California Issues Statewide Warning on Unlicensed Med Spa Services Following Investigations and Consumer Injuries

Recent enforcement activity by California State authorities highlights growing regulatory and consumer protection concerns surrounding businesses operating as med spas. On January 8, 2026, the California Department of State issued a public warning to consumers after a statewide investigation revealed widespread instances of unlicensed medical services, unsafe practices, and serious consumer injuries.

The investigation, led by the Department of State’s Division of Licensing Services in coordination with the California State Department of Health, the California State Education Department, and the California City Office of Oversight and Investigations, resulted in inspections of hundreds of businesses offering medical and cosmetic procedures. The findings underscore the risks posed by unlicensed providers and the legal obligations applicable to businesses promoting or offering med spa services in California.

This blog summarizes the investigation’s findings, outlines the regulatory requirements governing med spa services in California, and highlights guidance provided to consumers and businesses in response to these enforcement actions.

Statewide Investigation into Med Spa Service Providers

Scope of the inspections

The Department of State conducted 223 inspections of businesses across California State that were promoting or providing med spa services. Phase one of the investigation began in California City and focused on appearance enhancement businesses offering medical procedures, including cosmetic injections and intravenous infusions.

Of the businesses inspected, 87 were cited for potential violations, including the unlawful practice of medicine. While many matters remain pending hearings and final resolution, enforcement outcomes have already included monetary fines, license suspensions, and license revocations. The Department of State has indicated that inspections will continue as part of its ongoing annual inspection program.

Unsafe Conditions and Unlicensed Practices Identified

During the inspections, investigators observed numerous safety and compliance issues. These included expired and suspected counterfeit products, the presence of controlled substances such as Fentanyl, Xylocaine, and Propofol, and unsanitary conditions involving used and unused needles stored together.

Investigators also found medical devices associated with procedures such as laser liposuction, buttock augmentation, centrifugation, non ablative skin lasers, cryotherapy, and laser tattoo removal. In many cases, individuals without the appropriate professional licenses were found performing these medical services.

Reported Injuries and Enforcement Examples

Based on inspection findings and consumer complaints, state authorities reported injuries linked to injections of counterfeit drugs and procedures performed by unlicensed individuals. Reported harms included allergic reactions, burns, double vision, harmful poisoning, infections, sepsis, and hospitalization.

The Department of State cited examples of prior enforcement actions to illustrate the risks posed by unlawful practice. In one matter, an appearance enhancement license holder injected unknown substances into a consumer’s face, neck, and breasts, resulting in significant pain, blistering, infection symptoms, and permanent scarring. In another case, a licensed esthetician operating an unlicensed salon provided cosmetic injections and other procedures that led to a MRSA infection, sepsis, and hospitalization. These cases resulted in license revocations and emergency enforcement actions.

Regulatory Requirements for Med Spa Services in California

Licensing and Professional Requirements

Businesses promoting or offering med spa services that include medical procedures must be licensed as medical facilities or medical practices. Medical procedures must be performed by licensed professionals such as physicians, nurse practitioners, physician assistants, or registered nurses acting within the scope of their licensure and under appropriate supervision.

Medical facilities typically employ a licensed physician or nurse practitioner as a medical director responsible for ensuring that patients receive care from qualified staff. Physician practices are owned and operated by licensed physicians who are accountable for the safety and effectiveness of patient care.

Providers operating through professional entities such as professional corporations or professional limited liability companies must obtain a Certificate of Authorization from the California State Education Department. Even when properly organized, medical providers may not include the word spa in the name of the professional entity, which may signal potential regulatory violations.

Medical Versus Non Medical Services

While med spas may offer both non medical and medical services, many commonly marketed procedures require a professional medical license. These include injections of drugs or fillers, microneedling, cryotherapy, liposuction, laser procedures other than laser hair removal, dermal peels, plasma treatments, radiofrequency procedures, skin tag removal, ultrasound treatments, intravenous therapy, hormone replacement therapy, vitamin infusions, GLP one weight loss drugs, and similar services.

Consumers are advised that even procedures marketed as non invasive may still be classified as medical services requiring licensed professionals.

Consumer Guidance and Enforcement Coordination

State agencies emphasized the importance of consumer awareness and verification of provider credentials. Consumers are encouraged to confirm that medical directors and practitioners are properly licensed, review disciplinary histories, and obtain medical consultations before undergoing any procedures.

California State authorities also provided guidance on how to file complaints with the appropriate agency depending on the type of provider involved, including the Department of Health, the State Education Department, the Department of State’s Division of Licensing Services, or local law enforcement in cases involving harm from unlawful medical practice.

Multiple state agencies reiterated their commitment to coordinated enforcement, public education, and accountability to protect consumers from unsafe and unauthorized med spa services.

Practical Implications for Businesses and Consumers

The Department of State’s warning reflects heightened scrutiny of businesses operating in the med spa space and underscores the legal risks associated with offering medical services without proper licensure. Businesses marketing med spa services must carefully evaluate whether their operations comply with medical facility, professional licensure, and corporate practice requirements.

For consumers, the investigation highlights the importance of verifying provider qualifications and understanding that cosmetic and wellness services may carry serious medical risks when performed by unlicensed or unqualified individuals.

Final Thoughts

The statewide investigation and resulting enforcement actions signal a clear message from California regulators that unlicensed med spa services pose unacceptable risks to public health and safety. As inspections continue, both businesses and consumers should expect sustained regulatory oversight and enforcement in this area.

Entities offering med spa services and individuals seeking treatment should take proactive steps to ensure compliance with licensing requirements and adherence to professional standards, recognizing that consumer safety remains the central focus of California State’s regulatory efforts.

If you would like to discuss regulatory requirements applicable to med spa operations or compliance considerations under California law, our team at Crestfield is available to assist.

Authors: Jan Louise Henry, Esq. and Weiwei Lu

Contact Person: Nick L. Torres, Esq. and Zhiqi Zheng, Esq.