Who can inject Botox in Colorado?

Last checked October 25, 2026 against the sources listed below. Information, not legal advice: confirm with the board before you treat patients.

In Colorado, physicians, physician assistants and nurse practitioners with prescriptive authority can inject Botox and dermal fillers. Registered nurses can inject under an order, standing order or protocol from a physician, PA or other authorized provider. Colorado is unusual because Medical Board Rule 1.17 lets a physician delegate cosmetic injections to unlicensed people, such as medical assistants and estheticians, under strict conditions. Since August 6, 2025, a physician or NP who delegates aesthetic services to an unlicensed person must post their name and license number on site, on the website and in ads, and use a signed consent form.

Who can inject in Colorado: role by role

Role	Botox (neurotoxins)	Dermal fillers	Conditions
Physician (MD/DO)	Yes	Yes	Licensed by the Colorado Medical Board. To delegate injections to unlicensed staff, the physician must be trained in and actively performing the procedure, insured to perform it, and physically present in Colorado.
Physician assistant	Yes, with conditions	Yes, with conditions	Must have a collaborative agreement with a physician who actively practices in Colorado. The agreement must be a supervisory agreement if the PA has fewer than 5,000 practice hours, or is changing practice areas with fewer than 3,000 hours in the new area (C.R.S. 12-240-114.5(2)(b)(I), with limited exceptions). So an experienced PA moving into aesthetics may still need one. Like every PA, they work only within their own training and competence. A PA may delegate to unlicensed staff only under the PA's direct supervision and within the PA's own scope.
Nurse practitioner	Yes, with conditions	Yes, with conditions	Needs prescriptive authority (provisional first, full after a 750-hour prescribing mentorship) and must stay within the NP's role and population focus. No ongoing physician supervision is required once full authority is granted. No Board of Nursing statement addresses cosmetic injections specifically.
Registered nurse	Yes, with conditions	Yes, with conditions	Needs an order, standing order or protocol from a physician or PA, or delegated care from another licensed provider such as an NP. The RN cannot prescribe. The nurse must have the training and competence the Board of Nursing scope test requires. No Board statement addresses cosmetic injections specifically.
LPN/LVN	Not addressed	Not addressed	No board statement found on cosmetic injections by LPNs. The statute lets LPNs give prescribed medications under supervision. The Board's LPN scope policy (30-12) ties LPN scope to the practical nursing curriculum and discusses expanding it with added training and facility guidance, but it does not mention cosmetic injections, so nothing here upgrades LPN injecting.
Medical assistant	Yes, with conditions	Yes, with conditions	Only as a physician's delegatee under Medical Board Rule 1.17, which lists injection of any substance as a medical-aesthetic service. The physician must judge the injection routine and technical, check the MA's training, watch the MA perform it first, write protocols, and review the work regularly. HB25-1024 notices and consent forms apply.
Esthetician	Yes, with conditions	Yes, with conditions	Not part of the esthetician license, and cosmetology rules bar going below the epidermis unless the service is properly delegated under Medical Board rules. Only as a physician's delegatee under Rule 1.17, with the same conditions as a medical assistant. May not use the title "medical aesthetician."

The patient exam before treatment

Colorado has no rule that spells out a "good faith exam" for cosmetic injections. The closest rule is Medical Board Rule 1.17, which applies when a physician delegates to an unlicensed person. It says delegated services must happen within an appropriate physician/patient relationship and that ongoing care of a patient without direct physician involvement is inappropriate. A physician's initial consultation is listed as one sign of that relationship. The physician also should not delegate anything that needs the delegatee's medical judgment.

For registered nurses, the Nurse Practice Act lets an RN act on "a written plan, verbal order, standing order, or protocol, whether patient specific or not." The Board of Nursing says such a plan can authorize discretionary medical action, including selection of medication. We found no Colorado rule that requires the prescriber to examine the patient in person before an RN injects.

Supervision and delegation

Colorado has two separate tracks.

Nurses (RN, LPN, NP): regulated by the Board of Nursing, not by Rule 1.17. The Board says there is no Board requirement for physician oversight during independent nursing practice, and that for delegated medical functions the amount of physician oversight is set by the physician and nurse. Employers and physician practices can require more. LPNs always practice under the supervision of a licensed health care provider.
Unlicensed staff (medical assistants, estheticians, others): covered by Medical Board Rule 1.17. The physician must be on the premises unless detailed written protocols and emergency protocols are in place and the physician is in Colorado and available to promptly attend to the patient in person. If the physician leaves the state, a covering physician who is in Colorado must be named. The physician may use telehealth but should not rely on it alone.

Rule 1.17 also requires the physician to:

Personally confirm each delegatee's education, training or experience and watch them perform the procedure before they do it on their own.
Monitor quality at the site at least every two weeks and reassess each delegatee in person at least once a year.
Review the care given under the delegation within 14 days.
Keep a written delegation agreement (Appendix A) that is available to the public. Job descriptions or similar records can replace it if the physician is on site and able to direct the delegatee at least 60% of the time.

