California Enacts Sweeping Pharmacy Bill Extending Board Sunset and Requiring Nonresident PIC Licensure
On October 1, 2025, Governor Gavin Newsom signed into law AB 1503, creating wide-ranging changes for the world of pharmacy inside and outside California. The new legislation affects pharmacy operations, nonresident pharmacy compliance, and California Board of Pharmacy authority. Unless specifically noted, changes in the law go into effect on January 1, 2026.
Pharmacy operators should immediately develop and implement practical changes in response to the following key provisions:
- Board of Pharmacy Authority
The bill extends the sunset of the California Board of Pharmacy, continuing its exclusive authority to administer and enforce pharmacy law until January 1, 2030. - Pharmacist Furnishing & Standard of Care
Pharmacists are authorized to furnish FDA-approved or authorized medications and devices under an accepted standard-of-care framework, including contraception, nicotine replacement therapy, and HIV and travel medications. This provision also extends authorization indefinitely for pharmacists to furnish COVID-19 oral therapeutics.
- Day-Supply Conversions & Refill Restrictions
AB 1503 removes restrictions and allows a pharmacist to provide emergency refills and to convert prescriptions to a 90-day supply in certain circumstances.
- Pharmacist-in-Charge (PIC) Authority
The PIC must establish pharmacist-to-technician ratios within statutory limits, and the bill prohibits interference with PIC judgment.
- Nonresident Pharmacies
Beginning July 1, 2026, the bill requires nonresident pharmacies to: - designate and employ a California-licensed PIC at nonresident sites;
- notify the Board of changes within a set time frame; and
- submit to Board inspections and pay associated costs.
- Ownership/Prescriber Conflicts
The legislature created a narrow exception which allows licensure where prescribers and pharmacies share a financial interest. However, this arrangement is subject to disclosure and restrictions on filling prescriptions from related prescribers. - Chain and Mail-Order Enforcement
AB 1503 expands penalty authority over chain community and mail-order pharmacies for repeated violations and requires the consideration of mitigating and aggravating factors. - Recordkeeping and Self-Assessments
The record keeping provision requires all licensed pharmacies to complete a self-assessment every odd-numbered year and within 30 days of certain licensing, location, or PIC changes. - Licensing and Discipline
Licensing requirements now include health care fraud and identity theft convictions as grounds for license denial. The updated requirements also provide a streamlined reactivation process within 3 years for retired pharmacist licenses.
Stakeholders should evaluate need for changes such as updating policies, changing staffing models, revisiting compliance programs, and for nonresident pharmacies, planning for the PIC licensure requirement.
If you have questions about how this bill may impact your operations, or questions regarding any other matter involving pharmacy law, please contact your Quarles attorney or:
- Nick Meza: (602) 229-5439 / nicholas.meza@quarles.com
- Susan Brichler Trujillo: (602) 229-5318 / susan.trujillo@quarles.com
- Anne O’Brien: (312) 715-5259 / anne.o'brien@quarles.com
- Kenya Hagans: (414) 277-5456 / kenya.hagans@quarles.com