licence fee is the same government that owns these two banks. That being said, the uncertainty here concerns why a government-owned bank would not open a bank account for a company that holds a government-issued medical cannabis licence and whether private banks will do so.

Running a cash-only medical cannabis enterprise in Panama would be complicated, costly, risky and a compliance nightmare for all involved.

Insurance Uncertainty

Similar to banks, insurance companies are very cautious when considering medical cannabis. Patients that require very specific strains of medical cannabis (normally with less than 1.5% THC) have complained that the monthly cost of medicines (which they are forced to smuggle into Panama) can exceed USD500 per month. In a country where the monthly minimum salary is approximately only USD600 per month, one can understand the need for public or private medical insurance to cover this medication cost.

Although Law 28-2014 mandates that “public and private insurance companies have the responsibility to attend” to patients who have rare diseases, there is no obligation to do so regarding other patients. Law 28-2014 also allows pharmaceutical companies that donate their products directly to patients to deduct the cost of these products from their income tax; however, while Decree 121 allows the donation of medical cannabis to patients via hospitals, Decree 6 specifically prohibits this.

Will public or private insurance companies cover medical cannabis prescriptions? Will local suppliers be permitted to donate part of their production to patients in need? Eliminating these uncertainties will help patients who require medical cannabis but cannot sustain the monthly costs of medication.

Bureaucratic Uncertainty

Yet another year has passed and the bureaucratic uncertainty has increased. As noted in 1.1 Primary Laws & Regulations, the medical cannabis legislation in Panama comprises multiple laws and regulations – many of which overlap on occasion. This causes uncertainty and creates the risk of incompliance due to error rather than through ill will.

Even though the medical cannabis legislation comprises hundreds of pages of laws and regulations and dates back to October 2021 (and its former regulations, dating back to September 2022, were in force for almost three years before being overruled and completely modified in April 2025 by Decree 6), not a single medical cannabis licence has been issued and not a single prescription has been filled. During multiple meetings with MINSA, licensees have been left wondering what the future holds and what will happen to their multimillion-dollar investments.

The previous government of Panama, the Cortizo government, passed Law 242 and Executive Decree 121 but did not implement either. The current government of Panama, the Mulino government, has been in power for 11 months, has held multiple meetings with the licensees and has created new regulations via Decree 6 ‒ yet still has not permitted a single patient to fulfil a single prescription.

MIDA has not yet established a protocol for the importing of cannabis seeds, nor the growing of cannabis in Panama.

The training of the police force in respect of medical cannabis has not been completed, prompting questions as to what would happen were a patient stopped during a routine traffic stop and medical cannabis found in their possession. Panama has a very strict policy regarding narcotics and leniency is seldom shown. Educating the police force and changing their perspective to one of understanding that a patient is not the same as a recreational user will be paramount to eliminating the current stigma and preventing discomfort among patients.

Calendar Uncertainty

Based on previous uncertainties, it seems that – even if all seven licences were issued tomorrow – Panama would still not be able to supply its patients for several more months (or possibly even years).

Currently, local industry participants cannot :

• plan their cultivation cycles;
• reserve ready-to-ship products from overseas suppliers;
• import machinery needed in the industry;
• hire employees (as they are not yet trained); and
• lease commercial space for dispensaries.

All the foregoing activities should, under normal circumstances, be part of a well-developed business plan; however, this is impossible owing to uncertainty regarding when sales will be available. Even if licensees were to face no other issues regarding banking in Panama, SUPERBANCOS and the SSNF require a formal business plan to be delivered to the bank before the licensee’s bank account can be opened. Although local authorities are working diligently to cut delay times, no business can plan without a calendar and clear dates on hand.

Panama’s Law 242 obligated every licence applicant to include a reputable and experienced international partner in their corporate structure. The vast majority of these international partners are US- or Canada-based companies ‒ some of which are listed on the US stock market. Panama has bilateral treaties with the USA regarding protecting American investments in Panama. Those multimillion-dollar investments appear at risk and far from protected.

