Illinois to Require Illinois-Licensed PICs for Nonresident Pharmacies Effective January 1, 2026

Effective January 1, 2026, every nonresident pharmacy licensed by the Illinois Department of Financial and Professional Regulation (IDFPR) must designate a Pharmacist-in-Charge (PIC) who holds an active Illinois pharmacist license.

This new requirement appears in 68 Illinois Administrative Code § 1330.550(a):

“Beginning January 1, 2026, pharmacists-in-charge of nonresident pharmacies shall be licensed in Illinois.”
— 68 Ill. Adm. Code § 1330.550(a)
(Illinois Administrative Code – IDFPR)

Overview

Under Illinois law, a nonresident pharmacy is any pharmacy located outside the state that ships, delivers, dispenses, or distributes prescription drugs or devices into Illinois.
(68 Ill. Adm. Code § 1330.10)

Nonresident pharmacies must register with the IDFPR and comply with Illinois pharmacy rules. These include maintaining retrievable prescription records for Illinois residents, providing a toll-free telephone service for patient consultation, and disclosing ownership and pharmacist information.
(68 Ill. Adm. Code § 1330.550)

Until now, Illinois did not require pharmacists employed by nonresident pharmacies to hold Illinois licensure. The updated rule changes that standard by requiring the Pharmacist-in-Charge—the individual responsible for ensuring compliance with Illinois pharmacy law—to be licensed in Illinois beginning January 1, 2026.

Impact of the Change

The rule aligns Illinois with a growing number of states that require in-state licensure for nonresident pharmacy PICs. It ensures that the person accountable for operations affecting Illinois patients is subject to Illinois regulatory authority and understands state-specific requirements.

A nonresident pharmacy that does not have an Illinois-licensed PIC in place by the effective date will be out of compliance with state regulations and may face enforcement actions or renewal delays.

Pharmacies should review their current PIC designations and confirm that the designated pharmacist is licensed in Illinois prior to the rule’s effective date.

Summary

Beginning January 1, 2026, nonresident pharmacies licensed in Illinois must ensure their Pharmacist-in-Charge holds an Illinois pharmacist license. This rule, codified in 68 Ill. Adm. Code § 1330.550(a), creates a clear expectation of accountability and compliance for all pharmacies dispensing medications into Illinois. This new requirement ensures that the individual responsible for compliance and patient safety within these pharmacies is directly subject to Illinois regulations, aligning the state with a broader trend toward stricter oversight of out-of-state pharmacies operating within Illinois.

Pharmacies operating across state lines should proactively review and update their PIC designations to meet this new Illinois requirement. Ensuring that the designated PIC is licensed in Illinois not only guarantees compliance but also reinforces the pharmacy’s commitment to patient safety and regulatory integrity. Staying ahead of these changes will help avoid potential enforcement actions and ensure seamless operations in the evolving landscape of pharmacy regulation.