New Mexico NMS2S Transition: What Cannabis Operators Must Do

New Mexico is replacing BioTrack with a new state-mandated cannabis track-and-trace platform: the New Mexico Seed-to-Sale System, or NMS2S.

The transition begins on August 25, 2026. BioTrack is scheduled to shut down completely on September 4. Cannabis operators and their software providers have a compressed window to reconcile inventory, establish new accounts, learn new workflows, update integrations, and test the results.

The new NMS2S system introduces different workflows, identifiers, transaction rules, and integration requirements. It will also launch without API support for cultivation, manufacturing, transfer, and inventory management workflows (as of the publish date).

Here is what New Mexico operators currently need to know.

What is New Mexico's NMS2S Track-and-Trace System?

NMS2S is New Mexico’s successor state-mandated seed-to-sale system. It will replace BioTrack as the Cannabis Control Division’s system of record for regulated cannabis inventory and activity.

The New Mexico Regulation and Licensing Department awarded the new seed-to-sale contract to Real Time Solutions in January 2026. In June, the Cannabis Control Division announced that it was developing a successor system but did not provide a launch date or a detailed transition plan.

On August 10, 2026, the CCD published the first migration dates in an industry bulletin. The CCD shared a more detailed tentative cutover schedule on August 14.

That means non-retail licensees received 15 calendar days’ notice between the first published migration date and the initial BioTrack shutdown. The tentative detailed schedule arrived with only 11 days before the existing state system shutdown. 

The NMS2S transition timeline

The current schedule is based on CCD Industry Bulletins 26-08 and 26-09. CCD has described the dates as tentative and cautioned that unforeseen circumstances could still require changes.

August 25 after 5:00 p.m.

BioTrack will shut down for producers, manufacturers, testing laboratories, and other non-retail licensees. CCD expects non-retail operations to continue where permitted, but licensees must keep accurate records and reconcile any activity in NMS2S when access to their migrated inventory becomes available. This means that licensees can continue to use a platform like Flourish to manage operations, but the system will not have a "state system" to integrate with.  

Retailers may continue recording sales in BioTrack during this period. However, they will not be able to receive inventory while the transfer systems are unavailable.

Retailers should plan inventory needs in advance to cover this anticipated transfer downtime, which is expected to last until September 2, 2026.

Testing laboratories will not be able to receive samples beginning August 25.

Around August 31

RTS expects producer and manufacturer inventory to be restored in NMS2S. Operators will need to reconcile activity from the migration period before relying on the migrated balances. Testing laboratories are expected to resume accepting samples, and historical test results should be available in NMS2S.

September 1 at 12:01 a.m.

CCD will begin migrating retailer inventory into NMS2S. Retailers must continue reporting sales through BioTrack during this period. Their retail inventory should be fully synchronized with BioTrack before the migration snapshot.

CCD has also instructed retailers not to send or accept transfers from other retailers through BioTrack after this point.

September 2

Retail inventory captured at midnight on September 1 is expected to be fully migrated and available in NMS2S by noon on September 2, 2026.

Retailers will temporarily have access to both BioTrack and NMS2S. They may begin receiving transfers in NMS2S, but sales must continue through BioTrack until the final cutover.

During this overlap, retailers will need to adjust NMS2S inventory to account for sales recorded in BioTrack after the retail migration snapshot. This creates a short but important manual reconciliation period.

September 4 at 12:01 a.m.

The legacy BioTrack system will be turned off.

All retail sales after this point must be reported through NMS2S, including sales submitted by integrated third-party point-of-sale systems.

Operators should continue monitoring the CCD Data and News page because the agency expects to issue additional instructions, manuals, and transition updates.

What operators should do before migration?

The most important preparation is making sure BioTrack accurately reflects physical inventory.

BioTrack remains the source of truth for the migration. Information that exists only in a point-of-sale, ERP, or inventory-management platform that has not successfully synchronized to BioTrack will not appear in NMS2S. Inaccurate inventory and any phantom or junk records will sync during cutover, so this is the opportunity to clean up the system. 

CCD recommends that licensees run a “Current Inventory” report directly from BioTrack and use it as the basis for reconciliation.

Before the applicable migration date, operators should:

• Reconcile physical inventory against BioTrack inventory.
• Resolve outstanding discrepancies and incomplete transactions.
• Review plants, harvests, packages, and other tracked records.
• Complete or close outdated records where appropriate.
• Confirm that completed transfers have been accurately recorded.
• Review facility, license, and location information.
• Verify that third-party software is fully synchronized with BioTrack.
• Keep records of any activity that occurs while the systems are unavailable.

Operators should correct genuine discrepancies, but should not make unsupported adjustments simply to make records appear cleaner before migration.

All products currently on the market for consumer sale will be grandfathered into the successor system.

BioTrack user accounts will not migrate

Existing BioTrack user accounts will not carry over to NMS2S.

The primary controlling person listed in each licensee’s NM-PLUS account will become the initial system administrator. That person will then be responsible for creating and managing access for other employees.

Operators should verify the information of their primary controlling person before the transition. If that record is outdated, the business could face an avoidable access problem during an already narrow reconciliation window.

Key NMS2S Workflow & Compliance Changes

CCD says NMS2S is designed to align system workflows more closely with existing regulatory requirements. As a result, operators should not expect every BioTrack workflow to work the same way in the new system.