Panama would be wise to prevent further adverse situations with the U.S.A. and other international partners,  by reading daily news one can notice that, under the current Mulino and Trump administrations, Panama -U.S.A. relations are not at their prime.

Legal Uncertainty

On 24 May 2025, Panama passed its “Hemp Law”, Law 464-2025 – a short, seven-page law that is still unregulated but has caused much uncertainty in the market. Medical cannabis licensees in Panama fear their investments are at risk based on the current ongoing litigation concerning hemp and medical cannabis in other markets. Adding yet more governmental confusion to a hyper-regulated market that has yet to launch after years of private investments and modified regulations is far from the ideal situation in which to attract further investments into Panama.

It said that a smooth sea never made a skilled sailor. In that case, Panama may need some life jackets, as the water ahead appears turbulent.

Administrative Compliance

Panama’s multiple and overlapping cannabis regulations are reminiscent of when the Foreign Account Tax Compliance Act (FATCA) regulations passed in the USA in 2010 were imposed on Panama and its banking sector a few years later. Overnight, the overwhelming majority of Panamanian banks decided to unilaterally stop working with American citizens. Accounts were closed and new accounts were rejected. Accounts were closed and new accounts were rejected. Getting an American to sign on their Panamanian spouse’s Panamanian checking account, in a Panamanian bank, was near impossible. 

The reason was not based on anti-American sentiment nor anything similar. On the contrary, Panamanian banks wanted American clients and wanted to comply with FATCA. The issue was fear on the part of Panamanian banks; the FATCA regulations were long, complex, and hard to understand. The banks, despite wanting to comply, did not know how to and feared that an omission due to lack of clarity would entail fines or – even worse – accusations that the bank was assisting US citizens to evade US laws.

A simple solution was swiftly devised. The solution was to cease all work with American citizens unless the transactions were financially large enough to merit such a risk.

Today, the cannabis industry in Panama is very similar. There is a common fear among all licence holders. Although they all claim to be investing heavily in compliance and want to ensure complete adherence to the local norms and regulations, licensees all fear that ‒ owing to the volume, overlap and complexity of the laws – they will falter on some technicality and get fined or even prosecuted. Law 242 and Decree 6 describe a long list of monetary sanctions that can be imposed on licensees in the event they falter – although this also leaves the door open for criminal investigations.

Changing regulations without any prior notice does not help eliminate the compliance risk.

Criminal System

Panama switched criminal systems in late 2016, eliminating the previous inquisitorial criminal system and implementing a new accusatory criminal system. Previously, defendants had the right to try and prove their innocence, whereas now you they are presumed innocent until proven guilty.

The system may have changed but not necessarily the people in it. Many prosecutors come from the old system, have been trained in that system, worked inside that system for 20 years, and today still hold positions of importance in the new system. One of the downfalls of the current criminal system is that prosecutors and/or district attorneys bear no responsibility for their actions, meaning that a prosecutor can present frivolous charges against a person, start an investigation that takes years, take an undocumented case to court and lose that case in an overwhelming manner, then go to work the next day as though nothing happened.

This is because there are no ramifications for the prosecutor, which is worrisome because in Panama simply having one’s name mentioned in a criminal investigation can swiftly lead to bank accounts being closed, commercial ties being suspended and assets being frozen. This is relevant to the medical cannabis industry because, if one uninformed and uneducated prosecutor decides to open an investigation into a licensee with zero evidence of wrongdoing, that licensee will be under a microscope until the investigation is closed due to lack of evidence or until the licensee triumphs in court. Training prosecutors should be as important as training industry employees, as both can have an adverse effect on the industry.

AML Regulations

Panama has an abundance of AML regulations. Anyone who considers they can walk into a bank in Panama with USD20,000 in cash and open a bank account in less than a month has obviously not been to Panama and is uninformed.

Most of Panama’s AML regulations are aimed at controlling the flow of cash in and through Panama. The Criminal Code describes 37 different criminal offences that can lead to money laundering – all of which carry a prison sentence of between five and 12 years.

