Colorado med spa ownership rules: who can own a med spa in Colorado
In Colorado, a professional service corporation that practices medicine must be owned by physicians licensed by the Colorado Medical Board, and physician assistants may hold shares but not a majority (C.R.S. 12-240-138). Colorado also prohibits general business entities from employing physicians. A 2026 bill that would have let estheticians, nurses and others own medical-aesthetic corporations was postponed indefinitely, so the rules stand. Since 2025, med spas that delegate aesthetic services to unlicensed staff must also make specific disclosures on signs, in ads and in consent forms.
- C.R.S. 12-240-138: all shareholders of a medical professional service corporation must be Colorado-licensed physicians owning shares in their own right; PAs may own a minority.
- Colorado has a statutory prohibition on general business entities employing physicians.
- HB26-1249, which would have opened medical-aesthetic corporations to estheticians, cosmetologists, nurses, APRNs and PAs, was postponed indefinitely on March 25, 2026.
- HB25-1024 (signed April 7, 2025): when physicians or APRNs delegate medical-aesthetic services to unlicensed people, you need a sign, ad and website statements, and a signed consent.
- Lay founders usually own a management services organization (MSO) that supports a physician-owned practice.
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Who can own a med spa in Colorado
Short answer: Colorado-licensed physicians, with physician assistants allowed a minority share. Investors and other professionals take part through a management company.
Colorado's Medical Practice Act lets physicians form professional service corporations for the practice of medicine (C.R.S. 12-240-138). The articles of incorporation must reflect an ownership requirement: every shareholder must be an individual licensed by the Colorado Medical Board to practice medicine who owns their shares in their own right. A licensed physician assistant may be a shareholder, but PAs, alone or together, may not own a majority. The American Med Spa Association also notes that Colorado has a statutory prohibition on general business entities employing physicians.
That leaves three practical structures:
- Physician-owned professional service corporation or similar entity.
- Physician-majority entity with PA shareholders.
- Physician-owned practice plus MSO. A lay founder or investor owns the MSO, which provides space, equipment, staff administration and marketing; the physician practice controls medical decisions.
The 2026 bill that did not pass
HB26-1249, Medical-Aesthetics Corporation Ownership, would have created an exception for corporations organized solely to provide medical-aesthetic services. It would have let estheticians, cosmetologists, practical nurses, registered nurses, APRNs and PAs with active Colorado licenses be shareholders, and let PAs own a majority. On March 25, 2026, the House Health and Human Services Committee voted 13-0 to postpone it indefinitely. If you read about "new Colorado ownership options" online, check the date: as of October 2026, current law has not changed.
HB25-1024: Colorado's delegation disclosure law
Short answer: if unlicensed staff perform delegated medical-aesthetic services, patients and the public must be told who the delegating practitioner is.
HB25-1024, Medical-Aesthetic Services Delegation Disclosures, was signed on April 7, 2025 and took effect in August 2025. It applies when a physician or APRN delegates medical-aesthetic services to an individual who is not a licensed health care provider. The American Med Spa Association summarizes three disclosures:
- A sign posted visibly in the area where delegated services are performed, showing the delegating practitioner's name, license number and contact information, and the board's complaint web address.
- Website and advertising statements that services are delegated, with the delegating practitioner's name and license number.
- Informed consent explaining the delegation, including the sign information, signed by the patient and kept by the practice for seven years.
This is the most direct link between ownership, supervision and marketing in any state in this series. Delegation and supervision rules themselves are covered in our med spa medical director requirements guide.
Colorado med spa registration checklist
- Confirm the structure with a Colorado healthcare lawyer: physician-owned entity (PA minority allowed) and, if needed, an MSO.
- Form the entities with the Colorado Secretary of State, with articles that include the ownership requirement for the medical corporation. Get EINs, sales tax licenses for retail and local business licenses.
- Sign the management services agreement so the MSO handles non-clinical services only.
- Verify licenses: Colorado Medical Board (physicians, PAs), Board of Nursing (RNs, APRNs) and the Office of Barber and Cosmetology Licensure for estheticians.
- Document delegation under Colorado Medical Board rules, and identify which services, if any, are delegated to unlicensed staff.
- Put HB25-1024 in place: the treatment-area sign, the website and ad statements, and the consent form with seven-year retention.
- Drug sourcing: authorized distributors only, lot tracking, DEA registration for controlled substances.
- Privacy: HIPAA policies and Business Associate Agreements with vendors that handle patient data.
What ownership means for Colorado med spa marketing
Short answer: in Colorado, your ads may legally need to name the delegating practitioner and license number. Build that into every template.
