The most misread thing about Colorado’s 2025 disclosure law is what it did not do. It did not prohibit delegating medical-aesthetic services to unlicensed individuals. It required you to tell people you are doing it.
That is a sharper instrument than a ban, because it puts the decision in front of the client at the point of sale and leaves the legal responsibility exactly where it already was — with the delegating practitioner.
What delegation does not change
Delegation moves the performance of a task. It does not move the responsibility for it, and it never expands the receiving person’s authority. Three things stay with the delegating physician or APRN regardless of who is holding the syringe:
- Patient selection. Whether this patient should have this treatment is a clinical judgment, and it is not delegable to someone unlicensed.
- The protocol. Dosing parameters, product documentation, injection technique boundaries and the limits of what may be done without escalation.
- Complications. The response plan for the common ones and the serious ones, including who is contacted and how fast.
Colorado’s medical board delegation rules for cosmetic procedures reach the use of lasers, radio-frequency devices and intense pulsed light where tissue is structurally altered or hair removed, and the injection of neurotoxins, collagen, hyaluronic acid fillers and comparable substances for cosmetic purposes. Note also that delegation to a registered nurse runs through the Nurse Practice Act rather than the medical board’s delegation rule — two different frameworks, and a single template covering both is a sign the paperwork was bought.
The protocol content that matters
A protocol that will survive review is specific about:
- Which services may be delegated, to whom, and with what training evidenced.
- Selection criteria that screen patients out, not just in.
- Dosing and product parameters, with lot and product documentation.
- Adverse-event response, including vascular occlusion, and the escalation pathway to the physician.
- When treatment must stop and the patient be seen.
Now add the disclosure layer
On top of all that, HB25-1024 requires the on-site sign, the website and advertising statements, and the seven-year consent. Practically, that means your delegation decisions and your marketing have to agree with each other — which is a discipline most clinics have never had to apply.
The question to answer honestly
Would a client who read your sign carefully still book? If yes, delegation is working for you. If no, you have learned something about the model that Colorado has now made unavoidable, and it is better learned from your own signage than from a complaint.
Related reading
Frequently asked questions
Can unlicensed staff perform injections in Colorado?
Colorado’s framework contemplates delegated medical-aesthetic services performed by unlicensed individuals, which is precisely why the disclosure law exists. What may be delegated, to whom, and on what training is a question for your delegating practitioner and your counsel, service by service.
Does delegation to a registered nurse follow the same rule?
No. Delegation to an RN is governed by the Nurse Practice Act rather than the medical board’s cosmetic delegation rule.
Who is responsible if a delegated treatment goes wrong?
The delegating practitioner retains responsibility for selection, protocol and complication response. Delegation moves the task, not the accountability.
What has to be in the protocol?
At minimum: which services may be delegated and to whom, patient selection criteria, dosing and product parameters, adverse-event response and the escalation pathway.
General information about Colorado delegation rules, not legal advice. Board rules change. Confirm your obligations with healthcare counsel licensed in Colorado.