Who can perform med spa treatments in California
Who is allowed to do Botox, fillers and laser treatments in a California med spa?
Injectables and medical lasers are limited to three license types
In a California med spa, neurotoxin and filler injections and medical laser treatments may be performed by physicians, and by registered nurses or physician assistants under physician supervision.
The Medical Board's med spa page states that medical treatments should be performed by medical professionals only, meaning a physician, or a registered nurse or physician assistant under the supervision of a physician. Its longer guidance names nurse practitioners alongside them and adds that lasers, other prescriptive devices and prescriptive drugs must only be used by licensed registered nurses, nurse practitioners or physician assistants when delegated.
The underlying reason is that these are prescription drugs and devices. The Board's guidance says the use of prescriptive drugs and devices for cosmetic reasons is the practice of medicine, with no separate, lighter set of rules for aesthetic work.
| Role | Prior exam | Injections and medical lasers | Supervision |
|---|---|---|---|
| Physician | Yes | Yes | Not applicable |
| Nurse practitioner | Yes, under standardized procedures | Yes | Standardized procedures, or independent practice under B&P 2837.103 |
| Physician assistant | Yes, if delegated | Yes | Supervising physician; at most 8 PAs per physician |
| Registered nurse | No | Yes, after physician or NP exam | Standardized procedures; physician immediately reachable |
| Esthetician or cosmetologist | No | No | Not permitted to inject or use lasers |
The Medical Board states that med spa medical treatments should be performed only by a physician, or a registered nurse or physician assistant under physician supervision. — Medical Board of California, retrieved 2026-09-27
The Medical Board's guidance states that lasers, other prescriptive devices and prescriptive drugs must only be used by licensed registered nurses, nurse practitioners or physician assistants. — Medical Board of California, retrieved 2026-09-27
The prior examination comes before any prescription treatment
Before a patient receives neurotoxin, filler or a prescriptive laser treatment, a physician, nurse practitioner or physician assistant must perform an appropriate prior examination.
Business and Professions Code 2242 makes prescribing, dispensing or furnishing dangerous drugs without an appropriate prior examination and a medical indication unprofessional conduct. The Board of Registered Nursing puts it plainly for med spas: patients must be examined by a physician or an advanced practitioner, such as a nurse practitioner or physician assistant, before treatments are administered.
The Medical Board's guidance adds that this examination may not be delegated to a registered nurse. A nurse practitioner acting under standardized procedures may perform it and order the drug or device. The statute also permits the exam to take place by telehealth where that meets the standard of care.
B&P 2242B&P 2242 makes prescribing, dispensing or furnishing dangerous drugs without an appropriate prior examination and a medical indication unprofessional conduct. — California Legislative Information, retrieved 2026-09-27
The Board of Registered Nursing states that med spa patients must be examined by a physician or an advanced practitioner before treatments are administered. — California Board of Registered Nursing, retrieved 2026-09-27
Registered nurses inject under standardized procedures, not alone
A registered nurse may inject and operate lasers in a California med spa only under written standardized procedures, with a supervising physician who is immediately reachable.
Business and Professions Code 2725 describes standardized procedures as protocols developed through collaboration among administrators and health professionals, including physicians and nurses. The Medical Board's guidance adds two conditions that matter in a spa setting. The physician must document each nurse's training and competence and evaluate it on an ongoing basis. And the location must be an organized health care system under the physician's control, which the guidance says is not a salon or other facility outside the physician's control.
That second condition is why the practice, and not a salon landlord, has to control the treatment rooms.
B&P 2725B&P 2725 describes standardized procedures as policies and protocols developed collaboratively by administrators and health professionals including physicians and nurses. — California Legislative Information, retrieved 2026-09-27
The Medical Board's guidance states that standardized procedures require an organized health care system, which is not a salon, spa or facility outside the physician's control. — Medical Board of California, retrieved 2026-09-27
Nurse practitioners and physician assistants have wider but defined roles
Nurse practitioners may examine and order treatment under standardized procedures, and physician assistants work under a supervising physician who may oversee no more than eight of them.
A nurse practitioner who meets the requirements of Business and Professions Code 2837.103 may practise without standardized procedures, but only in listed settings such as a medical group practice or professional medical corporation, and only after three full-time-equivalent years or 4,600 hours of transition to practice. That route does not permit an NP-owned spa outside those settings, as who can own a med spa explains.
For physician assistants, Business and Professions Code 3516 caps supervision at eight PAs per physician at any one time. The medical director page covers the rest of what supervision requires.
4,600 hoursB&P 2837.103 requires a nurse practitioner practising without standardized procedures to complete three full-time-equivalent years or 4,600 hours of transition to practice. — California Legislative Information, retrieved 2026-09-27
8Under B&P 3516(b), a physician may not supervise more than eight physician assistants at any one time. — California Legislative Information, retrieved 2026-09-27
Estheticians may not inject, use lasers or destroy live tissue
A California esthetician may give facials, exfoliate and remove hair by waxing or tweezing, but may not inject, use lasers, or perform any service that ablates or destroys live tissue.
Business and Professions Code 7316 defines the practice of skin care and excludes services that result in the ablation or destruction of live tissue. It also excludes hair removal by lasers or light waves. The Medical Board's med spa page is blunter: cosmetologists may never inject the skin, use lasers, or perform medical-level dermabrasion or skin peels.
Estheticians remain valuable in a med spa for services inside their scope. What the practice cannot do is have one operate a laser or deliver a deep peel because a physician signed a protocol; the Board's guidance calls delegation to improperly licensed personnel prohibited.
B&P 7316B&P 7316 excludes from the practice of skin care any service resulting in the ablation or destruction of live tissue, and hair removal by lasers or light waves. — California Legislative Information, retrieved 2026-09-27
The Medical Board states that cosmetologists may never inject the skin, use lasers, or perform medical-level dermabrasion or skin peels. — Medical Board of California, retrieved 2026-09-27
Medical assistants need a physician physically present
Medical assistants are unlicensed, and the Medical Board's guidance says they may not use lasers or prescriptive drugs in cosmetic treatments regardless of training or supervision.
Business and Professions Code 2069 allows medical assistants to give certain injections in general medical settings, but only when the supervising practitioner is physically present in the treatment facility. The Board's med spa guidance goes further for cosmetic work: no unlicensed staff, including medical assistants, may use prescriptive lasers or drugs, whatever their training.
Staff medical assistants in a med spa for check-in, room preparation and chart support. Before assigning a treatment to anyone, check it against the table at the top of this page, then confirm the insurance and workplace safety steps are in place for every staff member with exposure to blood.
B&P 2069B&P 2069 requires the supervising physician or other authorised practitioner to be physically present in the treatment facility when a medical assistant performs permitted procedures. — California Legislative Information, retrieved 2026-09-27
The Medical Board's guidance states that no unlicensed staff, including medical assistants, may use lasers or prescriptive drugs, regardless of training or supervision. — Medical Board of California, retrieved 2026-09-27
Questions
Can a registered nurse perform the good-faith exam before Botox?
No. The Medical Board's guidance states the appropriate prior examination may not be delegated to a registered nurse. A physician, a nurse practitioner under standardized procedures, or a delegated physician assistant performs it, and the nurse may then treat.
Can an esthetician do laser hair removal in California?
No. B&P 7316 excludes hair removal by lasers or light waves from the practice of skin care, and the Medical Board states that cosmetologists may never use lasers.
Does the supervising physician have to be in the building?
For nurses under standardized procedures, the Medical Board says the physician need not be on site but must be immediately reachable. For medical assistants performing permitted procedures, B&P 2069 requires physical presence in the facility.