How to Start a Med Spa in Georgia: Medical Director Rules, Delegation and the 2026 Board Statement

October 29, 2026

Georgia has no law written specifically for medical spas. A med spa here is a business built from three things: the licenses of the people who treat patients, the rules for delegation and supervision, and ordinary business law. If any one of those is wrong, the whole operation is exposed, so this guide covers them in order of importance. Start with the licenses and the medical director arrangement, because that is where most med spa problems begin.

This article is informational content, not legal or tax advice. Rules and fees change. Confirm every figure on the agency's own page, and talk to a Georgia health care attorney and a CPA before you sign a medical director agreement or choose an ownership structure.

Materials and Information to Gather First

• A list of every clinical provider you plan to employ or contract with, with their Georgia license numbers
• Access to the license verification tools on the Georgia Composite Medical Board, Georgia Board of Nursing and cosmetology board websites
• A business name checked against the Secretary of State business search
• A written list of services, each tagged with the license it requires
• A draft medical director or supervision agreement, which a Georgia health care attorney should review
• A filing budget: $110 to form an LLC or corporation, $35 to reserve a name, plus the local and state items in the steps below

1. Verify Every Clinical License Before You Hire or Contract

Georgia licenses med spa staff through separate boards, and each board governs what its licensees may do. Georgia does not license med spas as such, so your compliance depends on the people who perform procedures.

Provider	Licensed by	What it means for your clinic
Physician	Georgia Composite Medical Board	Practices medicine and may perform or delegate medical procedures
Physician assistant	Georgia Composite Medical Board	Works under physician supervision as Georgia law allows
APRN	Georgia Board of Nursing	Scope and supervision rules apply to each procedure
RN and LPN	Georgia Board of Nursing	Acts within nursing scope and delegation rules, not as an independent prescriber
Esthetician	State Board of Cosmetology and Barbers	Performs cosmetology-scope services only

Every person who performs a procedure must hold the right Georgia license for it. A license from another state does not count. Check each person in the state's verification tool before their first shift and again at each renewal, then keep dated printouts in a credential file. A license that lapsed or was restricted after you hired someone is still your problem.

Common mistake: assuming an injector licensed in another state can work in your Georgia clinic, or checking a license only from a resume.

2. Read the Composite Medical Board's May 7, 2026 Position Statement

This is the most important development for med spa owners in 2026. On May 7, 2026, the Georgia Composite Medical Board issued a statement aimed at what it calls “matchmaker medical director” arrangements, in which a physician signs a contract but provides no genuine clinical oversight. Law firm summaries report that the statement reads existing Georgia law to:

• bar paid physician-matching services that assign or route a delegating or supervising physician for a fee
• bar a physician from being an employee of an APRN or an APRN-owned company when the physician is required to supervise that APRN
• treat any payment, money or otherwise, for serving as a supervising or delegating physician as a problem

The Board also circulated draft guidance on IV hydration. It warns against relying on an RN or LPN evaluation alone, against generic standing orders, against menu-based treatment without an individualized patient assessment, and against drug handling and sterile compounding that do not satisfy Georgia pharmacy law and USP 797. These are the Board's stated positions as summarized by others, so read the statement itself on the Board's website before you rely on any summary.

What to do about it

1. Read the statement on the Board's website. Summaries can drop qualifiers that matter.
2. Map every arrangement. For each physician, write down who supervises whom, how the physician is paid, and whether the physician reviews protocols, sees patients and is reachable when a delegated procedure happens.
3. Reject a signature-only medical director. A physician who signs a contract and never reviews a chart is the arrangement the Board describes. Pay for real oversight time, not a name on the letterhead.
4. Write individualized protocols. IV therapy and injectables need an assessment that fits each patient, not a menu applied to everyone.
5. Confirm drug handling against the pharmacy rules. Storage, compounding and sterile preparation must meet Georgia pharmacy law and USP 797. Have a pharmacist confirm this in writing.
6. Have a Georgia health care attorney review the medical director agreement. Delegation is governed by the Composite Medical Board's rules in Chapter 360. Read those rules yourself or ask counsel to walk you through them.

3. Sort Your Services by License Scope

Not every service in a med spa falls under the same rules. Split your menu into two groups before you design the space or buy equipment.

Medical services

Injectables, lasers that treat tissue, IV therapy and prescription products are medical services. They must be performed by, or delegated and supervised within the scope of, a licensed physician, PA, APRN or RN as Georgia law allows. Confirm with counsel and the medical board which person may operate each device and under what supervision. Manufacturer training or a course certificate does not replace the clinical license a procedure requires, and an esthetician license does not authorize medical procedures.

Cosmetology-scope services

Facials, waxing and other esthetic treatments are cosmetology services. The person performing them needs an esthetician or cosmetologist license, and the location needs a Board-licensed salon or shop. The business name must include “Salon” or “Shop,” and the owner completes a Board-approved health, safety and sanitation course. If you offer both groups in one building, you need both sets of approvals. Read the salon business guide and the cosmetology license guide before you sign a lease.

Common mistake: treating the whole med spa as a salon, or the whole thing as a medical office. Each group is governed separately, and mixing them up is a common route to a violation.

