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In October 2025, California Governor Gavin Newsom signed Assembly Bill 1503 into law, marking a significant change for pharmacies located outside California that dispense medications into the state. The new law amends California's Business and Professions Code governing nonresident pharmacies and establishes new requirements related to the designation and licensure of a Pharmacist-in-Charge (PIC). Pharmacies and pharmacists should pay careful attention to these changes and new requirements, as these provisions become operative on July 1, 2026.
For a change like this, being proactive is critical.
Background and Overview
California's Pharmacy Law requires any out-of-state pharmacy that ships, mails, or delivers prescription drugs into California to register as a nonresident pharmacy with the California State Board of Pharmacy. Historically, the Board permitted the PIC of such pharmacies to hold an active pharmacist license in another state, typically their home state.
Under AB 1503, that flexibility will end. Beginning July 1, 2026, each nonresident pharmacy must designate a California-licensed pharmacist to serve as its PIC. This means that even if a pharmacy's physical operations are located entirely outside California, the pharmacist responsible for oversight of California dispensing must now hold a California pharmacist license.
Key Provisions
The new law includes several notable requirements and compliance obligations:
- California Licensure for PICs: A nonresident pharmacy must identify a pharmacist who holds an active California license to serve as PIC. A pharmacist licensed solely in another state may not serve in this role.
- Timely Notification to the Board: Within 90 days of designating a PIC, the nonresident pharmacy must notify the Board of the individual's identity, license number and effective date of designation. The same timeline applies if the designated PIC ceases to serve in that role.
- Inspection and Compliance Authority: The Board of Pharmacy may now require periodic inspections of nonresident pharmacies, generally every four years (or more frequently if warranted), and may assess reasonable costs associated with those inspections.
- Ongoing Reporting and Operational Requirements: The law reinforces the Board's authority to require documentation demonstrating compliance with California's prescription, labeling, and controlled substance standards, even for pharmacies operating outside the state.
Implications for Nonresident Pharmacies
The most immediate operational impact will be the need for nonresident pharmacies to ensure their designated PIC holds an active California pharmacist license by July 1, 2026. Obtaining such licensure typically requires passing California's Multistate Pharmacy Jurisprudence Examination (MPJE) and meeting other state-specific requirements.
For multi-state operators, 340B contract pharmacies, specialty pharmacies and mail-order facilities, this requirement may necessitate revisiting internal policies, personnel assignments, and compliance frameworks. Pharmacies should evaluate now whether their existing PIC—or another member of their management team—should pursue California licensure in advance of the 2026 effective date.
Strategic Considerations
While this change adds a new administrative step, it also provides an opportunity to strengthen regulatory oversight and consistency for California-dispensed prescriptions. Pharmacies that act early to secure a California-licensed PIC and document compliance procedures will be best positioned to minimize disruption.
It may also be prudent for nonresident pharmacies to:
- Begin reviewing internal SOPs related to pharmacist licensure and Board communications.
- Identify pharmacists who may already meet California's licensure criteria or can obtain licensure well before the deadline.
- Budget for inspection fees and potential Board-related administrative costs.
- Engage legal counsel to ensure compliance with both California and home-state regulations governing pharmacy operations, labeling, and recordkeeping.
Conclusion
AB 1503 reflects California's continuing focus on ensuring consistent standards of pharmacy practice for all entities serving its residents, regardless of location. Nonresident pharmacies should act proactively to assess compliance obligations and prepare their leadership teams for the upcoming July 1, 2026 transition.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
