New York Med Spa Regulations

Who can inject Botox and dermal fillers in New York?

Injecting neurotoxins (Botox) and dermal fillers is the practice of medicine in New York (Education Law §6521), so it may be performed by a physician (MD/DO) and by a nurse practitioner or physician assistant acting within their delegated/collaborative medical scope. A registered nurse may administer the injection only by executing a patient-specific order from a physician, NP, or PA following an appropriate examination; estheticians and cosmetologists may not inject, and the Department of State's med-spa chart classifies injectables as requiring a medical (not appearance-enhancement) license.

Full guide: Who Can Inject Botox in New York? RN, NP & PA Scope of Practice 2026 →

Source: NY Dept. of State — Med Spa Procedure Licensure Chart (injectable neurotoxins/dermal fillers = Medical license), NY State Board for Medicine — Use of Energy Devices Including Lasers as the Practice of Medicine (§6521; treatments by/under order of physician, PA, or NP; RNs execute orders), NY Office of the Professions — Nurse Practitioner Practice Requirements, NY Education Law Article 131-B — Physician Assistants (delegated medical services under physician supervision), NY Education Law §6902 — RN executes medical regimens prescribed by a licensed provider

Does New York require a good-faith exam before treatment?

New York has no separately named 'good faith exam' statute for med spas; the duty to evaluate the patient flows from the definition of the practice of medicine and professional-misconduct rules. The State Board for Medicine's energy-device guidance expressly requires 'an assessment of the patient's condition before, during, and after the procedure,' and treating or prescribing without an appropriate evaluation is misconduct under Education Law §6530. Telehealth is permitted (Public Health Law Article 29-G / §2999-cc recognizes physicians, NPs, PAs, and RNs as telehealth providers), but the same scope and standard of care apply, so an appropriate history and evaluation must precede treatment or a prescription.

Source: NY State Board for Medicine — Use of Energy Devices Including Lasers (patient assessment required before/during/after any aesthetic treatment), NY Education Law §6530 — Definitions of physician professional misconduct, NY Office of the Professions — Telepractice Guidance (Public Health Law §2999-cc telehealth providers)

Does a med spa in New York need a medical director?

New York imposes no med-spa-specific 'medical director' designation. Because medical services must be delivered through a physician-owned professional entity (corporate-practice-of-medicine rule), the owning/supervising physician(s) are legally responsible for the medical practice; separately, physician assistants require a supervising physician and registered nurses act under the general supervision of a physician, NP, or PA. There is no statute requiring a med spa to name a medical director as such.

Full guide: New York Med Spa Medical Director Requirements 2026: OPMC, Supervision & Delegation →

Source: NY Business Corporation Law §1503 — professional service corporation shareholders must be licensed in the profession, NY Education Law Article 131-B — PA must work under supervision of a physician, NY State Board for Medicine — Use of Energy Devices (treatments by/under order of physician, PA, or NP; RN under general supervision)

Can a non-physician own a med spa in New York?

New York enforces the corporate practice of medicine doctrine. A professional service corporation or PLLC that practices medicine may be organized and owned only by individuals licensed to render that professional service — i.e., licensed physicians — under Business Corporation Law §1503; lay individuals and ordinary business corporations may not own a medical practice or employ physicians to practice medicine, and permitting/aiding unlicensed practice is misconduct under Education Law §6530(11). There is no med-spa exception.

Full guide: Who Can Own a Med Spa in New York? CPOM, PC & MSO Guide 2026 →

Source: NY Business Corporation Law §1503 — only individuals licensed to render the professional service may organize/own a professional service corporation, NY Office of the Professions — Corporate Entities for Professional Practice (medicine under BCL Article 15), NY Education Law §6530(11) — permitting/aiding an unlicensed person to perform licensed activities is misconduct

What supervision does New York require for med-spa procedures?

Physician assistants may perform only medical services delegated by, and under the continuous (not necessarily on-site) supervision of, a physician, and one private-practice physician may supervise no more than six PAs. Nurse practitioners must practice under a written collaborative agreement and protocols with a qualifying physician until they complete 3,600 hours of practice, after which they may practice independently. Registered nurses perform aesthetic medical treatments and injections only by executing orders under the general supervision of a physician, NP, or PA.