4. Check Whether the Health Spa Act Covers Your Memberships

Georgia's Health Spa Act (O.C.G.A. 10-1-393 and 10-1-393.2) was written for gyms and “health spas,” which the statute defines as establishments whose primary purpose includes services meant to improve a person's physical condition or appearance through weight change, treatment, dieting or exercise. The Act excludes practices owned and operated by licensed physicians practicing medicine.

Whether a med spa's prepaid memberships fall under the Act is not settled. Before you sell multi-month packages, ask the Attorney General's Consumer Protection Division or a Georgia attorney, and confirm the answer with the agency. If the Act applies, contracts are capped at 36 months and the contract forms must be filed with the Attorney General. The terms are laid out in our fitness studio guide.

Tip: Decide on your membership structure before launch and get the answer in writing. Rewriting contracts after you have sold packages is harder and more expensive.

5. Complete the Business Basics in Order

These steps are routine, but the order matters. Form the entity first, because your contracts, bank account and licenses all depend on the legal name.

1. Form the entity. File Articles of Organization for an LLC or Articles of Incorporation for a corporation with the Secretary of State's Corporations Division, online through eCorp or on paper. The total cost is $110 ($100 fee plus $10 service charge). Online filings take about 7 to 10 business days and paper filings about 15 business days. Expedited review costs $120 (2 business days), $275 (same day if received by noon) or $1,200 (one hour on business days). You can reserve a name for 30 days for $35. Every entity needs a registered agent with a Georgia street address, not a P.O. box, and an entity cannot serve as its own agent. Read the LLC formation guide for the full process.
2. Settle who can own the practice. Who may own a practice that employs or contracts with physicians is a legal question for a Georgia health care attorney, not a rule this guide can state. Settle it before you file, because changing ownership later means more paperwork and possibly new approvals.
3. Calendar the annual registration. The annual registration is $60 ($50 plus $10), due between January 1 and April 1 each year. An LLC files its first registration in the year after it forms, and a new corporation files within 90 days of incorporating. Confirm the current window and late penalty with the Secretary of State. An entity that stays delinquent can be administratively dissolved, and reinstatement costs about $260.
4. Get the local occupation tax certificate. Georgia issues no general statewide business license, and the Secretary of State issues none. The local certificate, often called a business license, comes from the city if you are inside city limits, or from the county if you are unincorporated. It is issued under O.C.G.A. Title 48, chapter 13. Georgia has 159 counties and about 537 cities, and each sets its own formula, deadlines and prerequisites, so call your issuer before you sign a lease. Employers with more than 10 employees must file an E-Verify affidavit to get the certificate (O.C.G.A. 36-60-6). Clinical staff licenses come from the state boards described above. See our Georgia business license guide.
5. Register with the Department of Revenue. Register through the Georgia Tax Center if the spa sells taxable retail products or has employees. This sales tax registration is free and is not a business license. The state rate is 4%, and combined state and local rates run from 6% to 9% depending on county and city (Atlanta is 8.9%). Georgia issues no separate resale permit; the resale instrument is Form ST-5, the certificate of exemption. See our sales tax guide.
6. Register a trade name if you need one. If the spa operates under a name other than its legal name, file a trade name registration with the Clerk of Superior Court in the county where the business is chiefly carried on. It is not filed with the Secretary of State. The clerk fee is about $165, plus newspaper publication once a week for two weeks. Confirm the exact amount with your county clerk and read the Secretary of State FAQ.
7. Carry workers' compensation. Georgia requires coverage at three or more workers, including part-time staff. See our workers' compensation requirements guide. Georgia has no state paid sick leave or family leave mandate, but federal rules and your own policies still apply.
8. Plan for taxes. Georgia uses one flat rate for individual income tax, and the corporate rate equals the individual rate. Corporations, and LLCs taxed as corporations, pay a net worth tax of $0 to $5,000 depending on net worth. A typical single-member or partnership LLC owes no Georgia franchise tax. Ask a CPA to model your structure, and see our Georgia business taxes overview.

Common Mistakes to Avoid

• Signing a medical director agreement before reading the May 2026 Board statement
• Paying a matching service to assign a supervising physician
• Hiring a clinician whose Georgia license was never checked in the verification tool
• Using one standard IV menu for every patient instead of an individual assessment
• Selling 36-month packages without first checking whether the Health Spa Act applies
• Assuming the county issues your certificate when you are inside city limits, where the city issues it
• Forgetting the annual registration window, which closes April 1

Realistic Results and How to Describe Them

Formation is the fast part. Online filings take about 7 to 10 business days, and the local certificate and sales tax registration can take longer depending on your city or county. The slow part is building a compliant clinical model, which is why the medical director and delegation work should come before you lease space or buy equipment.

Describe patient outcomes with hedged language such as “many patients report,” “may help” or “is designed to.” Avoid “guaranteed,” “permanent,” “cures,” and “FDA approved” unless the specific product carries that approval for that use. Product claims are regulated by the FDA, and advertising is subject to Georgia and federal consumer protection law. Have counsel review your website, promotions and before-and-after photos, and state that results vary by patient in every consultation.