Illinois Med Spa Laws: Who Can Legally Inject Botox & Fillers?

Who Can Legally Perform Aesthetic Procedures in Illinois?

Scopes of practice come from Illinois licensing laws, explained in guidance from the Illinois Department of Financial and Professional Regulation (IDFPR). The summary below follows the IDFPR and IDPH medical spa memo (updated October 30, 2025) and the statutes it cites. It is general information, not legal advice; confirm current requirements with IDFPR or an attorney.

Physicians (MD / DO): May operate a medspa, perform cosmetic procedures that affect the living layers of the skin, prescribe and administer drugs including Botox, and supervise and delegate these procedures.

Nurse Practitioners (APRN): An APRN with full practice authority may practice without a written collaborative agreement in all practice settings consistent with national certification, and may prescribe legend drugs and Schedule II through V controlled substances (225 ILCS 65/65-43).

Physician Assistants (PA): Must practice under a written collaborative agreement with a physician and may perform injectable procedures that fall within that agreement. The physician does not have to be present where services are provided, but communication must be available for consultation by radio, telephone, or telecommunications (225 ILCS 95).

Registered Nurses (RN): May administer injectables when a physician delegates the task under 225 ILCS 60/54.2. A delegated task must fall within the scope of practice, education, training, or experience of the delegating physician and within a physician-patient relationship.

Laser and light-based procedures: Using a light-emitting device for cosmetic procedures that disrupt the skin's surface, ablative or non-ablative, is the practice of medicine. A physician may delegate these procedures to an LPN, RN, or APRN with full practice authority, with on-site supervision, or, for non-ablative procedures, with the physician available by phone or electronic means (68 Ill. Admin. Code 1285.336, as summarized in the IDFPR and IDPH memo).

Licensed Estheticians and Cosmetologists: Esthetics covers cosmetic care of the skin's outermost layer, and estheticians are prohibited from using techniques, products, and practices intended to affect the living layers of the skin (225 ILCS 410/3A-1). Illinois currently publishes two parallel versions of that section, from Public Act 104-134 and Public Act 104-153; both keep that prohibition. IDFPR's Statement on Prohibited Practices lists Botox, chemical peels except superficial chemical peels, collagen injections, microneedling, and radio frequency among the procedures that are the practice of medicine and outside their scope. Our guides to chemical peels and Morpheus8 and RF microneedling show how this applies to those treatments.

The Physician Exam Before Delegated Treatment (Good Faith Exam)

When a physician delegates a procedure such as Botox to someone else, IDFPR's Statement on Prohibited Practices sets three conditions: the person receiving the service must be a patient of the physician, the physician must examine the patient and determine the appropriateness and course of treatment, and the person receiving the delegation must carry out the treatment as instructed.

Clinics and consultants often call this a Good Faith Exam (GFE). That label is industry shorthand, not a term found in the Illinois sources above.

Non-ablative laser hair removal has a narrower rule. Since January 1, 2025, an on-site physician exam is not required if a delegation protocol is followed, the exam is performed by an APRN, the procedure is performed by a trained RN or LPN, and a physician is available by telephone (IDFPR and IDPH memo, citing 68 Ill. Admin. Code 1285.336).

If a clinic cannot tell you who examined you or who authorized your treatment, ask before you proceed. Our med spa red flags guide lists other warning signs.