Texas Med Spa Laws: What Actually Applies to Your Practice
Ownership, delegation, licensing and oversight, in the order they affect you. Updated for the 2025 rule changes.
Start with your treatment menu
Every other question follows from what you offer. Texas does not regulate med spas as a category. It regulates procedures, and it sorts them by what they do to tissue rather than how they are marketed. A facial and a fractional laser resurfacing sit under different agencies with different rules, even in the same room on the same afternoon.
So the useful starting point is a list of every service you offer or plan to offer, with the license of whoever performs it. From there the ownership, licensing and delegation requirements resolve themselves.
Three agencies, depending on your menu
Texas Medical Board
Medical procedures and physician delegation. Injectables, medical-grade lasers, prescription therapies, and the delegation that authorizes non-physicians to perform them.
TDLR
Esthetic services, cosmetology establishment licensing, and the separate certification pathway for laser hair removal covering both individuals and facilities.
DSHS
Device and facility areas including permanent makeup and tanning. This is the one operators discover last, usually after the first two are handled.
The ownership rule most people miss
Texas prohibits non-physicians from owning or controlling an entity that provides medical services. There is no exception for nurses, nurse practitioners, physician assistants, or estheticians. The workable structure is a management services organization you own handling business operations, paired with a physician-owned professional entity holding all clinical authority, joined by a management services agreement. That agreement is legal work. The fee structure and the control boundaries are where these arrangements fail, and a template will not survive scrutiny.
What every compliant Texas med spa has
- A physician-owned entity providing the medical services
- Written delegation covering every procedure and device
- A good faith examination before treatment
- Facility licensing matched to the services offered
Texas requirement
In Texas, only a physician licensed by the Texas Medical Board, an MD or DO, may serve as a medical director. A nurse practitioner or physician assistant cannot hold the role, though either may perform delegated services under physician supervision.
The medical director’s name and Texas Medical Board license number must be posted in all treatment areas.
Frequently asked
Does every med spa need a medical director?
What changed in 2025?
What are the penalties?
Rather than a single schedule, exposure is spread across the agencies whose rules you touched. TDLR publishes current penalty amounts for the cosmetology and laser programs on its enforcement pages. The Medical Board acts on the physician side. Neither figure is fixed in advance, and both change, so the reliable move is to check the current schedule on the relevant agency site rather than budget from a number you read once.
Do these rules apply to a mobile or telehealth practice?
Find out where your practice stands
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More from Texas Med Spa Directors
Who can own a med spa in Texas · What a medical director costs · Talk to us about your practice · Does a med spa need a medical director?
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