On Jan. 6, the American Academy of Dermatology Association (AADA) and the New York State Society of Dermatology and Dermatologic Surgery, released a statement, joining the New York City Council in urging New York lawmakers to require medspas and cosmetology and nail establishments to clearly disclose that they cannot perform medical procedures.
The AADA states that many clients assume staff are licensed in medspas, but these treatments require the expertise of board-certified dermatologists. Per the Jan. 6 press release provided by the AADA, the organizations also join the Council in urging New York State to launch a public education campaign informing consumers about the risks of undergoing cosmetic medical procedures in unlicensed or improperly supervised facilities [1].
NYC Council Report Details Regulatory Failures in Medspas Across the City
In December 2025, the council released a report called ‘A Joint Enforcement Operation Against Improperly Licensed Medspas in NYC,’ detailing why these investigations were initiated across New York, motivated by the rapid expansion of medspas across the state. The report also provided updates of the hearings that took place addressing the violations and lack of regulation.
The investigations took place between June and September 2024 by the NYC Council’s Oversight and Investigations Division [2]. Of the 15 inspected medspas across the five boroughs, the majority failed to display licenses, maintain safety records, have medical professionals present or comply with insurance requirements; some also employed unlicensed or expired practitioners [2].
NYC Physician Calls for Clearer Oversight and Continuous Education in Cosmetic Procedures
David Goldberg, MD, JD, a physician-attorney and the Director of Cosmetic Dermatology and Clinical Research at the Schweiger Dermatology Group in New York says the issue with quality at medspas has been an ongoing issue for some time in New York and across the country. He agrees with the Council's assessment that current regulatory legislation is lacking in clarity and consistency, and that disclosure for AEB businesses "where there is no license for the medical procedures being performed is important patient safety information."
At Schweiger Dermatology in New York, he says providers receive ongoing training through webinars, modules and in-person education, with all PAs and NPs supervised on-site by physicians. While appropriate training and oversight are necessary, these are often baseline. Continued education and ongoing training for protocols and procedures should be fluid, Goldberg adds.
“Safety is always the number one priority. It must be—these are elective cosmetic procedures,” he says. “Licensure is the obvious requirement and baseline for patient safety, but even that is not enough.”
Investigation Spurs Proposals for Stricter Oversight
All 15 of the inspected businesses received DOS violations, resulting in four license revocations now issued, and four cases have been fully adjudicated. Of the 15 businesses, 93% had license display problems and 86% were missing required safety records. The cases for the remaining 11 inspected businesses appear to still be pending, the report states [2].
The council proposes the state lawmakers to consider enacting a law requiring all Appearance-Enhancement Businesses (AEBs) to clearly display disclosure that they are not licensed to perform medical procedures. It would list common services that AEBs are prohibited from providing, including Botox and other injectables, dermal fillers, platelet-rich plasma (PRP) treatments, intravenous (IV) therapy and infusions and body contouring procedures.
State Health Commissioner James McDonald, MD says, “The Department of Health reminds New Yorkers of the importance of ensuring their provider has the proper qualifications and training, especially as cosmetic medspa procedures become more popular. Licensed health care professionals undergo rigorous training to understand the complexities of human physiology, and are the only individuals qualified to perform these services. The Department of Health will continue to investigate and hold individuals and practices accountable who offer unauthorized services that put people’s lives at risk.”
References:
2-https://council.nyc.gov/press/wp-content/uploads/sites/56/2025/12/OID_Medical_Spas-REPORT_120125-v847.pdf?source=email
