Most states keep the identity of your medical director between you, them and the regulator. Colorado has decided your clients should know too.
HB25-1024, signed into law on April 7, 2025, requires a med spa that uses unlicensed individuals to perform delegated medical-aesthetic services to disclose that fact in three places. It applies to physicians licensed under Article 240 of the Colorado Revised Statutes and to APRNs licensed under Article 255.
The three disclosures
| Where | What it must say |
|---|---|
| On site | A prominently displayed sign stating that certain medical-aesthetic services are performed by unlicensed individuals under delegation, with the delegating practitioner’s name, licence number and contact information, and the web address of the relevant board for lodging complaints |
| Online and in advertising | A clear statement on the website and in advertising materials that some services are performed by unlicensed personnel under delegation, naming the practitioner and licence number |
| In the chart | Written informed consent acknowledging that certain services will be performed by unlicensed individuals under supervision, retained for seven years |
Read this as a business rule, not a compliance chore
Three consequences follow, and only one of them is administrative.
Your marketing has to be true. A great deal of aesthetic advertising implies, without stating, that a physician or nurse is performing the treatment. If unlicensed staff are delegated the work, Colorado now requires you to say so in the same materials. The gap between the implication and the disclosure is a problem you have to fix in the copy, not in the footnote.
Your medical director becomes searchable. Their name and licence number sit on your website alongside a link telling clients where to complain. That is a materially different proposition from a private directorship agreement, and any physician taking the role should know it before signing.
The consent is a seven-year record. Retention that long means the consent form has to be right now, not retrofitted later, and it has to be findable.
The uncomfortable question it forces
If disclosing who performs your treatments would damage your business, the disclosure is not the problem. The staffing model is. Colorado has simply removed the ambiguity that was holding it up.
Conversely, if your treatments are performed by appropriately licensed clinicians under a genuinely engaged medical director, the disclosure costs you nothing and quietly differentiates you from the clinic down the road that is scrambling to reword its homepage.
What to do
- Establish, honestly, which services are performed by unlicensed individuals under delegation.
- Produce the sign, with the practitioner’s name, licence number, contact details and the board’s complaint address.
- Add the disclosure to the website and to advertising templates — including paid social, which is where it is most often missed.
- Update the consent form and set retention to seven years.
- Re-read your marketing for claims the disclosure now contradicts.
- Tell your medical director their name is going public. They may have a view.
Related reading
Frequently asked questions
When did Colorado HB25-1024 take effect?
It was signed on April 7, 2025, and applies to physicians licensed under Article 240 and APRNs licensed under Article 255 of the Colorado Revised Statutes.
Does it apply if all our treatments are performed by licensed staff?
The disclosures address services performed by unlicensed individuals under delegation. Establish accurately which category each service on your menu falls into rather than assuming.
How long must the consent be kept?
Seven years.
Does the sign really need our medical director’s licence number?
The on-site disclosure includes the delegating practitioner’s name, licence number and contact information, together with the board’s web address for complaints.
General information about Colorado med spa disclosure requirements, not legal advice. Confirm your obligations with healthcare counsel licensed in Colorado.