Medical Spa Requirements In California

Thinking about starting a med spa in California? You're not alone. With non-invasive treatments growing in popularity, more professionals are eyeing the opportunity. But here's the catch: California has some of the strictest medical spa regulations in the country. So, before you rent a space or buy that laser machine, let’s unpack exactly what the state expects.

Understanding Medical Spa Licensing in California

What qualifies as a medical spa?

A medical spa isn’t just a place that offers facials and massages. The moment your spa offers treatments like Botox, laser resurfacing, or microneedling, California sees it as a medical practice.

Here’s why that matters:

• These services require medical judgment.
  
  
• The provider must have a valid medical license.
  
  
• You can’t just hire a technician off Craigslist and start injecting fillers.
  
  

In short, if there’s a needle, laser, or prescription involved, you’re under the Medical Board’s radar.

Who can legally own and operate one?

In California, only licensed physicians or a Professional Corporation (PC) made up of licensed physicians can legally own a medical spa. That means:

• Non-doctors can’t own or control the clinical side.
  
  
• But they can run the business through a Management Services Organization (MSO)—a legal workaround used by many med spas.
  
  

Without this structure? You risk being fined or shut down.

Staffing Rules and Supervision Standards

Required medical professionals on-site

You can’t just hang your shingle and call it a med spa. Your team needs the right credentials.

Here’s a quick breakdown:

• Doctors (MD/DO) – Must supervise or consult.
  
  
• Nurse Practitioners (NP) – Can operate independently under protocols.
  
  
• Physician Assistants (PAs) – Need supervision agreements.
  
  
• Registered Nurses (RN) – Can perform certain procedures but need oversight.
  
  
• Licensed Vocational Nurses (LVN) – Limited scope and always supervised.
  
  
• Estheticians – Can’t touch medical treatments.
  
  

Each title comes with a scope. Go outside it? You’re playing with fire.

Supervision protocols and delegation

The doctor doesn’t have to be there every second. But they must provide adequate supervision.

Depending on the procedure:

• Some tasks need direct supervision (doctor in the building).
  
  
• Others are okay with general supervision (doctor available by phone).
  
  

You can delegate some treatments to nurses or techs, but only if:

• They're trained,
  
  
• They're supervised,
  
  
• And the treatment falls within their scope.
  
  

Treatment Types and Legal Scope

Common aesthetic procedures allowed

In California, med spas offer a buffet of treatments, including:

• Botox and dermal fillers
  
  
• PRP (platelet-rich plasma) therapy
  
  
• Laser hair removal
  
  
• Chemical peels
  
  
• Body contouring
  
  
• Microneedling with or without radiofrequency
  
  

These treatments? They're legal—but only if the right people perform them.

Who can perform which treatments?

Here’s a simple guide:

Treatment	Allowed Providers
Botox/Fillers	MD, NP, PA, RN (with supervision)
Laser Hair Removal	MD, NP, PA, RN
Microneedling	MD, NP, PA, RN (with device clearance)
Chemical Peels	RN, esthetician (non-medical peels only)

Unlicensed staff performing injections? That’s a lawsuit waiting to happen.

Compliance with State Regulations

Advertising and informed consent rules

You can't just promise "miracle results” or “instant transformations” in your ads. Why?

Because:

• California considers exaggerated claims false advertising.
  
  
• Only licensed providers can appear in ads offering treatments.
  
  

Also, patients must sign informed consent forms before any procedure. These forms should:

• Describe risks clearly.
  
  
• List who’s doing the procedure.
  
  
• Be signed before any needle comes out.
  
  

Recordkeeping, HIPAA, and patient safety

Your spa isn’t just a business—it’s a medical clinic in the eyes of the law. That means:

• Keep medical records for 7 years.
  
  
• Follow HIPAA rules—no patient selfies without signed release forms.
  
  
• Keep equipment calibrated and clean.
  
  

Slip up here? It’s not just a bad Yelp review. It’s a possible license suspension.

Setting Up a Med Spa in California Legally

Business structure and corporate practice of medicine

California prohibits the corporate practice of medicine. That means regular LLCs can’t run med spas unless:

• A physician owns the clinic,
  
  
• Or there’s a formal MSO structure with a management agreement.
  
  

Many med spas use a dual structure:

• Professional Corporation (PC) runs the medical side.
  
  
• MSO handles marketing, leasing, and HR.
  
  

It’s legal, as long as the lines don’t blur.

Permits, certifications, and insurance

Before opening, check your city’s zoning laws. Some cities require:

• Conditional use permits,
  
  
• Health inspections,
  
  
• Business licenses specific to personal services.
  
  

And don’t skip malpractice and business insurance. You’ll want coverage for:

• General liability,
  
  
• Professional errors,
  
  
• Cyber risks (if storing patient data online).
  
  

Conclusion

Opening a med spa in California isn’t impossible, but it does come with strict legal strings. From who can own it, to who can touch a syringe, to how you word your ads—everything’s regulated. But once you get the rules down and build your team right, the opportunity is huge.

Don’t cut corners. Get the structure right. And when in doubt? Talk to a healthcare attorney before launching. A little planning now could save you from a mountain of fines later.