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Illinois ownership & cpom for med spas

Corporate-practice-of-medicine limits on who may own an aesthetic practice. Below are the Illinois rules that govern it, each linked to its primary source. Monitoring and reference, not legal advice.

Ownership & corporate practice of medicine in Illinois

Illinois is among the strictest corporate-practice states, and its regulators say so in a document written for med spas specifically: a med spa is a medical practice, so it must be owned by physicians — or, for the services within their scope, by APRNs. There is no room for a non-clinical shareholder in the entity that delivers care.

  • IDFPR and IDPH state that because the services a med spa provides are medical services, the Medical Practice Act and the Nurse Practice Act require med spas to be owned and operated by physicians — and, for some services, by advanced practice registered nurses. A med spa that is not organized as a corporate entity, such as a sole proprietorship or partnership, must still be owned and operated by a physician or an APRN.

    IDFPR/IDPH Medical Spa Services memo (updated 2025-10-30) · verified Aug 17, 2026

  • Only physicians may organize under the Medical Corporation Act. Physicians may instead use the Professional Service Corporation Act or the Professional Limited Liability Company Act; APRNs may use only those latter two. A physician entity may have only physicians as shareholders or members, officers, directors or managers, and an APRN entity only APRNs.

    805 ILCS 15/ · 805 ILCS 10/ · 805 ILCS 185/ (as stated in the IDFPR/IDPH med spa memo) · verified Aug 17, 2026

  • A person who is not a physician or an APRN cannot be a shareholder or member, an officer, a director or a manager of a med spa entity. That closes the door on an outside investor taking equity in the entity that delivers the care, whatever their commercial role.

    IDFPR/IDPH Medical Spa Services memo (updated 2025-10-30) · verified Aug 17, 2026

  • Professional entities are limited to one type of professional service plus certain related services, and none of the related services listed would let the same entity practice both medicine and cosmetology or esthetics. An entity organized under the Medical Corporation Act may provide medical services only.

    805 ILCS 185/13 · 805 ILCS 10/3.6 (as stated in the IDFPR/IDPH med spa memo) · verified Aug 17, 2026

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