Colorado did something in 2025 that no other state in our coverage has done: it made your medical director’s name a public-facing disclosure.
HB25-1024, signed on April 7, 2025, requires a med spa using unlicensed personnel for delegated medical-aesthetic services to say so — on a prominently displayed sign, on its website and in its advertising, and in a written informed consent retained for seven years. The sign and the online disclosure must carry the delegating practitioner’s name and licence number, plus the web address of the board where a complaint can be lodged.
What Colorado actually requires
- A Colorado-licensed physician as medical director, actively involved rather than nominal.
- On-site signage stating that certain services are performed by unlicensed individuals under delegation, naming the delegating practitioner, their licence number and contact details, and the relevant board’s complaint address.
- Website and advertising disclosures to the same effect, naming the practitioner and licence number.
- Written informed consent acknowledging that unlicensed individuals will perform certain services, retained for seven years.
- A professional entity consistent with Colorado’s corporate-practice restrictions, with an MSO for the business side.
- Written delegation protocols covering patient selection, dosing, product documentation, adverse-event response and escalation.
Who may do what in Colorado
| Licence | What they may do |
|---|---|
| MD or DO | Independent; the medical director role |
| Advanced practice registered nurse | Within scope; HB25-1024 reaches APRN delegators too |
| Physician assistant | Within scope, under the applicable supervision |
| Registered nurse | Delegation to an RN runs through the Nurse Practice Act rather than the medical board’s delegation rule |
| Unlicensed personnel | Permitted for delegated services only with the HB25-1024 disclosures in place |
| Esthetician | Within the cosmetology scope; injections are not in it |
Read the disclosure requirement as a business decision, not a paperwork one. If your model depends on clients not knowing who is treating them, Colorado has removed that option. If it does not, the disclosure is free credibility.
What MDside provides in Colorado
- A Colorado-licensed MD or DO as medical director, doing the work rather than lending a name.
- The professional entity and management agreement built to Colorado rather than to a national template.
- Licensed physicians for the good faith exams behind prescriptions and injectables.
- Protocols and delegation written against your live service list, and revised when it changes.
- 503A and 503B pharmacy relationships and lab draws.
See what is included, or book a call and tell us which states you operate in.
Read the detail on Colorado
Frequently asked questions
What does Colorado HB25-1024 require?
On-site signage, website and advertising disclosures, and a written informed consent — all stating that certain medical-aesthetic services are performed by unlicensed individuals under delegation, and naming the delegating practitioner and licence number. Consents are retained seven years.
When did it take effect?
It was signed on April 7, 2025. It applies to physicians licensed under Article 240 and APRNs licensed under Article 255 of the Colorado Revised Statutes.
Does Colorado allow non-physician ownership of a med spa?
Colorado applies the corporate practice of medicine doctrine, so the clinical entity is physician-owned with a management company alongside it for the business side.
General information about Colorado practice structure and med spa regulation, not legal advice. Statutes, board rules and scope-of-practice requirements change. Confirm your obligations with healthcare counsel licensed in Colorado.