Prescribing cannot be delegated, delegatees cannot pass a task on to someone else, and delegatees must report all adverse events to the physician. Off-label use is generally prohibited unless the physician specifically authorizes it and it fits accepted medical standards.

Nurses can also delegate. The Nurse Practice Act lets nurses delegate routine tasks within their own scope to unlicensed staff when no nursing judgment is needed. HB25-1024 sets disclosure duties for NPs who delegate aesthetic services to unlicensed people, and the Board of Nursing has reminded clinical directors of those duties. No Board of Nursing statement says whether a cosmetic injection is a task a nurse may delegate.

Med spa ownership and the medical director

Colorado law allows professional service corporations for the practice of medicine owned by Colorado-licensed physicians. PAs may hold shares, but physicians must keep majority ownership, and lay directors and officers may not control medical judgment. A 2026 bill to let PAs own a majority of medical-aesthetics corporations, and to let nurses, estheticians and cosmetologists be shareholders, was postponed indefinitely in committee.

We found no Colorado statute or board rule that sets out how a non-physician, including an NP, may own a med spa. Owners often ask about management services organization structures, which no Colorado statute or board rule addresses, so get advice from a Colorado health care attorney.

Rule 1.17 does not set separate duties for a "medical director." The duties fall on the delegating physician, who must keep any medical director agreement on file. Offices where delegated aesthetic services happen must post each delegating physician's name and contact information in the reception area, and each patient must sign a written disclosure before treatment. Under HB25-1024, a physician or NP who delegates aesthetic services to someone who is not a licensed health care provider must also:

Post a highly visible notice where services happen, with the delegating licensee's name, Colorado license number, contact details and the board complaint web address.
Put a notice on the delegatee's website and all advertising saying services are delegated, with the licensee's name and license number.
Give each patient an informed consent form saying the service is delegated, have the patient sign it, and keep it for at least seven years.

These HB25-1024 duties do not apply to facilities regulated under Title 25 of state law.

Training and certification

We found no Colorado rule that requires a state aesthetic injection certificate for any role. Nurses use the Board of Nursing scope test, which asks whether the skill was taught in basic nursing education or, if not, whether the nurse completed a comprehensive training program that included clinical experience. For unlicensed delegatees, the delegating physician must verify education, training or experience, watch the person perform the procedure, and reassess them each year.

Recent changes

HB25-1024 (effective August 6, 2025): new disclosure duties for physicians and NPs who delegate medical-aesthetic services to unlicensed people: on-site notice, website and ad notice, signed consent kept seven years.
HB26-1249 (2026): would have let PAs own a majority of medical-aesthetics corporations and let other licensees hold shares. Postponed indefinitely on March 25, 2026. Not law.
HB26-1107 (2026): the introduced version would have let LPNs and nurse aides give medication by injection in licensed facilities. That language is not in the final law, which covers dementia care disclosures.
HB26-1307 (effective August 12, 2026): continued the Colorado Medical Board to 2035. Its summary does not mention delegation or aesthetic services.
Coming up: the Nurse Practice Act is set to repeal on September 1, 2027, unless the legislature continues it, so the legislature has to act on it by then.

FAQ

Can an esthetician do Botox in Colorado?

Not under the esthetician license. A physician can delegate cosmetic injections to an esthetician under Medical Board Rule 1.17, with training checks, physician observation, written protocols and regular physician review. HB25-1024 notices and consent forms apply to delegation to unlicensed people.

Does a doctor have to be on site when an RN injects Botox in Colorado?

The Board of Nursing has no requirement for physician oversight of independent nursing practice, and for delegated medical functions it leaves the amount of oversight to the physician and nurse. The RN still needs an order or protocol, and employers can set stricter rules.

Can a nurse practitioner open a med spa in Colorado?

NPs with prescriptive authority can inject without physician supervision. No Colorado statute or board statement clearly covers NP ownership of a med spa, so talk to a Colorado health care attorney before setting one up.

What does a Colorado med spa have to post?

The reception area must show each delegating physician's name and contact information. If unlicensed staff perform delegated aesthetic services, the delegating physician or NP's name, license number, contact details and a board complaint address must be posted on site, and a delegation notice must appear on the website and in ads. Patients must sign a consent form that is kept for seven years.

Can an LPN inject Botox in Colorado?

The law lets LPNs give prescribed medications under supervision, but the Board of Nursing has no statement on cosmetic injections, and its LPN scope policy does not address them. Ask the Board or an attorney before relying on it.

Sources

Rules change and boards interpret them case by case. If your situation is unusual, ask the Colorado board or a health care attorney.

We are adding injector jobs state by state. Leave your email and state, and we will write when jobs in your state go up or the rules change. One email a week at most.