Every company in Panama that receives more than USD10,000 in cash in a transaction needs to report that transaction to a specialised government agency. Every real estate transaction, even if it is 100% purchased through a mortgage, must be reported to the same entity.

Obligating the cannabis industry to operate without banks will be counterproductive. How can Panama enforce all the positive and well-intended AML regulations while obligating the licensees to operate using only cash? Panama’s medical cannabis industry is estimated to rake in anywhere between USD300 million and USD600 million domestically per year. Such amounts of cash pose a security risk – licensees would not wish to have such amounts on hand or face the problem of its secure storage.

AML regulations and their compliance will be difficult if licensees cannot use digital cash services, credit cards and banks in general. Non-compliance with AML laws is a criminal offence that leads to a money laundering investigation. It is a vicious cycle with no proposed exit route.

There are three regulatory bodies that are entrusted with enforcing compliance and applying penalties Panama’s medical cannabis industry: MINSA, MIDA and MINSEG.

MINSA

MINSA is the main regulatory body and, as such, the institution with the most oversight and penalty-imposing powers. MINSA can impose three types of penalties ‒ namely, penalties for minor infractions, penalties for major infractions, and penalties for severe infractions.

Minor infractions

MINSA may fine a licensee anywhere between USD500 and USD5,000 per each minor infraction. There are currently 12 minor infractions, including:

• non-compliance with the requirement to submit monthly reports to MINSA on time;
• presenting incomplete reports;
• minor sanitary violations;
• failure to notify MINSA of administrative changes such as changes to the licensee’s operating hours or location; and
• storing medical cannabis outside the licensee’s secured areas.

Major infractions

MINSA may fine a licensee anywhere between USD5,001and USD15,000 per major infraction. There are currently 29 major infractions, including:

• fulfilling incomplete or altered prescriptions;
• presenting inventory discrepancies between what the licensee has in stock and what they should have in stock;
• impeding MINSA investigations;
• presenting import or export documents that differ from the actual products being imported or exported;
• altering prescription information being fed into the System;
• transporting medical cannabis without completing the established protocols;
• failure to inform MINSA of the theft or loss of any products;
• purchasing medical cannabis from unauthorised sources; and
• failure to inform MINSA of changes to the licensee’s corporate structure.

Severe infractions

MINSA may fine a licensee anywhere between USD15,001 and USD$25,000 per each severe infraction. There are currently eight severe infractions, including:

• producing or selling contaminated, altered or expired products;
• dispensing medical cannabis without a prescription;
• falsifying information in reports or in the System;
• repeating major infractions; and
• interfering with MINSA’s inspections.

The final penalty amount to be imposed is decided by MINSA after considering:

• the damage caused by the infraction;
• the benefits obtained by the infraction;
• whether the infraction was intentional or negligence-based; and
• whether or not the licensee has previously committed the same infraction.

MIDA

MIDA can impose penalties on licensees ‒ specifically, with regard to the cultivation division of their operation. MIDA’s powers only encompass the agricultural aspect of medical cannabis, however. As such, MIDA is in charge of ensuring that:

• no harmful chemicals are used;
• only approved seeds are used;
• agricultural GMPs are strictly followed; and
• the complete cultivation process – from seed to flower – is supervised.

Penalties can be imposed by MIDA but there is no distinction between the penalties MIDA applies to fruits and vegetables grown in Panama and the penalties it applies to medical cannabis.

MINSEG/Public Prosecutor

While MINSA and MIDA are entrusted with applying monetary penalties (and possibly licence suspensions) in the case of lax compliance by licensees, MINSEG will oversee security compliance of each medical cannabis product sold in Panama, including verifying traceability.

The public prosecutor’s office is responsible for interpreting whether these infractions are of a criminal nature or not. MINSA may impose a fine on a licensee for dispensing medical cannabis to a person without a prescription but, given that this is also a criminal offence in Panama, the offender may incur potential personal liberty restrictions in addition to a monetary fine.

