Widespread Violations in “Med Spas” Holding Only Cosmetology Licenses

From June to September 2024, city and state inspectors evaluated 15 businesses that held Appearance Enhancement Business (AEB) licenses from the cosmetology board, but did not hold the licenses required to offer medical procedures such as neuromodulator injections, dermal fillers, Brazilian butt lifts, and IV infusions.

The inspections found:

• All 15 of the inspected businesses were performing medical procedures without the necessary medical licenses.
• 93% failed to properly display their licenses.
• 86% failed to maintain basic safety records.
• 73% lacked appropriate medical professional oversight.
• 65% had chemical and fire safety violations.
• 60% lacked liability insurance.
• 53% had sanitation or hygiene deficiencies.
• 26% employed at least one unlicensed or expired practitioner.

Each business received Department of State (DOS) violations. Four med spas have already lost their cosmetology and AEB licenses following DOS-initiated hearings; the remaining 11 are under review with additional enforcement possible.

“New Yorkers deserve to know that the services they’re paying for are safe, legal, and provided by trained professionals,” said Council Member Gale A. Brewer, Chair of the Committee on Oversight and Investigations, in conjunction with the report’s release. “This investigation makes clear that locations across the city may be cutting corners, putting people at risk, and operating far outside the bounds of the law. … We need stronger oversight, more transparency for consumers, and real public education so that every New Yorker can make informed decisions about their health and safety.”

Key Policy Recommendations

To address the systemic risks exposed by the investigation, the New York City Council has advanced several recommendations:

• Mandatory consumer notices for AEB-licensed businesses.
  The Council recommends legislation requiring AEB businesses to post clear, conspicuous signage stating that they are not permitted to perform medical procedures.
• Regular, coordinated inspections.
  The report calls for routine inspections of AEB-licensed locations, with targeted focus on businesses advertising or delivering medical services.
• Statewide public education campaign.
  The Council urges a broad education initiative so New Yorkers understand the difference between cosmetic and medical services, the meaning of professional titles and licenses, and how to verify whether a provider and facility are properly credentialed. 

For ethical med spa owners and providers, this is an opportunity to:

• Audit your own compliance: licensure, supervision, protocols, documentation, insurance, and staff credentials.
• Educate your teams about state-specific rules governing medical spa practice.
• Communicate transparently with patients about licenses, training, and safety systems.
• Support thoughtful regulation and enforcement that targets illegal practice while enabling safe, patient-centered innovation.

AmSpa supports compliant, medically directed aesthetic practices with the education, tools, and guidance to uphold their legal obligations and clinical best practices. The med spa community will continue to elevate standards, restore public trust in the profession and ensure that patients receive the safe, high-quality care they deserve.