A DEA power of attorney is the document that lets someone other than the registrant sign orders for Schedule I and II controlled substances, on paper Form 222 or electronically through CSOS. The regulation prints the wording it expects, and DEA changed that wording on March 20, 2026. Most templates in circulation were written before the change.

This guide gives the current text, says who may sign and revoke it, and shows where it has to be kept. Every statement about the rule is tied to the section it comes from, and the sources are listed at the end.

What the power of attorney does

A registrant may authorize one or more individuals to issue orders for Schedule I and II controlled substances on the registrant's behalf by executing a power of attorney for each one. The person does not have to work at the registered location (21 CFR 1305.05(a)).

The same document covers both ordering methods. Its heading in the regulation is "Power of Attorney for DEA Forms 222 and Electronic Orders," and its text authorizes the holder "to execute applications for Forms 222 and to sign orders for schedule I and II controlled substances, whether these orders be on Form 222 or electronic" (21 CFR 1305.05(c)).

What changed on March 20, 2026

DEA published a technical amendment, effective the day it appeared, at 91 FR 13498. It rewrote the form text in paragraph (c), the revocation rule in paragraph (e), and the signature rule for Form 222 itself.

The background is a 2019 rule. That rule changed paragraph (d) so that the power of attorney had to be granted by the registrant, a partner or an officer. In the 2026 notice DEA says that "due to an administrative error" the form text and the revocation paragraph were not updated at the same time, so they kept the older wording.

Form text, 1305.05(c): how the grantor is described

Before: "who am authorized to sign the current application for registration of the above-named registrant"

Now: "the registrant, if an individual; a partner of the registrant, if a partnership; or an officer of the registrant, if a corporation, corporate division, association, trust or other entity"

Who revokes, 1305.05(e)

Before: "the person who signed the most recent application for DEA registration or reregistration, and two witnesses"

Now: the registrant, a partner or an officer, in the same words as above, and two witnesses

Who signs a Form 222, 1305.12(d)

Before: "a person authorized to sign an application for registration or a person granted power of attorney"

Now: the registrant, a partner or an officer, in the same words as above, "or a person granted power of attorney to sign a DEA Form 222 under § 1305.05"

Earlier wording: 21 CFR, 2025 annual edition (revised as of April 1, 2025). Current wording: 91 FR 13499–13500.

DEA describes these as conforming revisions that make no substantive change: the 2019 rule had already set who may grant the power. It is also explicit about the effect: paragraph (c) "will no longer allow a person authorized to sign an application for registration to execute or revoke a POA to sign DEA Form 222s."

Templates posted before the amendment still circulate. Two university-hosted copies checked on October 5, 2026 carried the earlier wording, and DEA's own Form 222 questions and answers page, dated October 5, 2020, still described revocation by the person who signed the most recent application.

Who has to sign

Paragraph (d) requires three sets of signatures:

  1. The person granting the power. The registrant, if an individual; a partner of the registrant, if a partnership; or an officer of the registrant, if a corporation, corporate division, association, trust or other entity.
  2. The person receiving it, called the attorney-in-fact in the form.
  3. Two witnesses.

Any or all of them may sign electronically (21 CFR 1305.05(f)). When DEA added that paragraph in 2019, commenters had asked it to drop the witness signatures for electronically signed documents. DEA declined: the witness requirement stayed, and witnesses may sign electronically (84 FR 51368).

In the same rule DEA gave its reason for limiting who may grant the power: "the significance of Form 222 signature authority, and the potential for diversion when that authority is abused."

The current format

The regulation says the power of attorney and the notice of revocation "must be similar to the following format." The text below is paragraph (c) as amended. Blank lines are shown where the regulation shows them.

Power of Attorney for DEA Forms 222 and Electronic Orders

______________________________
(Name of registrant)

______________________________
(Address of registrant)

______________________________
(DEA registration number)

I, ______________ (name of person granting power), the undersigned (the registrant, if an individual; a partner of the registrant, if a partnership; or an officer of the registrant, if a corporation, corporate division, association, trust or other entity), have made, constituted, and appointed, and by these presents, do make, constitute, and appoint ______________ (name of attorney-in-fact), my true and lawful attorney for me in my name, place, and stead, to execute applications for Forms 222 and to sign orders for schedule I and II controlled substances, whether these orders be on Form 222 or electronic, in accordance with 21 U.S.C. 828 and Part 1305 of Title 21 of the Code of Federal Regulations. I hereby ratify and confirm all that said attorney must lawfully do or cause to be done by virtue hereof.

______________________________
(Signature of person granting power)

I, ______________ (name of attorney-in-fact), hereby affirm that I am the person named herein as attorney-in-fact and that the signature affixed hereto is my signature.

______________________________
(signature of attorney-in-fact)

Witnesses:

1. ______________________________

2. ______________________________

Signed and dated on the ____ day of ____________, (year), at ______________.

Revoking it

A registrant may revoke any power of attorney at any time by executing a notice of revocation (21 CFR 1305.05(b)). As amended, paragraph (e) requires the revocation to be made by the registrant, a partner or an officer, described in the same words as the grantor, together with two witnesses. The form text states that written notice has been given to the attorney-in-fact the same day.

Notice of Revocation

The foregoing power of attorney is hereby revoked by the undersigned (the registrant, if an individual; a partner of the registrant, if a partnership; or an officer of the registrant, if a corporation, corporate division, association, trust or other entity). Written notice of this revocation has been given to the attorney-in-fact ______________ this same day.

