Mandatory Signage: The Disclosure Checklist

Colorado is no longer treating disclosure as a small compliance detail. Under HB 25-1024, med spas and aesthetic practices that use unlicensed individuals to perform delegated medical-aesthetic services must now follow a specific disclosure framework that is already in effect for 2026 operations.

This matters because the law is not just asking clinics to explain things verbally. It requires visible, written, and repeated disclosures across the patient journey. If your practice uses unlicensed aestheticians, medical assistants, laser technicians, or other non-licensed personnel under delegation, your signage and patient-facing materials now carry real compliance weight.

Start With The Most Important Clarification

HB 25-1024 is not a new delegation law. It does not change who may perform which procedures, and it does not create new licensing categories for unlicensed staff. Colorado's existing delegation authority remains in place. What this law does is add mandatory transparency requirements so patients and the public know when delegated services are being performed by unlicensed individuals.

That distinction matters. The law is about disclosure, not expanding scope.

Who Is Actually Affected

The law applies to any Colorado healthcare licensee who delegates medical-aesthetic services to an unlicensed person. That includes physicians, nurse practitioners, physician assistants, registered nurses, and other licensed professionals who use aestheticians, laser technicians, medical assistants, or other non-licensed personnel to perform delegated services.

In practical terms, this means many med spas, dermatology offices, and plastic surgery practices may be affected if they rely on unlicensed staff for delegated aesthetic procedures.

The Three Required Disclosure Methods

Colorado's law requires three separate disclosure methods, and all three are mandatory. This is what makes the law operationally important. A clinic cannot comply by posting a sign and ignoring the website, or by updating consent forms and forgetting the treatment area. The system only works if all three parts are in place.

1. On-Site Signage

The first requirement is the one most operators will notice right away: on-site signage.

A sign must be posted at the location where services are provided, and it must be prominently displayed. The law says the sign cannot be hidden or buried in small print. It needs to state clearly that certain medical-aesthetic services are performed by unlicensed individuals under delegation from a licensed practitioner. It also must include:

• the name of the delegating practitioner
• the license number of the delegating practitioner
• the web address of the relevant regulatory board for complaints

This is where the disclosure requirement becomes very concrete. Colorado is not asking for a vague statement about oversight. It wants the delegating practitioner identified directly.

2. Website And Advertising Disclosures

The second requirement moves beyond the treatment room. Colorado requires the business's website to include a clear statement that some services are performed by unlicensed personnel under delegation. The same disclosure must also appear in advertising materials, including social media, print, digital promotions, and in-office marketing. The law says these disclosures must be clear and conspicuous, not buried in footnotes or fine print.

That means the compliance issue is not limited to signage at the front desk. If the practice markets delegated services publicly, the disclosure needs to follow the marketing too.

3. Patient Informed Consent

The third requirement is patient-specific. Before each procedure performed by an unlicensed individual under delegation, the patient must receive and sign an informed consent document. That consent must explicitly explain that the patient is receiving medical-aesthetic services that have been delegated from a licensed person to an unlicensed person. It must also include the same core information required on the office sign:

• the delegating practitioner's name
• the delegating practitioner's license number
• the regulatory board contact information

Signed consent forms must then be retained in the patient's records for at least seven years.

The Disclosure Checklist

If a Colorado med spa uses unlicensed personnel for delegated services, the compliance checklist is straightforward:

• post the required sign at each location where delegated services are performed
• make sure the sign includes the delegating practitioner's name, license number, and the proper board complaint website
• update the website with the required disclosure
• update all advertising materials, including social media and in-office promotions
• revise informed consent forms for delegated services
• retain signed consent forms for seven years
• train front-desk and clinical staff on the new requirements

This is the real operational side of the law. It is not enough to know the rule exists. The disclosure framework has to be built into daily workflow.

Why The Posted Director Information Matters

This is where the law becomes more than signage. Because the on-site sign must include the name and license number of the delegating practitioner, Colorado is effectively turning the responsible clinical authority into part of the public-facing compliance structure. That means the person attached to delegated services is no longer invisible. Patients can see who holds the license behind the care model, and they can see where to direct complaints if something goes wrong.

For clinics, that changes the importance of who is attached to the role. A named, credible physician with real authority does more than satisfy paperwork. It strengthens trust, clarity, and the overall professionalism of the practice.

What Colorado Practices Should Do Now

Colorado's brief is direct about immediate action. Clinics should already be posting the required sign in treatment areas, updating websites and advertising, revising consent forms, training staff, and reviewing social media and promotional materials for compliance.

That is especially important because signage failures are often the easiest compliance issue for regulators, competitors, or patients to notice. A clinic may think of signage as minor, but the state is treating it as one of the clearest markers of whether the practice is being transparent about delegated services.

Why This Matters For Credibility

The hook in this law is not just that a name has to be posted. It is that the posted name represents the clinical authority behind the delegated care model.

Colorado now requires the delegating practitioner's information to be visible on-site. For clinics trying to build trust, that makes the quality and credibility of the physician relationship more important. A stronger physician presence does not just help internally. It also becomes part of how the clinic presents itself to patients.

That is why this is more than a signage rule. It is a transparency rule tied directly to who stands behind the delegated care structure.

The Bottom Line

Colorado HB 25-1024 is already in effect, and it requires med spas using unlicensed staff for delegated medical-aesthetic services to comply with three mandatory disclosure methods: on-site signage, website and advertising disclosures, and patient informed consent. The on-site sign must include the delegating practitioner's name and license number, along with the relevant regulatory board complaint website.

The simplest takeaway is this: if delegated services are happening in your clinic, the disclosure system needs to be visible, consistent, and built into every stage of the patient experience.