Several changes have already been announced.

• Medical vs. Adult-Use Tracking: NMS2S introduces distinct, separate tracking models for medical and adult-use products to provide clearer market reporting across both sectors.

Producer inventory types will be restricted

After migration, the inventory associated with a production license will be limited to:

• Deli Style Cannabis
• Fresh Frozen
• Bulk Flower
• Bulk Trim
• Clones
• Seedlings
• Seeds

Existing inventory will migrate as it is currently recorded. After the transition, however, producers will not be able to receive inventory types outside this list.

Finished-product testing becomes a clearer system gate

NMS2S will distinguish sale-ready products from material still in cultivation, manufacturing, or processing.

Sale-ready inventory will be identified as either Packaged Products or Deli-Style Flower. Before inventory can be converted to a sale-ready type and transferred to retail, it must have a finished-product test meeting the requirements of 16.8.7.15 NMAC.

Testing applies to the product in the form in which it will be transferred for sale. If a tested product is processed further, changes form, or receives additional ingredients, the resulting product will require a new finished-product test. The state specifically requires testing at the product's "Unpackaged" stage, the point at which the product form will no longer change before final packaging.

Courier activity will be tracked differently

Licensed couriers will receive their own track-and-trace accounts. Deliveries made by either licensed couriers or a licensee’s internal couriers must be tracked through NMS2S.

This changes more than reporting. Retail and delivery systems may need to work with state-defined driver, vehicle, and courier records when submitting delivery transactions.

The biggest integration issue: most non-retail APIs will not be available at launch

The NMS2S platform itself supports seed-to-sale activity. The limitation is the initial connection available to third-party software.

At launch, CCD and RTS are providing API materials for retail point-of-sale integrations. API materials for third-party inventory-management systems will not be available until after NMS2S launches. No public release date has been provided.

This affects workflows such as:

• Plant and harvest activity
• Inventory creation and adjustment
• Conversions and repackaging
• Waste and destruction
• Transfers and manifests
• Receiving
• Rooms and locations
• Lab and testing activity

Until the necessary APIs are released, cultivators, manufacturers, wholesalers, and vertically integrated operators may need to record compliance activity directly in NMS2S while continuing to manage operational activity in their primary business software.

That is a dual-entry period, not a complete integration.

Operators should coordinate with their software provider to export or report data and support reconciling with the NMS2S. 

How Cannabis POS & ERP Software Integrates with NMS2S

A state traceability integration touches every aspect of a cannabis operation: inventory identity, sales reporting, purchase limits, medical-patient validation, transfers, testing status, and transaction reversals, etc. 

Changing the state platform requires software providers to:

1. Interpret the new state requirements.
2. Map the new data model to existing operational records.
3. Build authentication and transaction handling.
4. Account for new identifiers and inventory relationships.
5. Design operator-facing failure and reconciliation workflows.
6. Test successful transactions, rejected transactions, timeouts, duplicate submissions, and migration data.
7. Validate the integration against the production environment.

The currently available retail materials also introduce meaningful differences from BioTrack. NMS2S assigns state inventory identifiers, provides retail inventory via a state-controlled feed, uses a new medical purchase limit model, and handles refunds through its void process.

Those are application changes that require deliberate implementation and testing. 

How Flourish Software Supports the NMS2S Cutover

Flourish is treating retail sales continuity as the immediate critical path.

Our team is mapping the NMS2S retail API to the existing inventory, customer, and point-of-sale workflows used by New Mexico operators. That includes retrieving state-authorized retail inventory, maintaining the relationship between Flourish packages and NMS2S inventory records, validating medical customers, reporting completed sales, and handling eligible voids.

We are also working through customer readiness:

• Confirming that BioTrack and Flourish inventory are synchronized before migration.
• Verifying NM-PLUS administrator information and NMS2S access.
• Preserving migrated barcode relationships where the state data allows it.
• Preparing for the September 1–4 retail reconciliation window.
• Identifying workflows that must temporarily take place in the NMS2S interface.
• Continuing to test as CCD and RTS publish production details and revised guidance.

For non-retail workflows, the state has not yet released the inventory APIs required for a complete third-party integration. Until those APIs are available, some compliance activity will need to be completed in NMS2S. Flourish will work with customers to support reporting to easy dual data entry. The user interface and process of recording STS activity in the new NMS2S is still unknown.  

That is not the final operating model. This is the interim state within a compressed and still-evolving state transition.

What to watch next

Several important details remain subject to additional guidance:

• Final production access for integrated POS providers
• Official NMS2S User Manuals (v2.0) and Industry Bulletin 26-10 are now live on the NM RLD NMS2S Portal, covering Producers, Retailers, Manufacturers, Testing Labs, Couriers, and Org Admins.
• Exact reconciliation procedures during system downtime
• The release date and scope of the inventory API
• Guidance for workflows that occur during the non-retail shutdown
• Any changes to the tentative migration schedule

CCD has said it expects to release frequent updates. Operators should monitor official communications and confirm workflow-specific questions with CCD, RTS, and their software providers.

The two primary transition notices are Industry Bulletin 26-08 and Industry Bulletin 26-09.

This article will be updated as New Mexico publishes additional NMS2S guidance.

This article is intended as operational information, not legal advice. Licensees remain responsible for following current CCD instructions and applicable New Mexico regulations.