Licensing planning guide

Colorado med spa
licensing guide.

Required disclosures when aesthetic medicine is delegated.

Prepared by Prospyr · Sources checked September 15, 2026

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What to know in Colorado

Start with these state-specific findings, then use the checklist below to review the rest of your practice. The linked authorities explain the conditions and exceptions behind each point.

01

Delegation carries patient-facing disclosure duties

HB25-1024 addresses physicians and APRNs delegating medical-aesthetic services to unlicensed people. It requires disclosures identifying the delegating clinician at the service location and in specified website or advertising materials.

Source: Colorado HB25-1024: signed medical-aesthetic delegation law
02

Consent and recordkeeping are part of the workflow

The law requires informed consent before covered delegated services and retention of that consent for seven years. The act contains exceptions, including certain Title 25-regulated facilities; assess applicability to the actual practice.

Source: Colorado HB25-1024: signed medical-aesthetic delegation law

Your next steps

  1. Audit the website, advertising and physical signage against the enacted disclosure requirements.
  2. Add a clinician-specific delegation consent and retention step before a covered appointment.

Questions to resolve before opening

  • Is this facility or service covered by HB25-1024 or an express exception?
  • Who maintains the required consent records when the practice or delegating clinician changes?

Bring your actual ownership chart, service menu, devices and staff credentials to the relevant board or healthcare counsel. The same answer may not apply to a different procedure or business model.

A practical licensing checklist

These planning steps complement the Colorado highlights. They are a workflow for investigation, not a claim that every listed permit applies to every practice.

01

Ownership & clinical control

Identify the owners of the clinical entity, who employs clinicians, who controls medical decisions and how management fees are paid. Ask healthcare counsel to confirm the entity and any professional-ownership or fee-splitting limits before signing agreements.

02

People & procedures

List the person who evaluates, prescribes, performs and supervises each treatment. Verify the actual professional license, restrictions, procedure training and required agreements. A course certificate alone does not establish a legal scope of practice.

03

Premises, devices & products

Check clinic or establishment licensing, local zoning and occupancy, device registration, drug purchasing and storage, and any laboratory or body-art services. Adding a procedure or location can change the applicable requirements.

04

Patient care & opening file

Document consent, assessment, treatment orders, emergency escalation, infection prevention and record access. Assign an owner to every unresolved question and keep the authority supporting the final decision.

Official sources & scope

A source-based planning guide for practice owners, not legal advice or a license approval. The state highlights cover the issues identified below; the workbook helps you resolve additional ownership, scope and facility questions with the relevant boards and qualified counsel. Requirements depend on your services, staff and business structure.

No attorney review is claimed. Report an update.