Who can inject Botox in New York?

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

In New York, physicians (MD/DO), nurse practitioners and physician assistants can inject Botox and dermal fillers, because cosmetic injectables are the practice of medicine. A registered nurse can inject only by carrying out a patient-specific order from a physician, NP or PA who has examined the patient; New York's standing-order law does not cover cosmetic injectables. LPNs are not addressed by any specific rule, and medical assistants, estheticians and cosmetologists cannot inject.

Who can inject in New York: role by role

Role	Botox (neurotoxins)	Dermal fillers	Conditions
Physician (MD/DO)	Yes	Yes	Licensed in New York. Injectables need a medical license under the Department of State chart and Education Law 6521.
Physician assistant	Yes, with conditions	Yes, with conditions	Only under continuous physician supervision, and only for duties within the supervising physician's scope of practice. The physician does not have to be on site. A physician may supervise up to six PAs in private practice (Education Law 6542).
Nurse practitioner	Yes, with conditions	Yes, with conditions	Within the NP's certified specialty area. NPs with 3,600 hours of practice or less need a written collaborative agreement and protocols with a physician; NPs with more than 3,600 hours may practice without them (current law runs to July 1, 2030). No NYSED statement names which specialties cover aesthetic injections.
Registered nurse	Yes, with conditions	Yes, with conditions	Only by executing a patient-specific order from a physician, NP or PA who has examined the patient (or a dentist within dental scope). No standing orders for cosmetic injectables. The RN cannot make the medical diagnosis or decide the treatment. No NYSED statement names Botox or fillers for RNs; this follows from the general nursing law.
LPN/LVN	Not addressed	Not addressed	No board statement found. LPNs may give most medications under the direction of an RN or authorized practitioner, usually with the directing practitioner on premises. Treat cosmetic injecting by an LPN as unsettled.
Medical assistant	No	No	Medical assistants are unlicensed in New York. Board for Medicine guidance bars unlicensed staff from drawing up medications or giving injections of any kind.
Esthetician	No	No	Esthetics licensing does not cover injections. The Department of State lists neurotoxins and fillers as procedures that need a medical license. The same applies to cosmetologists.

Dentists are a special case. NYSED says a dentist may use Botox or fillers in the oral and maxillofacial area only when it relates to restoring and maintaining dental health, for example alongside jaw surgery, and only if trained. Stand-alone cosmetic or facial recontouring injections are outside dental scope.

The patient exam before treatment

New York has no statute or board rule that names a "good faith exam" for med spas. The requirement comes from the general rules instead. Deciding that a patient needs Botox or filler, and which product and dose, is diagnosing and treating, which a physician, NP or PA may do. An RN is not legally allowed to make a medical diagnosis or prescribe a treatment.

NYSED says that in most cases an RN carries out treatment ordered for a specific patient by a practitioner "who has examined the patient." So the physician, NP or PA must examine the patient and write the order before the RN injects. The Department of State also tells consumers that injectables are medical procedures and that they must be seen by a medical professional first. We found no New York rule that says whether that exam must be in person. State telehealth law lists physicians, PAs and NPs as telehealth providers and covers assessment, diagnosis and treatment, but it does not address cosmetic injectables.

Supervision and delegation

Patient-specific orders only for RNs. New York lets RNs follow non-patient-specific orders (standing orders) only for a short list set in Education Law 6527 and 6909, such as immunizations, anaphylaxis treatment, opioid overdose treatment and certain tests. Cosmetic neurotoxins and fillers are not on that list.
Who can order for an RN. NYSED lists physicians, dentists, NPs, PAs, midwives and podiatrists among the providers whose patient-specific orders RNs may carry out, each within their own scope.
PAs. Supervision must be continuous, but the physician does not need to be physically present.
NPs. NPs can diagnose, treat and prescribe in their specialty without physician supervision. NPs with 3,600 hours or less must practice under a written collaborative agreement and protocols.
LPNs. The directing RN or practitioner must usually be on premises. The exception requires, among other things, that the practitioner can be reached by phone or video and can intervene in person within 15 minutes.
No delegation to unlicensed staff. Letting an unlicensed person inject is professional misconduct for the licensee. For the person who injects, and anyone who aids them, unauthorized practice is a class E felony.

New York has no injectable-specific rule on whether the physician, NP or PA must be on site when an RN injects. For comparison, the Board for Medicine's 2025 guidance on lasers and energy devices uses "general supervision": the supervisor need not be present but must be available to give guidance or intervene within a reasonable period. That guidance covers devices, not injections.

Med spa ownership and the medical director

New York enforces the corporate practice of medicine strictly. NYSED's report on the corporate practice of the professions says business corporations cannot hire licensees to provide professional services, except where a law allows it, such as hospitals. A medical practice is organized as a professional entity, such as a professional corporation (PC) or professional limited liability company (PLLC), owned by licensed professionals. A PC may issue shares only to people licensed in the profession it practices. Letting an unlicensed person share in professional fees is misconduct for the physician.

