Can a nurse practitioner own a med spa in California? Yes. Most of what you’ll read online says otherwise because it’s describing medical corporations. NPs can use a nursing corporation and own the practice outright. The harder questions are which services you’ll offer and whether you need a physician collaborator to inject Botox or use a laser. Here’s how ownership works in 2026, what each NP tier can do, and where physician oversight still applies.
Can a nurse practitioner own a med spa in California?
Yes. California lets registered nurses, which includes every nurse practitioner, own a professional nursing corporation, and a nursing corporation can provide aesthetic services. The Business and Professions Code defines a nursing corporation as a corporation authorized to render professional services under the Moscone-Knox Professional Corporation Act, and it names the Board of Registered Nursing (BRN) as the agency that oversees it (§ 2775).
Only licensed professionals can own a nursing corporation. Nurse practitioners and registered nurses are both licensed by the Board of Registered Nursing (BRN), so either can own all of the shares. Physicians, physician assistants, licensed midwives, and certain other licensees can hold minority stakes, as long as their combined ownership stays at or below 49% (Cal. Corp. Code § 13401.5(f)). The corporation’s name must include “nursing” or “registered nursing” (§ 2778), and the corporation is held to the same professional conduct standards as an individual nurse (§ 2777).
A medical corporation is the reverse. Physicians must hold the majority and can own all of it. An NP can own a minority stake of up to 49%, shared with any other licensed non-physician owners. Our guide to NP ownership through California nursing corporations compares the two, and Do Nurse Practitioners Need a Physician Owner? explains why the 51% rule people frequently quote applies to medical PCs, not nursing PCs.
Do you need a physician to open a med spa as an NP?
No, you don’t need a physician owner to open a med spa in California. Most NPs still need a physician collaborator, though, because owning the business and treating patients fall under different rules. A nursing corporation lets you own the med spa. Your NP “tier” (standard, 103, 104) determines whether you need a physician to treat patients.
California has three NP tiers. A standard NP practices under standardized procedures developed with a physician. A 103 NP can practice without standardized procedures, but only in specific settings with physician supervision (§ 2837.103). A 104 NP, after three years as a 103 NP in good standing, can practice with full autonomy (§ 2837.104). Please refer to California NP Practice Ownership for 103, 104 and Standard NPs for more specifics.
The detail that matters most for med spa owners comes from the BRN. In its AB 890 guidance, the Board states that an NP who works in a nursing corporation cannot practice as a 103 NP without standardized procedures or physician oversight, because a nursing corporation isn’t one of the qualifying group settings (BRN, AB 890 FAQ). A 103 NP who opens a med spa as their own nursing corporation must work under standardized procedures, just like a standard NP. Only a 104 NP is able to work without them.
| Who | Botox, fillers, laser, and IPL in a California med spa |
|---|---|
| Standard NP | Under standardized procedures developed with a supervising physician |
| 103 NP in a nursing corporation | Under standardized procedures developed with a supervising physician |
| 104 NP | Without standardized procedures under the statute, within national certification and training. |
| Registered nurse | Only under physician supervision |
| Medical assistants and other unlicensed staff | Not allowed under any circumstances |
What are standardized procedures, and how do they apply to aesthetics?
Standardized procedures are written policies and protocols that let a nurse practitioner perform functions that overlap with medicine. Administrators and health professionals, including physicians and nurses, develop them together (§ 2725(c)). The Legislature built them into the Nursing Practice Act because it recognized that nursing is dynamic, that nursing and medicine overlap, and that the overlap can be shared inside organized health care systems where physicians and nurses collaborate (§ 2725(a) to (c)).
For an NP, standardized procedures also govern furnishing. California law allows NPs to furnish or order drugs and devices when three conditions are met: the furnishing follows standardized procedures or protocols developed with a supervising physician, it fits the NP’s education and clinical competency, and the physician supervision requirements are satisfied (§ 2836.1). Botox is an FDA approved drug, and the FDA regulates dermal fillers as medical device implants (FDA), so both fall under these rules.
What services can an NP-owned med spa offer in California?
An NP-owned med spa can offer most aesthetic services. The rule of thumb is that every treatment has to be done by someone licensed to do it (Cal. Corp. Code § 13405), and a nursing corporation provides nursing services (§ 13401(b)). That covers patient care, assessments, injections, and giving medications (B&P § 2725(b)). NPs can also prescribe drugs and order devices. For each service, the questions are whether physician supervision is required, or whether a service is out of scope for an NP’s license.
| Service | Can an NP-owned nursing corporation offer it? | What it requires |
|---|---|---|
| Botox and other neurotoxins | Yes | Standardized procedures with a supervising physician, unless the NP holds 104 certification |
| Dermal fillers | Yes | Same as Botox. The FDA regulates fillers as medical device implants |
| Laser and IPL treatments, including laser hair removal | Yes | Same as Botox. Please note that aestheticians can’t use lasers or light-based devices |
| Deeper chemical peels and medical-level dermabrasion | Yes | A licensed clinician. The Medical Board says cosmetologists can’t perform them |
| IV hydration | Yes | An exam and order from a prescriber, such as a physician or NP, before treatment. No compounding |
| GLP-1 weight loss programs | Yes | NP furnishing rules. Neither board has issued med spa specific guidance |
| Facials, superficial microdermabrasion, and other esthetician services | Yes if a nurse performs them. Unclear if you hire estheticians | Estheticians need a Board of Barbering and Cosmetology establishment license for the location. |
Laser and light-based hair removal is carved out of the aesthetician scope by statute (§ 7316(c)(3)), and the Medical Board says cosmetologists may never inject the skin, use lasers, or perform medical-level dermabrasion or peels (Medical Board of California, Medical Spas). Those services stay with licensed clinicians.
