What License Do You Need To Open A Medical Spa?

If you want to open a medical spa, you'll need to meet several legal requirements before you see your first client. Each state has its own set of rules, but most med spas need business licenses, proper medical oversight, and careful documentation from the start.

If you skip any compliance steps, regulators can shut you down, fine you, or even file criminal charges. So, the most important thing you can do before launch is to nail down the licenses and structure you need to operate legally and safely.

Opening a med spa means blending medicine and business. It’s more than a great location or fancy treatments. The hardest part? Navigating complex, confusing regulations. Unlike traditional spas, med spas follow medical practice laws, and these differ a lot from state to state.

These laws decide who can own a med spa, who can perform treatments, what kind of supervision is needed, and what license is required to open.

What Licenses Do Med Spas Need Before Opening?

The licenses you’ll need depend on your state, your role, and what treatments you want to offer. Most med spas need these core licenses and permits:

• Business License: This is the standard license from your city or county to open any business.
• Medical License: In a lot of states, the owner or medical director needs to have an active medical license. Sometimes, the owner must be a physician.
• Professional Licenses: Anyone doing medical procedures has to have the right license. That could be a physician, nurse practitioner, physician assistant, registered nurse, or a licensed aesthetician depending on the treatment.
• Health Department Permits: These prove you follow safety and sanitation standards.
• Certificate of Occupancy: This shows your facility meets local building and safety codes.

Don’t assume the requirements are the same everywhere. California and Illinois require med spa owners to be state-licensed physicians. Florida lets you own a med spa without medical training, but only licensed pros can perform medical procedures. Always secure all the federal, state, and local licenses before you serve clients.

State Regulations and Scope of Practice

Most med spa rules come from state agencies. Each state has a medical board, nursing board, and sometimes a pharmacy board. They decide what types of licensed professionals can do which procedures, and how much supervision each procedure needs.

State laws also outline who can own a med spa, how much supervision is needed, and what falls under scope of practice. Some states only allow physicians to own and run medical spas, but others let nurse practitioners or even management service organizations (MSOs) operate with a physician looking over the medical side.

You should always identify every law that applies — federal, state, or local. That includes the rules around the corporate practice of medicine, who can do which medical treatments, and all safety standards.

Keep in mind, state laws don’t stay the same. You need a system for staying up to date with new rules. Lots of states introduced bills in 2025 to expand what advanced practitioners can do or to change licensing.

Understanding the Corporate Practice of Medicine

Corporate practice of medicine (CPOM) laws stop non-licensed people or companies from running medical practices or affecting medical decisions. In lots of states, only doctors can own medical practices or hire physicians. The goal is to make sure business interests don't interfere with medical decisions.

Some states won’t let non-physicians own a medical spa. In those cases, you may need a physician-owned professional corporation (PC), or you can use an MSO model. The PC handles clinical care, while your LLC or another company manages the business side.

MSOs are an option if you aren’t a doctor but want to be involved. An MSO is owned by non-physicians and they handle management services like marketing, hiring, billing, and office work. The key is that the MSO can’t influence how medical care is delivered.

You’ll want to talk with a healthcare business attorney to find out the right structure for your state. Platforms like Portrait include payment processing that’s designed to meet CPOM rules, so your billing stays on the right side of the law.

Physician Oversight and Collaborative Requirements

Physician oversight is crucial if you’re running a medical spa. Most states see aesthetic treatments as medical, so you’ll always need a physician supervising directly or indirectly. Rules for this change by state and procedure. Sometimes, the physician must be in the building, other times, they can be available by phone or just set protocols.

The supervising physician can’t just sign paperwork and disappear. They have to be trained in the procedures, involved in operations, and they’re legally responsible for all actions delegated to other providers.

Your medical director is a must-have. This person is responsible for your protocols, supervision, patient selection, managing unwanted events, and keeping your quality up to standards.

Lots of states require a Good Faith Exam (GFE) before you treat a patient. A GFE is a full medical assessment by a licensed provider before any treatment. Most states say a physician, PA, or advanced practice nurse must do these exams. California needs a physician or NP with doctor supervision, and in Texas only a physician can supervise.

If you’re looking for help, Portrait offers medical director matching, scheduling, and oversight tools to make staying compliant much easier. These help automate paperwork and scheduling, making sure your GFE requirements are covered.