The main international cross-jurisdictional issues currently faced by Panama concern assurance of international compliance and respect for other countries’ authority. Panama requires that all local licensees work only with valid licensees from other countries. A licensee in Panama can purchase products from a supplier anywhere in the world, with the sole condition that supplier is licensed to sell medical cannabis in their home country. The same applies with regard to selling medical cannabis from Panama to other countries – local licensees are free to sell to any country in the world, as long as their client is authorised by their home country to purchase medical cannabis.

Any transaction involving Panama and the importation or exportation of medical cannabis will need to be declared and validated by Panama and the partner country prior to any products arriving in or leaving Panama.

Regarding national cross-jurisdictional issues, the main issue concerns how the responsibilities of MINSA, MIDA, MINSEG and the System overlap in some cases. This overlap can lead to repetitive reporting, an increase in paperwork, and confusion over to whom a licensee must report. By way of example, when an industry employee is hired at any level, the potential employee must first obtain a Labour Code Identification Number from the Ministry of Labour before completing a course with a certified training entity. The employee must then be submitted to scrutiny by MINSEG and the employer must be declared to MINSA in the System. If the employee works in the cultivation section of the business, they must also be registered with MIDA.

Several legal elements continue to affect access to medical cannabis in Panama, as follows. All should have been resolved prior to ‒ or, at the latest, during ‒ 2024.

The System Is Not Operational

The System is not yet operational. In 2024, the System was going to be implemented by the AIG; however, this recently changed, sending all licensees hunting for a System that they believe would be approved by MINSA and MINSEG (even though the exact standards of the System have yet to be established).

The National Registry, a module of the System that will log all patients’ use of medical cannabisis, is also not yet operational – meaning there are no approved medical cannabis patients. This indicates that, even if the product were available, it would still be illegal to dispense.

In 2025, the National Registry was renamed ‒ through Decree 6 – as Programa Nacional para el Estudio y Uso Medicinal del Cannabis y sus Derivados (PNEUCAM), which translates as “National Programme for the Study and Medicinal Use of Cannabis and Its Derivatives”. New name, same situation: still not online.

Insurance Coverage

A significant number of patients will receive a prescription that will be too expensive for them to fulfill without making use of medical insurance.

Will the public healthcare system supply cannabis? Will private medical insurance companies cover medical cannabis? There are simply no answers yet. In theory, national and private insurance companies must both cover medical cannabis; however, it is unclear how they will do so while cannabis remains under Schedule I.

Prescription Fulfilment by Third Parties

In case of bedridden patients, patients with limited mobility, or patients in palliative care, if a doctor prescribes medical cannabis, the patient cannot go to a pharmacy or dispensary to get the prescription fulfilled. The patient can send a person to do this for them, but that person has to be registered in the National Registry and must have been approved by MINSEG after presenting a clean criminal record, which can all be troublesome.

Decree 6 specifies how patients who are under professional care – or those who are still minors ‒ can obtain their prescriptions. Decree 6 leaves a gap when it comes to situations in which the patient is an elderly person who is not under professional care but instead lives at home with their family. Their family members must obtain a court order to be authorised to fulfil a medical cannabis prescription. This complicates an already complicated situation.

Until April 2025, Panama’s regulations only mentioned one non-controlled cannabinoid – namely, CBD. There was no limitation on edibles containing CBD, as long the final product did not contain 1% or more THC. All other medical cannabis products were strictly prohibited from being used in food intended for human consumption.

Decree 6 presents a major shift in this policy. It has completely eliminated the prohibition of using medical cannabis as an ingredient in products registered as food for human consumption.

There is no current legal action or legislative appetite to decriminalise cannabis in Panama, much less promote its recreational use. If and when a rescheduling in the classification of cannabis is approved by the US Drug Enforcement Agency, then Panama may perhaps feel enticed to follow suit. At the moment, nothing indicates any intention on Panama’s part to decriminalise the use of cannabis products containing more than 1% THC.