May an esthetician or laser technician perform microneedling in New York?
Oversight · part of The Practice Perimeter
Short answer
The cited rules do not settle this — New York's classification table grades energy devices by depth (Class I surface-level is open to trained non-licensees; Class IIIb and IV are the practice of medicine) and says nothing about needle-based microneedling.
Microneedling/Dermalrolling (Collagen Induction Therapy) Cosmetic procedure that involves repeatedly puncturing the skin with tiny, sterile needles to induce collagen and elastin production; penetrates into the deep dermis.
NY Dept. of State, Appearance Enhancement Licensees — Procedural Service Determinations (Procedure Licensure Chart), row “Microneedling/Dermalrolling”, column “NYS Education Dept. License” · verified Sep 3, 2026 · regulatory monitoring, not legal advice
Related New York rules
The Board grades energy devices by how deep they act and who may therefore operate them. Class I (surface only — e.g. handheld LED) is not the practice of medicine and may be performed by trained non-licensed professionals such as aestheticians. Class II (non-ablative devices including IPL and non-ablative hair-removal lasers) and Class IIIa (low-risk devices such as low-level laser therapy) are also not the practice of medicine, but require trained non-licensed personnel to work under supervision. Class IIIb (medium-powered, upper dermis — e.g. Thermage) and Class IV (high-powered, dermis and deeper — e.g. CO2 resurfacing, deep RF, laser lipolysis) ARE the practice of medicine; Class IIIb requires licensed medical professionals or supervised personnel, and Class IV is restricted to licensed medical professionals exclusively.
N.Y. State Board for Medicine — Use of Energy Devices Including Lasers as the Practice of Medicine (Mar. 7, 2025), Energy Device Classification Table · verified Aug 17, 2026
New York defines the practice of medicine as diagnosing, treating, operating or prescribing for any human disease, pain, injury, deformity or physical condition. Administering a prescription drug such as a neuromodulator or dermal filler, and prescribing it, fall inside that definition.
N.Y. Educ. Law §6521 · verified Aug 17, 2026
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