Colorado’s Ownership Revolution: PAs & NPs

Colorado may be moving toward one of the biggest ownership changes in the med spa space. Under HB 26-1249, the state would expand who may own and hold a majority interest in a medical-aesthetics professional service corporation. As of March 2026, the bill is still pending under legislative review, so this is not active law yet. But if it passes, the change would be significant.

Right now, Colorado’s professional corporation rules limit majority ownership to licensed physicians. HB 26-1249 would create a specific exception for corporations organized solely to provide medical-aesthetic services, opening majority ownership to a much wider group of licensed professionals.

Start With The Most Important Status Note

Before anything else, one point needs to stay clear: HB 26-1249 has not been enacted. The Colorado summary says it was introduced in the 2026 regular session and, if passed without a safety clause, would take effect around August 12, 2026. Until then, existing ownership expectations remain in place.

That means Colorado med spas should not restructure ownership based on this proposal yet. It should be treated as a meaningful pending change, not a current right.

What HB 26-1249 Would Actually Change

The proposed bill would expand who may be a shareholder in a medical-aesthetics professional service corporation, including who may hold a majority ownership interest.

According to the Colorado brief, the expanded ownership group would include:

• licensed Colorado physicians
• licensed Colorado estheticians
• licensed Colorado cosmetologists
• licensed Colorado practical nurses
• licensed Colorado registered nurses
• licensed Colorado advanced practice registered nurses
• licensed Colorado physician assistants

Why PAs And NPs Are The Real Headline

The broad ownership list matters, but the biggest growth story is what this could mean for PAs and APRNs.

The brief specifically highlights that physician assistants could hold majority ownership under the proposed bill. It describes this as a notable departure from current law, where PAs could be shareholders only if physicians still held the majority interest. APRNs are also included in the proposed expanded shareholder group, which means they could benefit from the same ownership expansion if the bill moves forward.

For operators planning growth, that could reshape who leads, funds, and builds medical-aesthetics practices in Colorado.

This Is An Ownership Change, Not A Scope Change

This is where operators need to be careful.

HB 26-1249 would change who may own a medical-aesthetics corporation. It would not change what each licensed professional is allowed to do inside the practice. The Colorado summary is direct on that point: all practitioners would still be required to perform only procedures that fall within their licensed scope, and corporations formed under the bill would still have to operate in accordance with all professional conduct standards applicable to the licensees involved. Violations could still lead to disciplinary action against the responsible individuals.

That means majority ownership and clinical scope are two different questions. A more flexible ownership model would not erase the need for proper delegation, oversight, and procedure-specific compliance.

Colorado Already Changed Something Else In 2025

This ownership proposal is not happening in isolation. Colorado already has an active med spa law in effect.

HB 25-1024, effective around August 5, 2025, established mandatory disclosure rules for practices that use unlicensed individuals to perform delegated medical-aesthetic services. It requires all three of the following:

• on-site signage
• website and advertising disclosures
• patient informed consent before each delegated procedure performed by an unlicensed person

Just as important, HB 25-1024 does not expand, restrict, or alter existing delegation authority. It adds transparency requirements, not a new scope-of-practice framework.

What This Means For Med Spa Founders And Operators

If HB 26-1249 passes, Colorado could become a much more attractive market for PAs, APRNs, RNs, and other licensed professionals who want a larger ownership stake in a medical-aesthetics business. That could change how partnerships are structured, how practices are capitalized, and who takes the lead in building new med spa groups.

But this is not a simple “ownership is open now” story. Operators would still need to think through whether the business is truly organized solely for medical-aesthetic services, whether each owner’s role still fits their professional scope, whether physician collaboration or delegated oversight is still needed for the actual services offered, and whether the practice is already complying with Colorado’s current disclosure requirements for delegated services.

So the opportunity may expand, but the compliance structure still has to hold.

What Colorado Practices Should Do Now

The Colorado brief is practical about next steps.

If you are a PA, APRN, RN, esthetician, or other licensed professional interested in ownership, now is the time to monitor HB 26-1249 closely, review how your current structure would change if the bill passes, and avoid making ownership moves before the legislation is enacted. At the same time, med spas should continue complying with HB 25-1024, including signage, advertising disclosures, consent updates, seven-year document retention, and staff training around delegated services.

That makes this a two-track issue: prepare for the possible ownership expansion, but stay focused on the law already in effect.

Why Collaborating Physician Support Still Matters

Even if Colorado opens the door to broader ownership, that does not automatically remove the need for physician collaboration, supervision, or procedure-specific oversight inside the practice.

Ownership is one layer. Clinical operations are another.

That is where the proposed shift becomes practical. A PA- or APRN-led ownership group may still need the right physician relationship behind certain services, protocols, or delegated activities, depending on how the practice is structured and what it actually offers. The bill would expand ownership, but it would not remove professional standards or scope-based expectations.

The Bottom Line

Colorado HB 26-1249 could reshape med spa ownership by allowing a much broader group of licensed professionals, including PAs and APRNs, to hold majority ownership in a medical-aesthetics professional service corporation. But as of March 2026, the bill is still pending, and current Colorado requirements remain in effect.

The key takeaway is simple: Colorado may be moving toward a more flexible ownership model, but operators should not confuse ownership expansion with a free pass on oversight, scope, or current compliance. The practices that prepare for both sides of that equation will be in the strongest position if the bill moves forward.