That means a non-licensed investor, esthetician or spa company cannot own the medical practice behind a med spa in New York. The Department of State says businesses offering injectables must be licensed as a medical facility or a medical practice. We found no exception for med spas. We also found no New York statute or board rule that requires a med spa to name a "medical director." The legal duties fall on the licensees who own the practice and who order, supervise or perform each treatment.

Training and certification

We found no New York rule that requires a state certificate or a set number of training hours to inject Botox or fillers. Licensure and scope are the legal gate. Licensees must still be competent: delegating to someone not qualified by training is misconduct, and NYSED's dental alert says a dentist's use of these products is within scope only "if trained."

Recent changes

April 2024: The New York State Dental Association reported NYSED's practice alert on Botox and dermal fillers, which limits dentists to dental-related use and rules out stand-alone cosmetic injections.
March 7, 2025: The Board for Medicine ruled that lasers and energy devices that reach the basement membrane or deeper are the practice of medicine, with RNs as the only professionals other than physicians, PAs and NPs allowed to carry out those orders. This does not cover injectables but signals how the Board views med spa work.
January 8, 2026: The Department of State reported a joint investigation with the Department of Health and NYSED: 223 businesses inspected and 87 cited for possible violations, including unlawful practice of medicine.
May 2026: The 3,600-hour rule that lets experienced NPs practice without a written physician agreement was extended to July 1, 2030.
July 15, 2026: The Department of State revised its med spa procedure licensure chart, which lists neurotoxins, fillers, PRP and IV therapy as procedures that need a medical license.
September 2, 2026 (pending): Assembly Bill A11705 would define "med spa" in the General Business Law, create a multi-agency task force, require unannounced inspections at least every 15 months and require $1 million in liability insurance or a bond. It is in committee and is not law.

FAQ

Can an RN inject Botox under a standing order in New York?

No standing-order route was found for cosmetic injectables. New York limits RN standing orders to a list in Education Law 6527 and 6909, and Botox and fillers are not on it. The RN needs a patient-specific order from a physician, NP or PA who has examined the patient.

Can a nurse practitioner open a Botox practice in New York?

An NP can inject and treat within their specialty, and NPs with more than 3,600 hours do not need a written physician agreement under current law. We found no New York rule that speaks directly to an NP-owned med spa, so get a lawyer's view on the entity structure before opening.

Can an esthetician or medical assistant inject Botox in New York?

No. The Department of State lists neurotoxins and fillers as procedures that need a medical license, and Board for Medicine guidance bars unlicensed staff, including medical assistants, from giving injections of any kind.

Can a dentist do cosmetic Botox in New York?

Only when it relates to dental health in the oral and maxillofacial area. NYSED says stand-alone cosmetic or facial recontouring injections are outside dental scope.

Can an LPN inject Botox in New York?

New York has no specific rule on it. LPNs may give most medications under the direction of an RN or authorized practitioner, but treat cosmetic injecting by an LPN as unsettled and check with the NYSED Office of the Professions first.

Sources

New York Education Law 6521, definition of the practice of medicine (New York State Senate)
New York Education Law 6902, nursing and nurse practitioner practice (New York State Senate)
New York Education Law 6527, physician non-patient specific orders (New York State Senate)
New York Education Law 6909, nurse practitioner non-patient specific orders (New York State Senate)
New York Education Law 6542, physician assistant supervision (New York State Senate)
New York Education Law 6509, professional misconduct for all licensees (New York State Senate)
New York Education Law 6530, professional misconduct for physicians and PAs (New York State Senate)
New York Education Law 6512, unauthorized practice (New York State Senate)
New York Business Corporation Law 1507, professional corporation shares (New York State Senate)
New York General Business Law 400, definition of esthetics (New York State Senate)
New York Public Health Law 2999-cc, telehealth definitions (New York State Senate)
Assembly Bill A11705 (2025-2026), med spa task force (New York State Senate)
Frequently asked practice questions for nursing (NYSED Office of the Professions)
Non-patient specific orders and protocols (NYSED Office of the Professions)
Practice requirements for nurse practitioners (NYSED Office of the Professions)
Utilization of medical assistants (NYSED, State Board for Medicine)
Use of energy devices including lasers as the practice of medicine (NYSED, State Board for Medicine)
Practice alert for the administration of Botox and dermal filler (NYSED Office of the Professions, dentistry)
Corporate practice of the professions (NYSED Office of the Professions, Board of Regents report)
Med spa procedure licensure chart (New York Department of State)
Consumer warning after med spa investigations, January 8, 2026 (New York Department of State)
NYSED issues guidance on Botox and dermal fillers (New York State Dental Association)
New York extends nurse practitioner independent practice authority through 2030 (Dermatology Times)

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

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