NP legislation (AB 890), signed into law in 2020 with expanded provisions beginning Jan 2026, created new pathways for California Nurse Practitioners to practice with greater autonomy. In doing so, it established two new NP certification tiers alongside the existing NP framework, giving California NPs three distinct categories under which they can practice.

The rollout has been complex. CA BRN is still finalizing formal written guidance, and some NPs have received conflicting information from different sources.

This guide outlines what each tier means, what CA BRN has confirmed about ownership and practice structure, and what 103 NPs in particular need to understand before deciding how to set up their practice.

California's Three NP Certification Tiers: Standard, 103, and 104

AB 890 (Cal. Stats. 2020, Ch. 265) created Article 8.5 of the Business and Professions Code, establishing two new certification pathways. Combined with the existing standard NP framework, there are now three tiers:

Standard NP

Practices under standardized procedures with a collaborating or supervising physician. This is the baseline framework that preceded AB 890 and remains the path for NPs who have not obtained 103 or 104 NP certification.

103 NP (Cal. Bus. & Prof. Code § 2837.103)

A transitional certification for NPs who have completed the required experience in California. Under this pathway, a qualifying NP may perform clinical functions without standardized procedures, within specific settings. Importantly, a 103 NP still requires a collaborating physician.

The statute requires completion of:

Cal. Bus. & Prof. Code § 2837.103(a)(1)(D)

"a minimum of three full-time equivalent years of practice or 4,600 hours" of transition to practice in California.

104 NP (Cal. Bus. & Prof. Code § 2837.104)

Full practice authority. A 104 NP meets all 103 NP requirements plus an additional three years of practice experience as a 103 NP. Once recognized as a 104 NP, no collaborating physician is required and no standardized procedures are required.

Can a Standard, 103, and 104 NP Own a Practice in California? Yes. Here's the Structure.

Standard NP

May fully own a Nursing Professional Corporation (PC) in California under Cal. Bus. & Prof. Code § 2775. Practices within the entity under standardized procedures with a collaborating or supervising physician in place.

104 NP

May fully own and practice within a Nursing PC. No collaborating physician is required and no standardized procedures are required. This is the most autonomous structure available to California NPs.

103 NP

A 103 NP may fully own a Nursing PC. However, per guidance from Marissa Clark, Chief of Legislation, California Board of Registered Nursing (April 2026), a 103 NP must practice as a "Standard NP" within their own Nursing PC entity.

That means that a 103 NP who owns a Nursing PC must practice within that entity as a standard NP, with standardized procedures and a collaborating physician in place. This is the current confirmed position from the CA BRN.

Bottom line: A 103 NP can own a Nursing PC. They just cannot use their 103 NP certification status within it. They practice as a standard NP with standardized procedures and a collaborating physician.

If You Want to Reach 104 NP Status Faster, Read This First

This is an important planning consideration for any 103 NP whose goal is to reach 104 status.

If a 103 NP owns a Nursing PC and practices within it as a standard NP under standardized procedures, those hours do not count towards 104 NP certification requirements. The CA BRN has confirmed this: only hours practiced under the 103 NP framework, in qualifying settings, count towards the path to 104.

For 103 NPs who want to own their practice and accrue hours toward 104 NP in that setting, a Management Services Organization-Professional Corporation (MSO-PC) structure offers a path to do both. In an MSO-PC arrangement, the 103 NP can practice under the 103 framework in a qualifying setting, with the MSO layer providing business infrastructure.

That said, an MSO-PC is significantly more complex and expensive to set up and to maintain than a standard Nursing PC. NPs should weigh the cost and complexity against the timeline benefit of reaching 104 sooner.

Bottom line: A Nursing PC is much simpler and less expensive to set up and run. An MSO-PC allows 103 NPs to accrue hours toward 104 while owning their practice. The right choice depends on your goals and timeline.

For more on how nursing corporations fit alongside MSO structures in California, see our guide California NP nursing corporation ownership.

Why NPs Are Getting Conflicting Information from the CA BRN

AB 890's implementation is ongoing, and guidance has not been consistent across all CA BRN staff.

For example, some NPs have received written guidance indicating that a physician must own at least 51% of any practice entity in California. That expectation applies specifically to medical professional corporations, not to Nursing PCs under the rules described in this guide. For a broader discussion of the physician-ownership myth and CPOM states, see Do nurse practitioners need a physician owner?.

The CA BRN is aware that inconsistent guidance has circulated. The Chief of Legislation is the appropriate source of the Board's formal positions on these matters. The Board plans to publish additional written guidance once pending legislation from the current session is resolved.

Prax Health will update our guidance as formal materials from the CA BRN are published.

Conclusion: Know Your Tier. Structure Your Practice Accordingly.

California NPs have real options for practice ownership at every certification level. The right structure depends on your current certification and your goals.

Prax Health helps NPs set up both Nursing PCs and MSO-PCs, and works with external healthcare legal counsel to provide clear, accurate, and objective guidance.