Illinois Update: Deadline Approaching for Social Equity Criteria Lottery Conditional Licensees

Cannabis Blog Mar 10, 2025 Chicago, IL

Time flies when you are trying to stand up a dispensary. While it may be hard to believe, it has been almost a year since Social Equity Criteria Lottery winners were issued their conditional licenses, and those licenses are about three months out from their expiration. For those who are not yet operational, we want to ensure that you are aware of certain upcoming regulatory obligations and deadlines.

Pursuant to the regulations, you can request a 180-day extension for your conditional license and it is critical that you timely submit any such request—no less than 10 business days prior to the expiration of your conditional license but preferably 30 days out from that deadline. When submitting a request for an extension, it is key that you demonstrate your past efforts to secure a site for your dispensary, describe any hardships you have encountered, and explain the forward plan to secure a site within the 180 days you have left.

Once you have a location, that site control can be demonstrated by providing the Illinois Department of Financial and Professional Regulation (IDFPR) with any of the following documents (other documents may be acceptable as well):

proof of building ownership;
agreement to purchase building or lease that is dependent on zoning or state license approval;
signed lease for the term of the initial license; or
proof of zoning approval or application for zoning approval.

Importantly, if the IDFPR denies the request for an extension or the conditional license holder is unable to become operational within 545 calendar days after being awarded a conditional license, the IDFPR will rescind the conditional license and may proceed to the next applicant drawn. The IDFPR’s regulations define “operational” as obtaining the Annual Adult Use Dispensing License: “In order to become operational, a conditional licensee shall be issued an adult use dispensing organization license pursuant to Section 15-36 of the Act by the conditional license’s expiration date.” In sum, unlike the prior licensing rounds, here you have 545 days to convert your conditional license to an operating license.

For questions about compliance with Illinois’ cannabis regulations or how Greenspoon Marder LLP can assist, please email Irina Dashevsky, Esq. ([email protected]).

About Greenspoon Marder

Greenspoon Marder LLP is a full-service law firm with over 225 attorneys and more than 20 office locations across the United States. With operations from Miami to New York and from Denver to Los Angeles, our firm attracts some of the nation’s top talent in key markets and innovation hubs. Our core practice areas include Real Estate, Litigation, and Transactional Services, complemented by the capabilities of a full-service firm. Greenspoon Marder has maintained a spot on The American Lawyer’s Am Law 200 as one of the top law firms in the U.S. since 2015, and our goal is to provide exceptional client service by developing a thorough understanding of each client’s business needs and objectives in order to provide strategic, cost-effective solutions.

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This Greenspoon Marder LLP Client Alert is issued for informational purposes only and is not intended to be construed or used as general legal advice nor a solicitation of any type. Please contact the author(s) or your Greenspoon Marder LLP contact if you have any questions regarding the currency of this information. The hiring of a lawyer is an important decision. Before you decide, ask for written information about the lawyer’s legal qualifications and experience.

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Illinois Update: Deadline Approaching for Social Equity Criteria Lottery Conditional Licensees

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