Update, 10:19 a.m.: Shortly after this article was published Thursday morning, the Illinois Department of Financial and Professional Regulation updated its publicly available dispensary information to reflect additional locations serving medical cannabis patients. The updated list shows an increase of 38 locations, from 55 to 93.
It is unclear why that figure differs from a separate state database that, as of this writing, identified 87 dispensaries as “Medical + Adult Use.” It is possible that updates to the state’s various public databases are still being made.
This article will be updated as additional information becomes available from the state.
Approximately 40 of roughly 220 adult-use cannabis dispensaries in Illinois have applied to begin serving medical cannabis patients through a new licensing process, according to sources familiar with the matter.
As of this writing, I have not seen the figure publicly confirmed by the Illinois Department of Financial and Professional Regulation (IDFPR), and the agency’s publicly available dispensary map appears to remain outdated.
A separate state database appears to already reflect some of the changes. As of Thursday morning, 87 dispensaries were identified as “Medical + Adult Use.” By comparison, IDFPR’s July 22 dispensary list identified 55 locations as serving medical patients.
A comparison of the two lists shows 32 additional locations now classified as medical and adult-use dispensaries. The apparent additions include locations operated by Bloc, Cannect, Consume, Ivy Hall, Nature’s Treatment of Illinois, nuEra, Starbuds, Terrabis, Terrace, and The Carbondale Dispensary.
Additional information from the state is expected later today.

Requirements for Serving Medical Cannabis Patients
The new licensing process allows existing adult-use dispensaries, upon approval by the state, to serve registered medical cannabis patients at the medical cannabis tax rate.
Applicants must pay a nonrefundable $5,000 application fee. Upon issuance of the license, the dispensary’s standard renewal fee increases by $10,000 per renewal cycle.
Applications also require an updated dispensary floor plan identifying a consultation area for medical patients, documentation of proper zoning and a patient prioritization plan. That plan must include a designated medical cannabis line and registers that serve medical patients first. Applicants must also provide an updated security plan “if necessary.”
The new licensing process was established through cannabis omnibus legislation signed into law by Gov. JB Pritzker on July 2.
IDFPR published the application packet ahead of the September 10 application date. I first shared the application publicly on August 12 after finding it on the agency’s website. At the time, I had not seen an announcement from the state or media coverage of the newly published application.
You can find the form by clicking here or by going directly to this link: https://idfpr.illinois.gov/content/dam/soi/en/web/idfpr/forms/auc/f2636.pdf
Potential Federal Tax Implications
The new licenses have also raised questions about federal taxes. Medical cannabis operating under a state medical license was recently moved to Schedule III, potentially providing relief from Section 280E. At the time of this writing, adult-use cannabis appears to remain subject to the provision at a federal level.
For dispensaries operating under both medical and adult-use licenses, exactly how that distinction will be treated remains unclear. The federal government is also considering the complete rescheduling of marijuana from Schedule I to Schedule III, which could address the aforementioned tax implication for cannabis businesses.
Illinois already provides cannabis businesses relief from 280E at the state level. In 2023, the Illinois General Assembly passed legislation allowing licensed cannabis businesses to deduct expenses that would otherwise be disallowed under Section 280E when calculating their Illinois taxable income. Lawmakers considered eliminating that relief during the 2025 budget process, but the proposal was not adopted.
Comment below with your thoughts and consider supporting my work!
You can support The Cole Memo with a one-time, monthly, or yearly contribution.
Support The Cole Memo by making a one-time contribution
Support The Cole Memo with monthly contributions
Support The Cole Memo with yearly contributions
Choose an amount
Or enter a custom amount
Your contribution is appreciated. Your contribution helps us afford equipment to capture our content and hosting fees to distribute our content.
Your contribution is appreciated. Your contribution helps us afford equipment to capture our content and hosting fees to distribute our content.
Your contribution is appreciated. Your contribution helps us afford equipment to capture our content and hosting fees to distribute our content.
Reactions to the Illinois Home Grow Raid Story, Plus Cannabis Arrests in Indiana | E316 – The Cole Memo
- Reactions to the Illinois Home Grow Raid Story, Plus Cannabis Arrests in Indiana | E316
- Illinois Police Raided His Legal Home Grow: The Story in ~3 Minutes | E315
- A First Look at the Police Raid of an Illinois Medical Cannabis Patient | E314
- The Era of Descheduled Cannabis Continues for Another Month in America | E312
- Illinois Outdoor Cannabis Rules Put Home Grow Back in the Spotlight | E311

Leave a comment