There is no standalone “Botox license” in Texas. You inject under an existing clinical license, and the injection itself is a delegated medical act that a physician must authorize in writing.
Written by Kiara DeWitt, BSN, RN, CPN, Advanced Clinical Nurse Injector. Medically reviewed by Dr. Josh Allen, D.O., Medical Director. Last updated August 2026.
Key Takeaways
You need an active clinical license that permits delegated medical acts: MD or DO, PA, APRN, RN, and in some cases, a dentist. Texas does not issue a cosmetic injector license. The Texas Medical Board classifies non-surgical medical cosmetic procedures, including injecting substances for cosmetic purposes, as the practice of medicine.
If injecting is the practice of medicine, then a non-physician injects only because a physician delegated the act. No delegation means no legal basis, regardless of how many certificates are framed on the wall.
Since Botox injections fall under medical practice acts in all 50 states, only licensed healthcare professionals with the appropriate training and delegated authority can legally perform this treatment. The following practitioners are qualified to administer Botox in Texas:
| Credential | Can inject? | Supervision required | Texas citation |
| Physician (MD, DO) | Yes, within own scope | Not applicable | Tex. Occ. Code ch. 157 |
| Physician assistant (PA) | Yes, as a delegated act | Yes, physician delegation and written order | Tex. Occ. Code ch. 157; see the 169.25(b) carve-out |
| APRN or NP | Yes, as a delegated act | Yes, physician delegation and written order | Tex. Occ. Code ch. 157; see the 169.25(b) carve-out |
| Registered nurse (RN) | Yes, as a delegated act | Yes, written order plus a signed protocol | 22 TAC 169.25, 169.27 |
| Licensed vocational nurse (LVN) | Contested. Treat as unsettled | Yes, and get counsel first | 169.25 defines the act, not who may receive delegation; LVN scope is set by the Texas Board of Nursing |
| Dentist (DDS, DMD) | Contested for purely cosmetic facial use | Varies | Texas State Board of Dental Examiners |
| Esthetician, cosmetologist, medical assistant | No | Not applicable | Injecting is the practice of medicine, 169.25 |
For registered nurses, your delegating physician authorizes the act. The Texas Board of Nursing still holds you to your own standards of practice, and you are expected to decline an act you are not competent to perform. A physician’s order does not transfer your judgment to the physician.
Our licensed nurse injector training covers the delegation paperwork and the written order, not just the needle.
On January 9, 2025, the Texas Medical Board repealed 22 TAC 193.17, and replaced it with a new subchapter: 169.25, 169.26, 169.27 and 169.28.
Four practical requirements came out of the new rules:
Two 2025 bills are often described inaccurately. Senate Bill 378, captioned “relating to certain prohibited practices by a barber or cosmetologist,” passed both chambers and was vetoed by the Governor on June 2, 2025, so it is not law. Several training sites still describe it as pending. House Bill 3749, captioned “relating to the regulation of the provision of elective intravenous therapy,” took effect September 1, 2025, but it governs elective IV therapy, not neuromodulator injections.
Where the sources genuinely disagree, get an opinion from a healthcare attorney licensed in your state and keep it on file.
A certificate is not a license and no course grants you scope. What good training does is make you competent enough that a physician will delegate to you and an insurer will cover you.
At InjectCo, our hands-on injector training course is mentorship that prepares and evaluates aspiring injectors on their understanding of facial anatomy in practice rather than on a diagram, their dose reasoning for injectables, and their preparedness for when something goes sideways.
An advanced clinical nurse injector will be closely observing the student. This workshop allows the opportunity to inject real Botox and dermal fillers on actual live patients.
The curriculum also involves photography authorization, adverse event documentation, and the written order that makes the whole arrangement lawful.
Every injector across our nine Texas locations trained through this pathway.
The pathway we run has three stages, and we are candid about who each one suits.
We also run a nurse injector internship for nurses who want repetition under supervision rather than a weekend certificate.
Nurses coming out of ICU, ER, pediatrics and derm tend to adapt quickly. The assessment skills are already there. A career as an injector fits well for professionals who:
It does not fit if you are looking for a quick exit from clinical work, as medical aesthetics is still clinical. You are still assessing, documenting, and managing complications, and now you are also managing patients’ expectations for a certain outcome.
Rules also vary by state. Confirm with your state medical board first before you rely on any information.
The questions below reflect the Texas rules in force since January 9, 2025. Rules vary by state and change without notice, so confirm current requirements with your own boards before you rely on any of it.
An active clinical license that allows delegated medical acts: MD, DO, PA, APRN, or RN. Texas issues no separate injector license. You also need a delegating physician and a written order naming you.
Yes, when a physician has delegated the act under a written order and you have signed and dated a protocol. See 22 TAC 169.25, 169.26(a), and 169.27. Your Texas Board of Nursing duties still apply on top of that.
You need a delegating physician, which in most med spa arrangements is the medical director. That physician must review or write the order, confirm your training, and be on-site or immediately available during treatment. See 22 TAC 169.26 and 169.27.
No. Under 22 TAC 169.25 the injection of substances for cosmetic purposes is the practice of medicine, so it can only be performed by a licensed practitioner acting under valid physician delegation. Estheticians, cosmetologists, and medical assistants are not eligible.
Considerably. Some states allow RN injection with remote supervision, some require the physician on-site, and a few restrict injection to advanced practice roles. Verify with the medical and nursing boards in your state.
No certification is legally required in Texas. In practice a delegating physician will want documented training in anatomy, dosing, and complication management before signing, and 22 TAC 169.26(a)(1) places that verification duty on them.
Hold or earn a qualifying license, complete hands-on training with supervised patient hours, secure a delegating physician, sign a protocol, and confirm your workplace meets the posting and identification requirements in 22 TAC 169.28.
Yes, effective January 9, 2025. It was replaced by 22 TAC 169.25 through 169.28. Any page citing 193.17 as current is out of date.
Your license is your way in, the physician written order is what makes the act lawful, and training is what makes you worth delegating to.
Medical Disclaimer
This article is professional education, not legal advice. Scope of practice, delegation, and supervision rules vary by state and change without notice. Confirm current requirements with your state medical board and nursing board, and consult a healthcare attorney licensed in your state before relying on any statement here.
Dr. Allen earned his Doctor of Osteopathic Medicine at Lake Erie College of Osteopathic Medicine and completed his emergency medicine residency with Texas A&M. As Medical Director, he reviews InjectCo’s treatments, protocols, and patient education content for accuracy and safety across all nine Texas locations.
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