
Florida cannabis & hemp
Florida cannabis real estate, and the hemp cliff that actually matters
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Is there a Florida cannabis property market?
Florida licenses only vertically-integrated Medical Marijuana Treatment Centers, which must cultivate, process and dispense themselves — so 28 licensees control all 766 dispensary locations and there is no third-party cannabis property market. The active Florida story is H.R. 5371, signed 12 November 2025, which narrows the federal hemp definition effective 12 November 2026.
Program data
Florida medical marijuana, in current numbers
~57%
Footprint held by the top five operators
Trulieve, MÜV, Curaleaf, Ayr, Surterra — Trulieve alone at 169 locations.
Top five Florida MMTC operators by dispensary footprint
Source: Florida OMMU ·| Operator | Dispensary locations |
|---|---|
| Trulieve | 169 |
| MÜV (AltMed) | — |
| Curaleaf | — |
| Ayr Wellness | — |
| Surterra / Parallel | — |
TODO (data): confirm per-operator location counts for MÜV, Curaleaf, Ayr and Surterra from the OMMU weekly update before launch. Trulieve at 169 is confirmed.
Structure
Why vertical integration removes the brokerage market
| Michigan | Florida | |
|---|---|---|
| License model | Separate licenses for grower, processor, retailer, transporter and lab. | One license type — the MMTC — which must cultivate, process and dispense itself. |
| Market participants | Hundreds of independent licensees. | 28 licensees, 25 actively dispensing. |
| Adult-use | Legal since 2018 under MRTMA. | Medical only. |
| Third-party property market | Deep. Operators buy, sell and lease buildings from each other constantly. | Effectively none. Expansion is MMTC-directed site selection, not operator-to-operator transactions. |
| Where the brokerage work is | Cultivation, retail, receivership, license-adjacent acquisitions. | MMTC site expansion, conventional CRE, and hemp-sector repositioning. |
We say this plainly because most firms won't: if you are looking for a Michigan-style cannabis property market in Florida, it does not exist. What we do in Tampa is investment sales, sale-leaseback and net-lease work — plus the hemp problem below, which is genuinely cannabis-adjacent brokerage with a deadline.
H.R. 5371 — the hemp cliff
12 November 2026
H.R. 5371, signed 12 November 2025, narrows the federal hemp definition effective 12 November 2026, reclassifying intoxicating hemp-derived cannabinoid products as marijuana under federal law.
Timeline
- Signed
- Effective
- Effect
- Narrows the federal hemp definition; intoxicating hemp-derived cannabinoid products are reclassified as marijuana under federal law.
What we do about it
- Lease restructuring and early termination negotiation for hemp operators
- Re-tenanting strategy for landlords with hemp-sector exposure
- Repositioning industrial hemp manufacturing space to conventional use
- Disposition where the operating business cannot survive the reclassification
Questions
Florida cannabis and hemp questions
- Is there a cannabis real estate brokerage market in Florida?
- Barely, on the medical side. Florida licenses vertically-integrated Medical Marijuana Treatment Centers that must cultivate, process and dispense themselves, so there is no third-party license-and-property market comparable to Michigan's. Real estate activity is MMTC-driven site expansion, not operator-to-operator transactions.
- What is an MMTC?
- A Medical Marijuana Treatment Center — Florida's single license type, which requires the same entity to cultivate, process and dispense. Vertical integration is mandatory, which is why 28 licensees control all 766 dispensary locations statewide.
- What happens to Florida hemp THC businesses in November 2026?
- H.R. 5371, signed 12 November 2025, narrows the federal hemp definition effective 12 November 2026 and reclassifies intoxicating hemp-derived cannabinoid products as marijuana federally. Tampa Bay THC-beverage retailers and hemp manufacturers face closure, repositioning or lease restructuring on that date.
Keep reading
The rest of the cannabis desk
Cannabis practice
How C3 CRE brokers licensed cannabis real estate, and why marketplaces don't close these deals.
ReadMichigan cannabis real estate
Opt-in vs opt-out, the 1,000-foot buffer, municipal authority, and current CRA market data.
ReadMichigan license types
Every adult-use license with annual fee, plant limit and the real estate it actually requires.
ReadMichigan distressed & receivership
The 24% wholesale tax, the TerrAscend receivership, and why licenses don't transfer with the building.
ReadCannabis site selection guide
Power, dehumidification, structure, water, extraction classification, zoning and timeline.
ReadNext step
Tampa Bay hemp exposure, reviewed
Landlord or operator, the November 2026 date is the same. Send the lease and the use and we will tell you what the building is worth on either side of it.
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