On March 20, 2020, in light of the growing COVID-19 pandemic and its expected impacts in Illinois, the Illinois Power Agency adopted the following emergency amendment to its Adjustable Block Program and Illinois Solar for All Program Marketing Guidelines:

In-person marketing and solicitation: Given the public health emergency posed by the COVID-19 virus, in-person marketing or solicitation of photovoltaic system sales, installations, or financing; in-person marketing or solicitation of community solar subscriptions; or similar in-person solar marketing or solicitation activity are prohibited.

Clarifications and updates to this prohibition were offered on May 19, 2020; June 4, 2020; June 30, 2020; August 5, 2020; and October 7, 2020.

This update confirms that the IPA’s prohibition of door-to-door sales and solicitation remains in place while offering an additional clarification regarding its scope.

Regarding the basis for the IPA’s door-to-door sales prohibition, the statewide COVID-19 positivity rate (the percentage of positive tests across total tests given) is over 4% (whether as a measure of cases or tests), and daily totals for both confirmed cases and fatalities in Illinois remain a significant public health concern.  While the IPA is encouraged by climbing vaccination rates, efforts should continue to be made to protect against a recurrent spike in COVID-19 transmission through curbing unnecessary—and especially unwanted—person-to-person contact.

Thus, in the interest of protecting public health, door-to-door sales remains a prohibited sales channel under solar incentive programs administered by the IPA (the Adjustable Block Program and Illinois Solar for All Program) and entities found violating this prohibition may be suspended from program participation.

To respond to a common misperception, the IPA’s program-related prohibition does not legally bar such conduct generally.  Where otherwise consistent with state or local requirements, entities are not legally prohibited from door-to-door marketing of rooftop solar or community solar subscriptions.  However, as an entity tasked with administering public incentive funding to support those transactions, the IPA is dedicated to ensuring that an endorsement of transactions or vendors made through publicly administered funding should only be made for those operating in the broader public interest.

One such requirement is not marketing door-to-door during a global health pandemic.  As performing door-to-door solicitations during a global health pandemic is not consistent with public health interests, entities found to be engaged in door-to-door sales may be suspended from benefitting from publicly administered incentive funding disbursed under IPA programs.  Stated differently, entities found to be operating against the public interest risk forfeiting public support.

While the Agency will continue to monitor available public health information, including vaccination-related information, as part of an ongoing assessment of the propriety of this prohibition, this prohibition shall remain in place until a formal announcement indicating otherwise is made by the Illinois Power Agency.  At present, the IPA has no known timetable for such an announcement.


A reiteration of prior-offered clarification is provided below:

As an additional clarification, whether a salesperson is vaccinated has no bearing on the permissibility of door-to-door sales and solicitations.

The IPA will endeavor to provide more frequent updates as the public health situation continues to evolve.  Additionally, prior-issued guidance regarding best practices remains in effect.

Should you have questions about whether specific practices are permitted, please contact IPA Chief Legal Counsel Brian Granahan at [email protected].