California Med Spa Regulations

Who can inject Botox and dermal fillers in California?

California has no med-spa-specific statute; injecting Botox or dermal filler is the practice of medicine (BPC 2052). Physicians (MD/DO) may inject directly; NPs and PAs may inject within their scope under standardized procedures or a practice agreement (BPC 2836.1, 3502); RNs may inject only under physician delegation and a standardized procedure or patient-specific order issued after a good faith exam (BPC 2725). LVNs, medical assistants, and estheticians may not inject.

Full guide: Who Can Inject Botox in California? RN, LVN & Esthetician Rules (2026) →

Source: BPC 2052 (unlicensed practice = practice of medicine), BPC 2725 (RN administers medications ordered by physician; standardized procedures), BPC 2836.1 (NP furnishing/ordering drugs & devices), BPC 3502 (PA under practice agreement/supervision), Medical Board of California — Medical Spas

Does California require a good-faith exam before treatment?

A good faith prior examination is required before furnishing the dangerous drugs and prescriptive devices used in cosmetic injectables (BPC 2242), and it must be performed by a licensed prescriber (physician, NP, or PA), not delegated to an RN. The statute expressly permits the exam to be conducted via telehealth, including asynchronous self-screening tools or questionnaires, provided the licensee meets the standard of care.

Source: BPC 2242 (prescribing without appropriate prior exam is unprofessional conduct; telehealth permitted)

Does a med spa in California need a medical director?

California does not use a 'medical director' model and has no statutory med-spa medical-director designation; instead the medical practice itself must be owned and controlled by a physician (BPC 2400). The Medical Board of California's own guidance states that the practice of lay-owned businesses hiring a physician as 'medical director' is prohibited, and that a physician who acts as medical director of a lay-owned business is aiding and abetting the unlicensed practice of medicine.

Full guide: California Med Spa Medical Director Requirements 2026: Complete Guide →

Source: BPC 2400 (corporations/artificial entities have no professional rights, privileges, or powers — statutory basis for the corporate-practice-of-medicine prohibition), Medical Board of California — Medical Spas (medical spas offering medical procedures 'must be owned by physicians'), Medical Board of California — 'The Bottom Line: The Business of Medicine – Medical Spas' (lay-owned business hiring a physician as 'medical director' is prohibited; physician is 'aiding and abetting the unlicensed practice of medicine,' citing Precedential Decision MBC-2007-01-Q, In re Joseph F. Basile)

Can a non-physician own a med spa in California?

California strictly enforces the corporate practice of medicine: corporations and unlicensed persons have no professional rights, privileges, or powers (BPC 2400), and a med spa offering medical procedures must be physician-owned. A professional medical corporation must be at least 51% owned by licensed physicians (remaining shares only to other licensed health professionals), so non-physician entrepreneurs typically use a management services organization (MSO) that contracts with the physician-owned corporation.

Full guide: Who Can Own a Med Spa in California? NP Ownership & CPOM Rules (2026) →

Source: BPC 2400 (corporate practice bar), BPC 2052 (practicing medicine without a license), Medical Board of California — P&S Practice Information (CPOM guidance)

What supervision does California require for med-spa procedures?

RNs perform delegated cosmetic procedures under a standardized procedure or patient-specific order; the supervising physician need not be onsite but must be immediately reachable (BPC 2725; Medical Board Medical Spas guidance). PAs work under a practice agreement with a supervising physician (BPC 3502), and NPs furnish or order drugs and devices under standardized procedures (BPC 2836.1) — except AB 890 '103/104' full-practice-authority NPs, who may practice without standardized procedures.

Source: BPC 2725 (RN standardized procedures), BPC 3502 (PA practice agreement/supervision), BPC 2836.1 (NP furnishing under physician supervision), Board of Registered Nursing — AB 890 (103/104 NP full practice authority), Medical Board of California — Medical Spas (physician immediately reachable)

What can an esthetician legally do in California?

An esthetician/cosmetology license confers no authority to practice medicine or surgery (BPC 7320); estheticians are limited to the epidermis and may not perform procedures that remove, destroy, incise, or pierce the skin beyond the epidermis (16 CCR 991). The Medical Board confirms cosmetologists/estheticians may never inject the skin, operate lasers, or perform medical-level dermabrasion or skin peels.

Full guide: California Esthetician & Advanced Skin Scope 2026: Peels, Microneedling & Med Spa Rules →

Source: BPC 7320 (cosmetology license confers no authority to practice medicine), Medical Board of California — Medical Spas (cosmetologists may never inject/laser/peel)

Who can operate a cosmetic laser in California?

Operating a laser or IPL device on living tissue is the practice of medicine, and the Medical Board permits it only for a physician, or a registered nurse or physician assistant under a physician's supervision (NPs likewise qualify under their furnishing/standardized-procedure authority). Estheticians, medical assistants, and LVNs may not operate medical lasers, and a supervising physician who lets them aids the unlicensed practice of medicine.

Full guide: California Laser Safety for Med Spas 2026: Who Can Operate & Supervision Rules →

Source: Medical Board of California — Medical Spas (physician, RN, or PA under supervision may use lasers), BPC 2052 (laser on living tissue = practice of medicine), BPC 2836.1 (NP may order/furnish devices)

What are the rules for IV therapy and vitamin drips in California?

California has no IV-specific med-spa statute; IV infusions (hydration, vitamin/'drip' therapy) involve prescriptive drugs, so they require a licensed prescriber's order following a good faith exam (BPC 2242) and are administered by an RN implementing a physician-ordered regimen or standardized procedure (BPC 2725). LVNs may start IVs only with additional certification and never practice independently.

Source: BPC 2725 (RN administers medications/therapeutic agents ordered by a physician), BPC 2242 (good faith exam before furnishing dangerous drugs)

Does a med spa have to register or hold a license in California?

California has no med-spa-specific license, permit, or state registry; a med spa is simply a physician's medical practice governed by the Medical Practice Act and the corporate-practice-of-medicine doctrine. The business must be physician-owned and the treating physician licensed by the Medical Board — there is no separate 'med spa' credential or facility registration.

Source: Medical Board of California — Medical Spas (must be physician-owned; no separate med-spa license), BPC 2052 (medical procedures require a licensed physician)

What are the penalties for practicing outside scope in California?

Practicing medicine without a license — including a non-physician performing injections or laser procedures — is a public offense punishable by a fine up to $10,000 and/or imprisonment (county jail up to one year, or state prison under Penal Code 1170(h)) (BPC 2052). Conspiring with or aiding and abetting unlicensed practice carries the same penalties, and physicians additionally face Medical Board discipline and possible facility closure.

Source: BPC 2052 (penalties for unlicensed practice and aiding/abetting)