What Are the Legal Requirements for Owning and Operating a Medspa?

 Posted on October 16, 2025 in Professional License Defense

Medical spas, or "medspas," are becoming more popular in Illinois. Many people like them because they offer simple cosmetic treatments in a calm, spa-like setting. But running a medspa is not the same as running a salon.

In Illinois, medspas that provide medical treatments are treated like medical offices under the law. This distinction brings with it a range of regulatory requirements and restrictions.

Whether you are a business owner, a doctor, or an esthetician, you need to know the laws that apply to medspas. An Illinois medspa license attorney can help you understand the rules for licensing, staffing, and safety so your business follows the law.

Who Can Own a Medspa in Illinois?

Illinois law says that any place offering medical treatments, even cosmetic ones, must be owned and run by a licensed doctor. The business must also follow a rule called the Corporate Practice of Medicine Doctrine. This doctrine prohibits non-physicians from owning or operating entities that provide medical services.

To comply with this rule, any medspa offering medical treatments must be owned by a licensed Illinois physician. All medical decisions must be made by a licensed doctor or another approved medical worker under the doctor’s supervision.

If a medspa does not follow these rules, the Illinois Department of Financial and Professional Regulation (IDFPR) can take action. The owners could face fines, license loss, or legal trouble.

Medical Services and Supervision Requirements

In Illinois, any treatment that changes the body, breaks the skin, or touches living tissue is usually considered medical care. This includes:

• Botox and dermal fillers

• Microneedling

• Medical-grade chemical peels

• Laser hair removal

• Platelet-rich plasma (PRP) injections

• Intravenous (IV) therapy

• Certain body contouring procedures

These treatments are considered medical procedures. Only a licensed doctor can do them or give permission to another trained medical worker. This can include a nurse, nurse practitioner, or physician assistant.

A doctor must supervise all treatments. The doctor and staff must follow Illinois laws, including the Medical Practice Act and rules for nurses and physician assistants. Medspa owners must make sure everyone is properly trained and only does work they are allowed to do.

What Estheticians and Cosmetologists Can (and Cannot) Do

In Illinois, licensed estheticians and cosmetologists can do many beauty and skincare treatments. They may give facials, apply makeup, do gentle exfoliation or microdermabrasion, and use light chemical peels that do not break the skin.

They cannot give Botox or filler injections, do microneedling that breaks the skin, perform deep peels, use lasers, or do PRP or other treatments that involve needles or blood.

If they break these rules, both the worker and the supervising doctor or owner can face penalties. Every staff member must only do the services allowed under their license.

Regulations for the Use of Lasers

In Illinois, laser treatments such as laser hair removal and skin resurfacing are considered medical procedures. Only a doctor or a licensed medical worker supervised by a doctor can use or control medical lasers.

Other treatments that use red light, low-level lasers, LED light, or radio waves to treat the skin are also medical procedures. These must be done by a licensed doctor.

Anyone operating a laser must maintain adequate documentation of training and certification. They also must obtain informed consent from clients before performing any laser procedure. Additionally, safety protocols, including protective eyewear and room signage, must be followed to prevent injury.

Infection Control and Safety Standards

All medspas in Illinois must comply with strict infection prevention and control standards. These are not only ethical obligations but also legal requirements under IDFPR and applicable health codes.

That means medspas are legally obligated to sterilize or properly dispose of all equipment that comes into contact with bodily fluids or skin. Medspas must use disposable needles, gloves, and other single-use items. Regular handwashing and use of alcohol-based sanitizers by staff is a requirement.

All sharp objects that have come into contact with any clients must be properly disposed of in designated containers. Medical-grade disinfectants must be used on all surfaces and treatment areas. Medspas are also required to document and be in complete compliance with OSHA regulations concerning bloodborne pathogens.

Failure to maintain a clean and safe environment can lead to penalties, suspension of licenses, or even closure of the facility.

Contact Our Peoria Medspa License Defense Attorney

Running a medspa in Illinois means knowing the rules for health care and licensing. At The Law Offices of Joseph J. Bogdan, Inc., our Rockford, IL medspa licensing lawyer can explain these laws and help fix any issues that could affect your business. Contact us today at 630-310-1267 to schedule a free consultation and learn how we can help protect your business.