What License Do You Need to Open a Medical Spa in Texas?

Opening a medical spa in Texas is an exciting opportunity—but before launching your med spa, it’s essential to understand the legal and licensing requirements involved. From medical director agreements to facility compliance, the licenses and regulations can be complex and vary based on ownership structure and offered treatments.
In this guide, we’ll walk you through what license do you need to open a medical spa in Texas, detailing the necessary licenses and compliance for operating a successful medical spa.
Who Can Legally Own a Medical Spa in Texas?
In Texas, non-physicians cannot directly own or operate a medical spa that provides medical treatments such as Botox, laser therapy, or microneedling. Instead, these services must be performed by—or delegated by—a licensed physician.
This means that:
- A physician must either own the medical spa or form a management services organization (MSO) that contracts with a licensed physician to provide medical services.
- Nurses, estheticians, or business investors may partner with a licensed physician under a compliant structure, but cannot independently provide or supervise medical treatments.
What Licenses Are Required to Open a Med Spa in Texas?
To legally open and operate a med spa in Texas, you typically need the following:
1. Medical License (for Supervising Physician)
A Texas-licensed physician must oversee all medical services. This physician may supervise nurse practitioners (NPs), physician assistants (PAs), or registered nurses (RNs) providing care under delegation.
2. Facility Licenses (if applicable)
While Texas does not require a specific “spa license” for medical spas, certain licenses may be required depending on the services you offer:
- Laser Hair Removal License: Required for facilities providing laser treatments.
- Radiation Device Registration: Needed for spas using devices like intense pulsed light (IPL) or certain cosmetic lasers.
- Texas Sales Tax Permit: For selling skincare products or cosmetic items.
- Occupational Licenses: For estheticians, cosmetologists, and massage therapists, if offering non-medical services.
3. Business Registration & Compliance
Your med spa must be properly registered with the:
- Texas Secretary of State
- Texas Medical Board
- Texas Department of Licensing and Regulation (TDLR) for non-medical services
You’ll also need business insurance and must comply with HIPAA, OSHA, and applicable employment laws.
How to Open a Med Spa in Texas: Legal Checklist
Starting your own med spa in Texas? Here’s a step-by-step legal checklist:
- Consult with a Healthcare Attorney
Engage an attorney experienced in medical spa licensing and healthcare law in Texas. - Establish Legal Entity
Form a PLLC or MSO depending on ownership structure. - Secure a Medical Director
Ensure a Texas-licensed physician oversees medical treatments. - Obtain Necessary Licenses and Registrations
Apply for tax permits, laser registrations, and business licenses. - Draft Compliance Documents
Set up medical protocols, consent forms, employee agreements, and HIPAA compliance. - Stay Updated
Keep up with Texas Medical Board rules and evolving laws affecting medical spas.
Avoid Common Legal Mistakes in Texas Med Spa Ownership
Many med spa owners get into legal trouble by:
- Offering medical treatments without proper physician oversight
- Paying commissions for patient referrals (this may violate anti-kickback laws)
- Misclassifying employees as independent contractors
- Advertising medical services improperly
By working with a knowledgeable healthcare law firm, you can ensure your medical spa stays compliant from day one.
Need Legal Help Opening Your Medical Spa?
At Dike Law Group, we specialize in helping healthcare professionals across Texas and the U.S. start, structure, and scale their medical businesses legally and confidently.
If you’re in need of help, guidance, or have questions concerning healthcare business legal matters or trademarks, we invite you to explore our website at Dike Law Group.
👉 To initiate a free intake discussion, please go to dorismeet.com, where you can schedule a meeting with attorney Doris Dike.
We look forward to supporting your journey toward a thriving, compliant, and successful med spa business.