New York’s Landmark Ruling on Medical Spas and Energy Devices
Background on New York’s Medical Spa Regulation Changes On March 7, 2025, the New York State Board for Medicine issued a determination that will reshape the landscape of cosmetic and aesthetic services throughout the state. In its ruling, the Board held that the use of energy-based devices-lasers, intense pulsed light (IPL), radiofrequency, ultrasound, and similar technologies-that penetrate beyond the surface of the skin constitutes the practice of medicine. The implications of this shift are profound, both legally and commercially, as medical spas and non-physician operators now face an entirely new regulatory reality. For years, the medical spa industry has thrived in a regulatory gray zone. Devices once marketed as “non-invasive” or “minimally invasive” blurred the line between cosmetic enhancement and medical treatment. Consumers flocked to spas offering wrinkle reduction, skin tightening, fat sculpting, and tattoo removal without giving much thought to whether these services we...