California · Strict

Do You Need a Medical Director for a Med Spa in California?

Whether California requires a medical director — and what that director is actually on the hook for — shapes your staffing, your liability, and your startup budget. Here's the California picture.

By Evan at Inside MedSpa

Medical director requirement

Required; physician must be on-site or immediately available for injectable procedures

Corporate Practice of Medicine

Strict; Corporate Practice of Medicine doctrine enforced—non-physicians cannot own/control medical decisions; MSO structure required This is the doctrine that decides whether a non-physician can own or control the practice, and it usually travels hand-in-hand with the medical-director question.

Who can supervise or delegate

NP/PA may inject under physician supervision; independent practice not permitted for injectables

How the exam ties in

Required; in-person exam mandatory before treatment

What to verify in California

Verify physician ownership or establish compliant MSO with physician control; confirm on-site supervising physician availability for all injection days.

Primary source: California Medical Board; California Board of Registered Nursing

General business information for California medical-spa owners, current as of 2026 — not legal advice. State boards update rules often; confirm specifics with the California board (and your own counsel) before you act.

See the full California regulation profile →

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