Source: NY Education Law Article 131-B — PA supervision requirements and 6-PA limit, NY Office of the Professions — NP Practice Requirements (collaborative agreement until 3,600 hours, then independent), NY State Board for Medicine — Use of Energy Devices (RN executes orders under general supervision), NY Education Law §6902 — RN executes medical regimens prescribed by a licensed provider

What can an esthetician legally do in New York?

Estheticians and cosmetologists are licensed by the Department of State under the Appearance Enhancement law (General Business Law Article 27) and are limited to surface/epidermal skin care — facials, cleansing, exfoliation, masks, superficial chemical peels, microdermabrasion, dermaplaning, and laser/IPL hair removal. They may not inject neurotoxins or fillers, perform medium/deep chemical peels, use energy devices that reach the dermis or deeper, or perform microneedling; those are the practice of medicine (microneedling is routed to an acupuncture license) and fall outside the appearance-enhancement scope.

Source: NY Dept. of State — Appearance Enhancement Scope-of-Practice Determinations, NY Dept. of State — Med Spa Procedure Licensure Chart, NY State Board for Medicine — Use of Energy Devices (Class I surface devices may be used by non-licensed aestheticians; dermal+ devices are practice of medicine)

Who can operate a cosmetic laser in New York?

The New York State Board for Medicine determined (March 7, 2025) that use of any energy device or laser affecting the basement membrane or deeper tissue (dermis, fat) to treat a physical condition is the practice of medicine; such treatments must be conducted by or under the order of a physician, physician assistant, or nurse practitioner, and among non-physician staff only a registered nurse (under general physician/PA/NP supervision) may execute those orders. Laser/IPL hair removal is specifically excluded and, along with other surface/epidermal Class I–IIIa devices, may be performed by trained non-licensed personnel such as estheticians (Class II–IIIa under supervision).

Full guide: New York Laser Safety Regulations for Med Spas 2026: Who Can Operate →

Source: NY State Board for Medicine — Use of Energy Devices Including Lasers as the Practice of Medicine (2025 determination; device classification table), NY Dept. of State — Med Spa Procedure Licensure Chart (laser hair removal = DOS license; other laser = Medical)

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

IV vitamin/hydration therapy is classified as the practice of medicine in New York because it introduces substances directly into the bloodstream, so it must be ordered by a physician, NP, or PA following an appropriate patient evaluation. A registered nurse may start the IV and administer the infusion by executing that order under general supervision; estheticians and cosmetologists may not perform IV therapy.

Source: NY Dept. of State — Med Spa Procedure Licensure Chart (IV therapy/vitamin infusions = Medical license), NY Education Law §6902 — RN executes medical regimens (including administering infusions) prescribed by a licensed provider, NY State Board for Medicine — Use of Energy Devices (RN is the only non-physician professional authorized to perform patient assessments/execute orders)

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

New York has no dedicated 'medical spa' license or registration category. A med spa offering medical services must operate through a physician-owned professional entity (PC or PLLC) authorized by the State Education Department, while any appearance-enhancement services require Department of State appearance-enhancement business and operator licenses. The state routes each procedure to an existing license category rather than licensing 'med spas' as such.

Source: NY Dept. of State — Med Spa Procedure Licensure Chart (procedures routed to Medical vs. DOS licenses; no med-spa license category), NY Business Corporation Law §1503 — medical services provided through a licensee-owned professional service corporation, NY Office of the Professions — Corporate Entities for Professional Practice

What are the penalties for practicing outside scope in New York?

Practicing medicine (or any licensed profession) without a license, practicing on a suspended/revoked license, or aiding and abetting unlicensed practice is a Class E felony under Education Law §6512. Licensed physicians additionally face professional-misconduct charges under Education Law §6530 — including practicing beyond the authorized scope (subd. 24), delegating professional responsibilities to an unqualified person (subd. 25), and permitting/aiding an unlicensed person to perform licensed activities (subd. 11) — prosecuted through the Department of Health's Office of Professional Medical Conduct, with sanctions up to license revocation and monetary penalties.

Source: NY Education Law §6512 — Unauthorized practice a crime (Class E felony), NY Education Law §6530 — Definitions of physician professional misconduct (subds. 11, 24, 25)