Illinois Med Spa Regulations

Who can inject Botox and dermal fillers in Illinois?

Injecting botulinum toxin, dermal fillers, and weight-loss or vitamin injections is the practice of medicine in Illinois. A physician licensed to practice medicine in all its branches (MD/DO) may perform and prescribe these, and a full-practice-authority APRN may prescribe and administer legend and controlled drugs within scope; a physician may delegate the administration to a physician assistant, registered nurse, or other trained person within a physician-patient relationship, so an RN or PA injects only under physician delegation.

Full guide: Who Can Inject Botox in Illinois? (2026 Scope Rules) →

Source: IDFPR/IDPH Memo Regarding Medical Spa Services (updated 10/30/2025) — physician authority to prescribe/administer Botox and weight-loss injections, APRN authority under 225 ILCS 65/65-43, and physician delegation under 225 ILCS 60/54.2

Does Illinois require a good-faith exam before treatment?

A good-faith examination is required. IDFPR's Statement on Prohibited Practices states that for delegated medical procedures at a medspa (e.g., Botox, chemical peels, collagen injections, microneedling, Radio Frequency), 'the person receiving the services must be a patient of the physician (there must be a physician/patient relationship), the physician must examine the patient and determine the appropriateness and the course of treatment.' The IDFPR/IDPH medspa memo confirms this applies to lasers too: 'The physician must examine the patient and determine an appropriate course of treatment before laser procedures are performed.' No fetched Illinois primary source authorizes performing this physician exam via telehealth for cosmetic injectables (Botox, fillers, weight loss injections) — the general telemedicine statute, 225 ILCS 60/49.5, is a jurisdictional/licensing provision for out-of-state practitioners and does not address the in-person-vs-telehealth standard for a medspa good-faith exam. The only telehealth-adjacent carve-out found is narrower and laser-specific: for non-ablative laser procedures only, the memo states a physician may satisfy on-site supervision by instead 'be[ing] available by telephone or other electronic means to respond promptly to any question or complication,' and, per a Medical Practice Act amendment effective January 1, 2025, an on-site physician exam before a non-ablative laser procedure is not required at all if (1) the facility follows a physician delegation protocol, (2) the exam is instead performed by an APRN, (3) the procedure is delegated to and performed by a trained RN/LPN, and (4) the physician remains available by phone/electronic means for questions or complications. That is delegation of the exam to an APRN (or a documented waiver for non-ablative laser only), not a physician conducting the good-faith exam itself via telehealth, and it does not extend to cosmetic injectables. Given the absence of any source blessing telehealth for the physician's own good-faith exam, telehealth_ok is set to false.

Source: IDFPR Statement on Prohibited Practices (04/06/2026) — 'The person receiving the services must be a patient of the physician (there must be a physician/patient relationship), the physician must examine the patient and determine the appropriateness and the course of treatment, and the person receiving the physician delegation must carry out the treatment as instructed.' (governs Botox, chemical peels, collagen injections, microneedling, RF, etc.), IDFPR/IDPH Medical Spa Memo (updated 10/30/2025) — 'The physician must examine the patient and determine an appropriate course of treatment before laser procedures are performed'; the phone/electronic-availability option applies only to on-site supervision of delegated NON-ABLATIVE laser procedures, and the narrower on-site-exam waiver (effective 1/1/2025) applies only when the exam is instead performed by an APRN under a delegation protocol for non-ablative laser hair removal — neither provision authorizes a physician performing the good-faith exam itself via telehealth, and neither extends to cosmetic injectables, 225 ILCS 60/49.5 (Illinois Medical Practice Act — Telemedicine), via FindLaw — defines telemedicine as rendering opinions on diagnosis/treatment of an Illinois patient from a remote location via transmitted patient data, and addresses only licensing/jurisdiction for out-of-state practitioners (with narrow exclusions for periodic consults, second opinions, and existing-patient/travel scenarios); contains no language establishing physician-patient relationship formation, exam standards, or good-faith exams, so it does not support a claim that telehealth GFE is generally permitted for medspa procedures

Does a med spa in Illinois need a medical director?

Illinois has no separate 'medical director' statute for medspas; instead the Medical Practice Act and corporate-practice-of-medicine doctrine require that a physician (or an APRN within their scope) actually own and be medically responsible for the practice, personally performing or delegating every medical procedure within a physician-patient relationship. The common out-of-state model of a lay-owned spa hiring a contracted medical director is not permitted, because the responsible physician must be an owner rather than merely a supervisor-for-hire.

Full guide: Illinois Med Spa Medical Director Requirements (2026) →

Source: IDFPR/IDPH Memo — medspas must be owned and operated by physicians (or APRNs for services in scope); medical procedures must be performed or delegated by a licensed physician within a physician-patient relationship

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

Illinois aggressively enforces the corporate practice of medicine. A medspa must be owned and operated by physicians, and for services within their scope may be owned by APRNs; only physicians may organize under the Medical Corporation Act, and physicians or APRNs may organize under the Professional Service Corporation or Professional Limited Liability Company Acts. A person who is not a physician or an APRN cannot be a shareholder, member, officer, director, or manager, so laypersons are barred from ownership and may only provide non-clinical services through a management services organization (MSO).