______________________________
(Signature of person revoking power)

Witnesses:

1. ______________________________

2. ______________________________

Signed and dated on the ____ day of ____________, (year), at ______________.

The section sets no expiration date and no renewal schedule. It also does not say what happens to a power of attorney when the officer who granted it leaves the organization. That is a question for your counsel or your DEA field office.

Where to keep it, and for how long

  • With the order records. The power of attorney must be "retained in the files, with executed Forms 222 where applicable," and "available for inspection together with other order records" (21 CFR 1305.05(a)).
  • For as long as the orders it supports. It is kept "for the same period as any order bearing the signature of the attorney." Executed Forms 222 must be kept available for inspection for two years (21 CFR 1305.17(c)), and CSOS order records for two years (21 CFR 1311.60(a)). A revoked power of attorney therefore stays in the file until the last order that person signed has aged out. Check whether your state requires longer.
  • Not at DEA. DEA's guidance says the power of attorney "is not submitted to DEA, but, it must be readily retrievable for inspection" (DEA Form 222 Q&A).

The same document in CSOS

Electronic orders are signed with a personal digital certificate. The power of attorney is what makes a non-registrant eligible for one.

  • Eligibility. A person granted power of attorney by a registrant to sign orders is eligible for a CSOS digital certificate (21 CFR 1311.10(b)).
  • Enrollment. Enrollment is online at www.deaecom.gov. The applicant uploads the power of attorney, and the registrant's CSOS coordinator approves applicants for a power of attorney certificate. The Certification Authority verifies the applicant's identity and employment (21 CFR 1311.25 and 1311.20(c), as amended effective November 3, 2025).
  • One person, one certificate. Only the certificate holder may access or use the certificate and its private key (21 CFR 1311.30(a)). DEA issues each power of attorney holder one signing certificate for each applicable registration number (DEA CSOS Q&A).
  • Six hours. A registrant that grants power of attorney must report to the DEA Certification Authority within 6 hours when the person has left the employ of the institution or has had their privileges revoked. Advance notice is allowed (21 CFR 1311.45(a)).
  • A list. The registrant must maintain a record that lists each person granted power of attorney to sign controlled substance orders (21 CFR 1311.45(b)).

Why this is a diversion control

Whoever holds a power of attorney can bring Schedule II drugs into the building under the registrant's name. DEA's stated reason for restricting who may grant it is the potential for diversion when signature authority is abused. The document is short, but it defines who can start an order.

The points below are practice suggestions, not regulatory text. Each one is a way to check that the paper matches what the rule requires.

  • Check who signed as grantor. On each power of attorney on file, confirm the grantor is the registrant, a partner or an officer. A document granted by someone who only held authority to sign the registration application is the case DEA says the rule no longer allows.
  • Use the amended wording for new documents. Replace any internal template that still reads "authorized to sign the current application for registration."
  • Compare the list with the orders. Every person other than the registrant, a partner or an officer who signed a Form 222 or a CSOS order in the retention period should appear on the list required by 1311.45(b), with a power of attorney on file that was executed before their first order.
  • Tie the list to offboarding. The 6-hour CSOS report only happens on time if human resources or the department tells the registrant the same day. Execute the notice of revocation at the same time.
  • Keep revoked documents. File the notice of revocation with the original and keep both for the retention period.
  • Count the witnesses. Two witness signatures on every grant and every revocation, whether signed on paper or electronically.

Common questions

Does it have to be notarized?

Section 1305.05 requires two witnesses and does not mention a notary. CSOS enrollment used to involve a notarized paper application. DEA removed that requirement when enrollment moved online, effective November 3, 2025 (90 FR 47566). Check whether your state adds its own requirement.

Do I send it to DEA?

No. It stays in your files, readily retrievable for inspection. A copy is uploaded during CSOS enrollment.

Is there an official DEA form number for it?

The regulation prints a format, not a numbered form, and says the document "must be similar to" it. CSOS enrollment is a separate online process, and the power of attorney is uploaded as part of it.

How many people can hold one?

The rule allows "one or more individuals," with a power of attorney executed for each. DEA's CSOS guidance says an organization may enroll an unlimited number of power of attorney holders. Fewer holders means a shorter list to keep current.

Related guides

The DEA Form 222 guide covers completing and filing the paper form, and the CSOS guide covers certificates and electronic orders. For the wider set of records an inspector asks for, see the recordkeeping guide and DEA audit readiness.

Sources

  • Drug Enforcement Administration. "Ordering Schedule I and II Controlled Substances Using DEA Form 222; Technical Amendments." 91 FR 13498, March 20, 2026. federalregister.gov · PDF
  • Drug Enforcement Administration. "Controlled Substances Ordering System (CSOS) Modernization." 90 FR 47566, October 2, 2025, effective November 3, 2025. federalregister.gov
  • Drug Enforcement Administration. "New Single-Sheet Format for U.S. Official Order Form for Schedule I and II Controlled Substances (DEA Form 222)." 84 FR 51368, September 30, 2019. federalregister.gov
  • 21 CFR 1305.05, 1305.12, 1305.17, 1311.10, 1311.20, 1311.25, 1311.30, 1311.45 and 1311.60, 2025 annual edition (revised as of April 1, 2025), read with the 2025 and 2026 amendments above. govinfo.gov, § 1305.05 · § 1311.45
  • DEA Diversion Control Division. "DEA Form 222 Q&A," answer EO-DEA194, October 5, 2020. deadiversion.usdoj.gov
  • DEA Diversion Control Division. "CSOS (Controlled Substances Ordering System) Q&A." deaecom.gov