- Ad templates. Add the HB25-1024 statement and practitioner details to website service pages, Google and Meta ad landing pages, and printed promotions for delegated services.
- Provider identity. Name the physician practice and describe each provider's role accurately.
- Board rules. See our Colorado medical board advertising rules guide and the before-and-after photo guide.
- Data. Booking-page tracking is a HIPAA question; see our guide to HIPAA-safe Meta ads for aesthetic practices.
Market context: our Southwest med spa market report, the Med Spa Google Presence Report 2026 and med spa marketing statistics. For hands-on help, see med spa marketing with Ichelon Consulting US.
What we found when we studied 555 US med spas on Google
Patients praise the care almost without exception. The one area where complaints outnumber praise is booking and communication, and that is where most med spas can win.
Full study · 555 US med spas across 20 metros · roughly ±4% nationally · review velocity and themes from a 115-spa subsample · verified against raw data.
Common Colorado med spa mistakes
- Acting as if HB26-1249 passed. It did not.
- Giving PAs majority ownership of a medical corporation.
- A general business entity employing physicians.
- Missing HB25-1024 disclosures on signs, ads, websites or consent forms.
- Discarding consent forms before the seven-year retention period ends.
- Copying an Arizona structure into a Colorado location.
Not legal advice: this page summarizes Colorado rules as we found them in October 2026. It is not legal advice. Confirm your structure with a Colorado healthcare attorney.
Sources
- Colorado General Assembly: HB26-1249, Medical-Aesthetics Corporation Ownership (bill summary describes current C.R.S. 12-240-138 ownership rules; postponed indefinitely March 25, 2026)
- Colorado General Assembly: HB25-1024, Medical-Aesthetic Services Delegation Disclosures
- American Med Spa Association: new Colorado law adds med spa disclosures
- American Med Spa Association: Colorado bill would expand medical-aesthetic ownership
- AANP: state practice environment
- FDA: counterfeit version of Botox found in multiple states
Related: ownership rules in all 50 states + DC · all US guides · book a call.
Related pages from the US team
Med spa ownership rules by state
The pillar guide with a 50-state + DC table.
Arizona med spa ownership rules
A neighbor where lay ownership is allowed.
Illinois med spa ownership rules
Another strict state with written regulator guidance.
Southwest med spa market 2026
Our research on Southwest and Mountain med spas.
Colorado medical board advertising rules
How Colorado regulates healthcare advertising.
Med spa marketing agency USA
How we work with med spas across the US.
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Common questions
Can a non-physician own a med spa in Colorado?
Not the medical practice. Colorado limits ownership of medical professional service corporations to Colorado-licensed physicians, with physician assistants allowed a minority stake, and prohibits general business entities from employing physicians. Non-physicians typically own a management services organization that provides non-clinical services to a physician-owned practice.
Can a physician assistant own a med spa in Colorado?
A PA can be a shareholder in a medical professional service corporation, but one or more PAs may not own a majority. HB26-1249 would have let PAs own a majority of a corporation organized solely for medical-aesthetic services, but the bill was postponed indefinitely in March 2026.
Can a nurse practitioner own a med spa in Colorado?
Colorado APRNs can delegate medical-aesthetic services, as HB25-1024 recognizes, and Colorado grants APRNs independent prescriptive authority after a transition period. Whether an APRN-owned entity can offer a full med spa menu without physician ownership is a question we could not confirm from a primary source, so check it with a Colorado healthcare attorney.
What does Colorado HB25-1024 require from med spas?
When a physician or APRN delegates medical-aesthetic services to someone who is not a licensed health care provider, the practice must post a sign in the treatment area with the delegating practitioner's name, license number, contact information and the board complaint web address; state in its website and advertising that services are delegated, with the practitioner's name and license number; and get a signed informed consent form explaining the delegation, kept for seven years.
What was Colorado HB26-1249?
A 2026 bill titled Medical-Aesthetics Corporation Ownership. It would have let estheticians, cosmetologists, practical nurses, registered nurses, APRNs and PAs own shares in a corporation organized solely for medical-aesthetic services. The House Health and Human Services Committee voted 13-0 on March 25, 2026 to postpone it indefinitely.
A note on this guide: it explains marketing practice, not legal advice. Rules on privacy, advertising and insurance change and vary by state, so confirm anything compliance-related with your own counsel.
Marketing a Colorado med spa?
Book a 30-minute call with a member of our Sr. Leadership team. We will check your ads and website against HB25-1024 disclosure rules and review your Google presence.