Full guide: Who Can Own a Med Spa in Illinois? (2026 CPOM Rules) →

Source: IDFPR/IDPH Memo, 'Ownership and Entity Restrictions' — only physicians may organize under the Medical Corporation Act; APRNs limited to PSC/PLLC; non-physician/non-APRN cannot be an owner, officer, director, or manager

What supervision does Illinois require for med-spa procedures?

A physician delegates medical tasks only within a physician-patient relationship and only to persons whose training and scope fit the task; when delegating to an unlicensed person, a licensed health care professional must be on site. For lasers, ablative procedures delegated to an RN/LPN/full-practice APRN require on-site physician supervision, while non-ablative procedures require on-site supervision or a physician available by telephone/electronic means; procedures that could disrupt the eye may not be delegated at all.

Source: IDFPR/IDPH Memo — delegation limits under 225 ILCS 60/54.2 and laser supervision rules under 68 Ill. Admin. Code 1285.336 (on-site vs. telephone availability; ablative vs. non-ablative)

What can an esthetician legally do in Illinois?

Cosmetologists and estheticians are prohibited from using any technique, product, or practice intended to affect the living layers of the skin and may not treat medical disorders. IDFPR expressly lists Botox, chemical peels (other than superficial), collagen injections, colonics, liposuction, microblading, microneedling, and radiofrequency as the practice of medicine outside esthetician scope, and an individual performing any physician-delegated medical procedure may not hold themselves out as an esthetician while doing so.

Full guide: Illinois Esthetician & Advanced Skin Scope 2026: The Rules →

Source: IDFPR Statement on Prohibited Practices — list of procedures that constitute the practice of medicine and are outside esthetician/cosmetologist scope; prohibition on affecting the living layers of skin per 225 ILCS 410/3-1 and 3A-1, IDFPR/IDPH Memo, 'Medical esthetics and other professions' — cosmetologists and estheticians prohibited from techniques affecting living layers of skin; salon registration cannot be used to operate a medspa

Who can operate a cosmetic laser in Illinois?

Use of lasers and related energy devices (IPL, radiofrequency, medical microwave, and similar devices that disrupt the epidermal surface) is the practice of medicine and must be performed by a licensed physician unless delegated. A physician may delegate ablative procedures to an RN, LPN, or full-practice-authority APRN with on-site supervision, and non-ablative procedures to those same persons or others with on-site supervision or the physician available by phone; the delegate must have documented training in each system, and eye-risk procedures may not be delegated.

Full guide: Illinois Laser Safety for Med Spas 2026: Who Can Operate →

Source: IDFPR/IDPH Memo, 'Lasers' — laser use is the practice of medicine performed by a physician; delegation of ablative/non-ablative procedures to RN, LPN, full-practice APRN, or others per 68 Ill. Admin. Code 1285.336 and 225 ILCS 60/54.2

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

Illinois has no IV-therapy-specific statute, but IDFPR lists injections of weight-loss medications and vitamins among the medical procedures performed at medspas, meaning IV hydration and vitamin/injectable therapy are the administration of drugs and thus the practice of medicine. They require a physician or APRN order following a good-faith examination, and an RN may administer under physician delegation within a physician-patient relationship.

Source: IDFPR/IDPH Memo — injections of weight-loss medications and vitamins listed as medspa medical procedures; physician prescribing/administration and delegation framework

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

There is no standalone 'med spa license' in Illinois. A medspa must organize as a medical corporation, professional service corporation, or professional limited liability company, file appropriate articles with the Illinois Secretary of State, and register with and be regulated by IDFPR. A facility that also offers cosmetology or esthetics services must additionally obtain a shop or salon registration under 225 ILCS 410/3D-5 and may not use a business name containing 'medical' terminology.

Source: IDFPR/IDPH Memo, 'Ownership and Entity Restrictions' — medspas organized as PLLC/PSC/medical corporation must register with and are regulated by IDFPR and file with the Secretary of State; salon registration under 225 ILCS 410/3D-5, no 'medical' name

What are the penalties for practicing outside scope in Illinois?

IDFPR is one of the most active states enforcing medspa compliance. The unlicensed practice of medicine and unlicensed practice of nursing draw civil penalties and cease-and-desist orders, and licensed professionals face suspension, probation, or revocation. IDFPR's October 2025 enforcement report documents an $8,500 civil penalty for the unlicensed practice of nursing, a cease-and-desist order against an individual for the unlicensed practice of medicine including performing Botox injections, and a salon reprimanded and fined for unsanitary conditions.

Source: IDFPR October 2025 Enforcement Report — $8,500 civil penalty for unlicensed practice of nursing; cease-and-desist for unlicensed practice of medicine including Botox injections; salon fined for unsanitary conditions