On September 10, 2026, Illinois gave medical cannabis licenses to 37 adult-use dispensaries (IDFPR). For the first time, these stores can serve medical patients and adult-use customers under one roof. Applications are rolling, so any adult-use dispensary in good standing can apply to add medical sales.
Adding medical sales is mostly a systems change. Your POS, labels, Metrc setup, and floor plan all need to handle two kinds of customers the right way. This checklist covers what to set up before your first medical sale.
What changed: SB 3222 at a glance
SB 3222 (Public Act 104-0463) was signed on June 12, 2026. It lets any Illinois adult-use dispensary in good standing add a medical license, starting September 10, 2026. Once approved, you can sell to registered patients at the medical tax rate, up to each patient’s allowed amount (their allotment).
The law also changed several other things you’ll need to plan for. Most of them took effect right away, on June 12 (IDFPR SB 3222 fact sheet):
| Change | What it means for your systems |
| Medical opt-in (from Sept. 10, 2026) | Your POS, labels, and Metrc must handle medical sales and patient allotments |
| Medical warning label | Every product sold to a patient needs a federally required warning label, added before the sale |
| Licenses stay together | Your adult-use and medical licenses can’t be split, in the store or in ownership |
| Video kept 60 days, down from 90 | You may now keep 60 days of footage instead of 90, unless it’s being held for an investigation |
| Curbside and drive-through allowed | IDFPR must first review your updated floor plan, security plan, and SOPs |
| Higher purchase limits for residents | Flower goes from 30g to 60g. Infused products go from 500mg to 1,000mg THC |
| In-house security guards allowed | You no longer need to hire an outside security company |
| Electronic agent badges | Staff can show badges on a screen. You still must report firings within 5 business days |
| Hours up to 2 a.m. | You need local approval and must notify IDFPR |
IDFPR says it will write new rules because of SB 3222. It’s also working with the Illinois Department of Agriculture on Metrc changes. Expect details to keep changing, and check IDFPR guidance before you lock anything in. We’ll update this checklist as new guidance comes out.
Before you apply: confirm the basics
IDFPR only accepts requests from dispensaries with an active license in good standing. It also wants to hear about any changes to your floor plan, systems, or policies before you make them.
- License status: Make sure your license is active, in good standing, and has no open discipline issues.
- Planned changes: If adding medical means changing your floor plan, systems, or policies, your designated contact should tell IDFPR before you make any changes.
- Conditional licensees: If you still have a conditional license, opt in when you submit your 15-36 application.
- Ownership records: SB 3222 changed who counts as a principal officer at privately held companies. It’s now anyone who owns 5% or more, up from 1%. Update your ownership chart (table of organization) if it no longer matches.
POS and tax setup
Your POS has to tell medical and adult-use sales apart, charge the right tax, and stop patients from going over their allotment. This is where most of the setup work happens.
- Customer type: The POS needs a clear way to mark each sale as medical (a registered patient or caregiver) or adult use, before any products are added.
- Tax rules: Set the medical tax rate separately from adult-use taxes. Test every product category, and have your accountant check the setup.
- Allotments: Check patient purchases against their allotment, not the adult-use limits per sale.
- New adult-use limits: While you’re in the settings, update the higher resident limits from SB 3222 (60g flower, 1,000mg infused).
- Reporting: Make sure you can pull sales reports by customer type. You’ll need them for tax filings and audits.
If your current POS can’t handle both sale types cleanly, now is the time to find out. Our comparison of cannabis POS systems is a good place to start.
Labeling and Metrc
Every product sold to a medical patient needs a federally required warning label, and it has to go on before the sale. Every sale also still has to match your Metrc records.
- Label workflow: Decide where and when staff add the medical warning label: when stock arrives, in the back room, or at the counter. Then set up label printing to match. Either way, the label must be on before the product leaves the counter.
- Metrc categories: Confirm how medical sales report to Metrc, and check that your POS sends them correctly. IDFPR and the Department of Agriculture are still working on Metrc changes for SB 3222, so test again once new guidance comes out.
- Test sales: Run test sales for both customer types. Confirm they show up correctly in Metrc before you go live.
New to Metrc in Illinois? Our Metrc compliance guide covers the basics.
Security and surveillance updates
Adding medical sales doesn’t bring new camera rules. But SB 3222 changed several security rules, so update them at the same time.
- Video storage: You can now keep 60 days of footage instead of 90. Before you cut it back, check for any footage you must keep for an investigation or another request.
- Security plan: Update your written plan to show any floor plan changes for medical sales. Our guide to creating a dispensary security plan covers what to include.
- Curbside or drive-through: If you add either one, IDFPR must review your updated floor plan, security plan, and SOPs before you start. Plan camera coverage and network access for those areas from the start.
- Security staff: If you switch from an outside security company to your own guards, badge them as agents. Also review the state law that covers private security, the Private Detective, Private Alarm, Private Security, Fingerprint Vendor, and Locksmith Act of 2004.
Patient data and privacy
Medical sales mean handling patient registry information, and patients expect it to stay private. Most dispensaries aren’t covered by HIPAA, the federal health privacy law. But patient data is still sensitive, so treat it that way.
- Let only certain roles see patient information in the POS
- Use two-step sign-in (multi-factor authentication) on the POS and back-office systems
- Keep patient data off shared or guest devices
- Have a written plan for what to do if patient data leaks
Network and uptime
More sale types, more lookups, and stricter Metrc reporting all depend on a steady internet connection. If you don’t have these yet, add them:
- A backup internet connection that switches on by itself, so checkout and Metrc reporting keep running
- Separate networks for the POS, cameras, back office, and guest Wi-Fi
- Alerts that tell someone right away when a system goes down
Your go-live checklist
Before your first medical sale, confirm:
- IDFPR has approved your medical license
- The POS marks medical vs. adult-use sales and charges the right tax
- Patient allotment checks work
- Medical warning labels are printed, and the labeling step is in your SOPs
- Test sales for both customer types match in Metrc
- Your security plan and floor plan are updated, and IDFPR knows about the changes
- Only certain roles can see patient data
- Staff are trained on the new medical steps
Running both workflows every day brings its own challenges, like check-in, serving both customer types at one counter, and training staff. Our guide to managing Illinois medical and adult-use sales in one store covers all of it.
How Cure8 helps
Cure8 sets up and supports the tech behind Illinois dispensaries. That includes the POS, labels, Metrc, network, and security changes you need to add medical sales. We’ll help you set up both sale types, test them before you go live, and update your security documents to match. Talk to Cure8 about your Illinois dispensary.
Frequently asked questions
1. Can any Illinois adult-use dispensary add medical sales?
Yes, if its license is active and in good standing. Under SB 3222, these stores can opt in for a medical license. Applications are rolling and opened September 10, 2026.
2. Do medical cannabis products in Illinois need a special label?
Yes. Every product sold to a medical patient needs a federally required warning label, added before the sale.
3. How long do Illinois dispensaries have to keep security footage?
SB 3222 lets dispensaries keep 60 days of footage instead of 90. Footage tied to an investigation must be kept longer.
4. Can a dispensary separate its medical and adult-use licenses later?
No. SB 3222 doesn’t allow it. The two licenses stay together, both in the store and in ownership.