Utah is taking a hard look at med spas. On September 16, 2026, the state's Office of Professional Licensure Review (OPLR) med spa review went to lawmakers with recommendations. These are not law: no bill has been filed and Utah's rules haven't changed.
By Amber Bechthold, Founder & CEO of Aesthetic Compliance Experts · Esthetician with 25 years in medicine and aesthetics · Last reviewed October 27, 2026
Key Facts at a Glance
Status: Recommendations · not law
State: Utah
Source: OPLR med spa review, Office of Professional Licensure Review
Presented: September 16, 2026, to the Business and Labor Interim Committee
Next: Utah's 2027 session runs January 19 to March 5, 2027
What it would do: set who examines, who injects and who can call itself a med spa
Who it would affect: doctors, advanced practice nurses, PAs, RNs, LPNs and master estheticians
What Changed
Exam and plan first: a doctor, advanced practice nurse (such as a nurse practitioner) or PA would examine first and write a plan.
Who gives shots: only RNs could be handed shots. Wellness shots would need the supervisor on site.
Minor cosmetic procedures: master estheticians, RNs and LPNs could be handed these.
Using the name: only places that fit the definition could call themselves a med spa.
Why This Matters in a Med Spa
If these recommendations become a bill in 2027, they would change who examines, who injects and who can use the name "med spa" in Utah. It's worth knowing now, before the session starts.
Does This Apply to My Clinic?
If your clinic is in Utah, it's worth watching. Nothing has changed yet.
What the law doesn't spell out
The draft can still change before it gets a bill number
It doesn't use the words "medical director"
The med spa part doesn't mention medical assistants
Hair removal exams could still be handed to an RN or master esthetician
Ask Utah's Division of Professional Licensing or your attorney.
Frequently Asked Questions
Did Utah change its med spa rules?
No. These are recommendations only. No bill has been filed.
When could this become law?
Only if a bill is filed and passed. Utah's 2027 session runs January 19 to March 5, 2027.
Could medical assistants still inject?
Under the recommendations, only RNs could be handed shots. The med spa part doesn't mention medical assistants.
Sources
Utah Public Notice: OPLR presentation, Business and Labor Interim Committee, Sept. 16, 2026
American Med Spa Association: Utah med spa review
What This Means for Your Clinic
If your clinic is in Utah, nothing has changed yet. The areas these recommendations would touch are:
Who examines patients and writes the plan
Who gives injections, including wellness shots
What master estheticians, RNs and LPNs can be handed
Whether you can call your clinic a med spa
We'll keep watching for a bill. Questions about your own setup go to your attorney or Utah's Division of Professional Licensing.
Need a legal answer for your clinic?
ACE works with Doris Dike, Esq., founder of Dike Law Group PLLC, our outside legal counsel. If you need an attorney to look at how this applies to your clinic, her office can help.
Phone: (972) 290-1031
Office: 6160 Warren Parkway, Suite 100, Frisco, TX 75034
Book a call: dklawg.com/contact
Have questions about how this applies to your clinic? Book a free 30-minute Gap Analysis Call or text us anytime at (817) 442-7484.
This post is educational. It is not legal advice, and requirements differ by state and by practice. Confirm how any change applies to your clinic with your own attorney or your licensing board.