IV hydration is getting extra attention from regulators. Before a patient gets an IV, a prescriber such as a physician or NP has to examine them (Board of Pharmacy, IV hydration policy). In addition, nurses can’t compound, or custom-mix, medications (§ 2725.1). In March 2026, the BRN reported a rise in complaints about med spas and IV clinics and confirmed that RNs and NPs can’t compound even if a prescriber tells them to (BRN, March 2026 Board materials). An RN can prepare an IV by following the label or package insert.
Why does the Medical Board say a med spa must be physician-owned?
The Medical Board of California treats cosmetic procedures that use prescription drugs or devices as the practice of medicine. Its FAQ says registered nurses and physician assistants may inject Botox or use lasers only under a physician’s supervision, and that unlicensed staff may not perform these treatments (Medical Board of California, Cosmetic Treatments FAQ). It describes a med spa as a physician-owned practice (Medical Board of California, Medical Spas).
That said, this FAQ does not address nurse practitioners, Standard or 103 NP certification under physician supervision, 104 NP certification under AB 890 (§ 2837.104), or nursing corporations, which are authorized separately under the Business and Professions Code (§ 2775).
Should an NP med spa use a nursing corporation or an MSO-PC?
For an NP who wants to own the practice, a nursing corporation is the most direct route. Many California med spa guides describe a management services organization paired with a physician-owned professional corporation, usually called an MSO-PC. That structure exists because a medical corporation requires a physician majority owner. A nursing corporation requires a nurse practitioner or registered nurse majority owner, so an NP can own the clinical entity outright.
An MSO-PC adds a second entity, a physician owner, and a complex set of agreements that relate these two separate entities to each other. It is not trivial to set up or to manage. We would recommend scheduling a call with the Prax team to discuss in more detail.
Quick answers
Can an NP own 100% of a med spa in California? Yes, through a nursing professional corporation. Physicians and certain other licensees can hold up to 49% combined, but no physician is required to own any of a Nursing PC.
Can an NP inject Botox in California without a doctor? Yes, a standard NP or a 103 NP operating under their own nursing corporation needs standardized procedures developed with a supervising physician. A certified 104 NP can practice with full autonomy within their certification.
Can a 103 NP practice independently in their own med spa? Yes, but with standardized procedures and a collaborating physician. The BRN says a nursing corporation isn’t a qualifying 103 setting, so a 103 NP should work under standardized procedures with a collaborating physician in place.
Can an NP-owned med spa offer IV hydration? Yes. A prescriber has to examine the patient and order it first, and neither NPs nor RNs may compound the IV medications.
Does the supervising physician own part of the practice? No. The physician who develops standardized procedures with you is a clinical collaborator.
What’s the first step? A free call with the Prax team can sort out which structure and physician arrangement fit your NP tier and the services you plan to offer.
This guide is for general educational and informational purposes only and isn’t legal, tax, or medical advice. California requirements change. Talk with a qualified professional about your situation.
Disclaimer: The information and/or resources provided in this post and elsewhere on the Prax Health site is provided for general informational purposes only and to assist you as you evaluate engaging in Prax Health’s services. It is not intended as, and Prax Health, Inc. does not provide, medical advice, diagnosis or treatment nor is it intended to be legal or tax advice.
Sources
- Cal. Bus. & Prof. Code § 2775 — defines a nursing corporation and names the BRN as its oversight agency
- Cal. Bus. & Prof. Code § 2777 — nursing corporations are held to the same conduct standards as individual licensees
- Cal. Bus. & Prof. Code § 2778 — nursing corporation name requirement
- Cal. Bus. & Prof. Code § 2779 — shareholder, director, and officer licensure requirements
- Cal. Corp. Code § 13401.5(f) — other licensees who may hold minority shares in a nursing corporation, capped at 49 percent combined
- Cal. Corp. Code § 13401 — professional corporations practice a single profession
- Cal. Corp. Code § 13405 — professional services only through licensed employees
- Cal. Bus. & Prof. Code § 2725.1 — registered nurses may not compound drugs
- Cal. Bus. & Prof. Code §§ 7316, 7317, 7319, 7347 — esthetician scope, establishment licensing, and the nursing exemption
- Cal. Bus. & Prof. Code § 2725 — overlapping functions and standardized procedures
- Cal. Bus. & Prof. Code § 2836.1 — conditions for NP furnishing of drugs and devices
- Cal. Bus. & Prof. Code § 2837.103 — 103 NP practice in qualifying group settings
- Cal. Bus. & Prof. Code § 2837.104 — 104 NP practice outside group settings and its conditions
- SB 1451 (2024) — amended Article 8.5, including how transition-to-practice experience counts
- California Board of Registered Nursing, AB 890 FAQ — traditional NP role continues, nursing corporations are not a 103 setting, 104 population focus
- Medical Board of California, Cosmetic Treatments FAQ — supervision rules for Botox, lasers, and IPL, and the Board's view of med spa ownership
- California Board of Registered Nursing, AB 890 implementation guidance — includes the CANP overview on 104 NPs and nursing corporations
- California Board of Registered Nursing, March 2026 Board materials — med spa and IV therapy complaints, no compounding by RNs or APRNs
- Medical Board of California, Medical Spas — who may perform cosmetic medical procedures and what cosmetologists may not do
- California Board of Pharmacy, Intravenous Hydration Policy (2024) — exam by an authorized prescriber before IV hydration
- FDA, Dermal Fillers (Soft Tissue Fillers) — dermal fillers are FDA-approved medical device implants