Key Takeaways: The New York State Board of Pharmacy (NYBOP) issued guidance in December 2025 requiring licensure both for pharmacies and for each individual pharmacist participating in shared pharmacy services arrangements when servicing New York patients. Nonresident pharmacy registration alone is no longer sufficient to satisfy shared services compliance. While this requirement becomes effective May 22, 2026, organizations should not delay taking action now. A proactive assessment and timely remediation of any licensure gaps will be critical to ensuring compliance moving forward. What Organizations Should Be Doing Now Evaluate your shared services model to identify where operations may be impacted; Confirm that all pharmacists supporting or involved in New York operations, including remote personnel, hold appropriate licensure and identify any gaps; Implement proactive compliance measures for any

On December 19, 2025, the Illinois Department of Financial and Professional Regulation (IDFPR) issued a variance that extends the deadline in 68 Ill. Adm. Code 1330.550(a) requiring pharmacists-in-charge of nonresident pharmacies to be licensed in Illinois. Originally, the rule required Illinois licensure beginning January 1, 2026, but IDFPR extended the deadline to March 30, 2026 to help avoid disruption in care for Illinois patients who rely on nonresident pharmacies. We encourage impacted nonresident pharmacies to confirm their designated PIC’s Illinois licensure status and, where licensure is still needed, to submit Illinois pharmacist license applications promptly to allow adequate time for processing and to ensure compliance by the new March 30, 2026 deadline.