Other Legal Considerations for Med Spa Operation

Compliance for med spas means more than just getting licenses. You must manage privacy, safety, documentation, and marketing closely. Here’s what you can’t skip:

• HIPAA and data privacy: You have to keep patient health info private. HIPAA sets the rules, and it applies even if you don’t take insurance. Set up secure EHRs, encrypt data, use strong passwords, and track access. We keep to strict HIPAA rules and protect your info.
• OSHA and workplace safety: OSHA sets safety standards for your staff. You need personal protective equipment, bloodborne pathogen training, hazard communication, and safe medical waste disposal. OSHA covers these areas for every med spa.
• FDA, FTC, and marketing: FDA controls medical devices, drugs, and biologics you use, so you must stick to approved uses and proper labeling. FTC keeps marketing honest — no false claims or unrealistic promises. Every claim should be true and backed by evidence.
• Facility standards and infection control: State and local health departments require proper sanitation, registered devices, safe chemical use, and solid waste management plans for sharps and biohazards. You should follow OSHA and CDC infection control standards every day.
• Record-keeping and EHR: Detailed records are a basic compliance step. Portrait’s EHR and CRM system helps you manage patient details, treatment plans, and secure communications with HIPAA compliance built in.

Practical Steps to Ensure Compliance

Here’s how to build and run a medical spa that meets all the rules, including what license you need to open your medical spa:

1. Research state requirements: Start with licensing, permits, and certifications for your treatments. Review sanitation and medical device rules, chemical safety, and check local zoning.
2. Pick the right business structure: Your LLC, PC, or MSO setup must fit your state’s CPOM laws. Always check with a healthcare lawyer.
3. Get licenses and permits before opening: Secure your business license, medical licenses, health permits, and certificate of occupancy.
4. Appoint a medical director: This person is responsible for all your protocols and supervision. Check that they’re qualified and licensed.
5. Create a compliance manual: Keep a handbook for your policies, regulatory requirements, safety protocols, HIPAA processes, and emergency procedures. Update it regularly as rules change.
6. Define everyone’s role: Make sure every staff member knows what they legally can and can’t do.
7. Implement informed consent: Always document risks and alternatives before any procedure.
8. Safe patient privacy: Use HIPAA-compliant systems, train staff, and protect all data.
9. Stay updated: Monitor new laws regularly and consider bringing in a compliance pro or software partner that focuses on healthcare rules.
10. Run risk checks: Use software to track staff licenses and training, check equipment, and spot gaps in your compliance plan.

Portrait has easy-to-use templates, step-by-step guides, and regular updates for clinics, plus medical support to keep your spa ready for any inspection.

How Portrait Can Support Licensing and Compliance

Our goal at Portrait is to be your go-to compliance partner. Our platform brings together simple software, real business services, and clear pricing. We make compliance easy from opening day to your busiest week.

With our launch support, we help with licensing, business setup, branding, and more—so you can open quickly and focus on your clients. Our compliance tools cover MD matching, automated GFEs, supervision, policies, and even malpractice coverage.

We’ve teamed up with healthcare law experts from ByrdAdatto to give you ongoing legal support and access to the best compliance advice. State and license requirements change all the time, and small mistakes can cost big. That’s why our tools and support make complicated rules easy to follow for everyone, not just experienced med spa owners.

The compliance hub gives you the latest information, documentation tips, and advice on safety and ethics. Over 800 spas and clinics have stayed compliant with our help, so owners, medical directors, and patients can feel confident.

Get Your Medical Spa Licensed and Open, Fast

So, what license do you need to open a medical spa? It comes down to your state, who owns the spa, and what services you’ll offer. Still, the most common things you’ll need are:

• Business licenses
• Medical licenses for providers
• Health department permits
• Compliance with state medical boards, CPOM laws, and federal HIPAA, OSHA, and FDA rules

Opening a med spa is setting up a real healthcare business with a relaxing vibe. You’ll need to follow all medical practice laws, scope of practice rules, ownership rules, and federal requirements. Compliance isn’t a "nice-to-have". It’s absolutely required.

Portrait helps you stay on track with legal paperwork, finding the right medical director, building Good Faith Exam workflows, and using HIPAA-safe, easy EHRs—all in one simple platform. You get to stay safe, legal, and spend your time helping patients instead of worrying about red tape.

If you’re ready to open your own med spa, check out how Portrait can help you launch and grow with compliance support and the right clinical partners.