Nationwide: 36 states have no med spa-specific rules, per the AMA

Key facts:

• In April 2026, the AMA reported that 36 states have no med spa-specific laws or regulations, citing a 2025 Dermatologic Surgery study.
• 44 states lacked patient-protection requirements specific to med spas.
• Only 12 states had any med spa-specific provisions.
• Roughly 70% of med spas operate without affiliation to a physician practice.

What did the AMA report?

On April 6, 2026, the American Medical Association highlighted a 2025 study in Dermatologic Surgery finding that 36 states have no identified laws or regulations specific to med spas, and 44 states lacked med spa-specific patient-protection requirements. Only 12 states had any med spa-specific provisions: Connecticut, Iowa, Illinois, Indiana, Massachusetts, New Mexico, Oklahoma, Rhode Island, Tennessee, Texas, Utah, and Wisconsin. See the AMA article.

If my state has no med spa rules, am I unregulated?

No, and this is the trap. In states without med spa-specific rules, oversight still comes through the general laws governing the practice of medicine, nursing, and facility operations. Regulators apply those. The AMA brief notes roughly 70% of med spas operate without affiliation to a physician practice, which is exactly the gap regulators are watching.

What it means for your med spa

Don't mistake no med spa statute for no rules. Check your supervision and delegation structure against your state's medical and nursing laws, confirm every clinical staff member is properly licensed for what they do, and keep documentation for patient evaluation, treatment planning, and consent. Enforcement sweeps are already happening, including a New York inspection of 223 med spas that cited 87 for violations.

FAQs

Which states have med spa-specific rules?

Per the study, twelve: Connecticut, Iowa, Illinois, Indiana, Massachusetts, New Mexico, Oklahoma, Rhode Island, Tennessee, Texas, Utah, and Wisconsin.

What governs med spas in the other states?

General laws on the practice of medicine, nursing, and facility operations.

Fresh Clinics helps med spa owners build a supervision structure that holds up under general medical and nursing law. Learn more about Fresh Clinics membership.