On April 20, 2026, the Virginia Board of Dentistry published final regulations in the Virginia Register that permanently change how cosmetic Botox and injectable procedures can be performed by dentists and oral surgeons in the state — including in med spa settings.
The rule takes effect May 20, 2026. If your practice employs or contracts with dentists or oral surgeons who perform injectables, this applies to you. Here is exactly what changed, what it requires, and what you need to do before the deadline.
What Just Changed
"Regulators aren't just asking who is injecting. They're asking what training you can prove."
What Dentists Must Now Have to Administer Cosmetic Botox
Under the new regulation (18VAC60-21-55), dentists who want to administer botulinum toxin for cosmetic purposes must complete documented training that meets all of the following requirements:
12 Total Training Hours
A minimum of 12 hours of training is required before a dentist may administer cosmetic Botox. Online-only certification does not meet this standard.
Minimum 4 Hours In-Person Clinical Training
At least 4 of the 12 hours must be hands-on, in-person clinical training. The remaining hours may be didactic (online or in-person).
Minimum 2 Live Patients
Clinical training must be performed on a minimum of 2 live patients. Simulation or mannequin-only training does not satisfy this requirement.
Accredited Program Required
Training must come from a program accredited by CODA, the ADA or its constituent/branch associations, or the Academy of General Dentistry. Unaccredited weekend courses do not qualify.
Important: This finalizes rules that have been operating under an emergency regulation since May 2024. If your dentist completed training under the emergency rule, verify their documentation still meets the permanent standard — particularly the accreditation requirement.
What Oral and Maxillofacial Surgeons Can and Cannot Do
Under amended section 18VAC60-21-350, oral and maxillofacial surgeons may apply for cosmetic procedure certification from the Virginia Board of Dentistry. With that certification, they may perform a defined set of cosmetic procedures — but with a strict geographic limitation.
Certified oral surgeons may perform:
- Dermal fillers and cosmetic injectables
- Laser resurfacing and dermabrasion
- Eyelid surgery and browlifts
- Rhinoplasty
- Submental liposuction
- Ear and chin/neck corrections
Hard limit: All cosmetic procedures performed by oral surgeons are restricted to above the clavicle — within the head and neck region only. Full-body cosmetic work, including injectables below the clavicle, is outside their authorized scope under this rule.
Not Sure If Your Practice Is Compliant?
We help med spa owners understand what regulatory changes mean for their marketing, positioning, and patient communication — and how to stay ahead of the curve.
Talk to Our TeamYour Med Spa Compliance Checklist
If your practice employs or contracts with any dentist or oral surgeon performing injectables or cosmetic procedures, complete these steps before May 20, 2026:
Audit Every Injector's Training Documentation
Pull training certificates for all dentists administering Botox. Verify total hours, clinical hours, number of live patients trained on, and the accreditation status of the training program.
Confirm Accreditation of Training Programs
The training provider must be accredited by CODA, the ADA or its constituent organizations, or the Academy of General Dentistry. Check the program directly if unsure.
Review Oral Surgeon Scope
If your practice has oral surgeons performing cosmetic procedures, confirm every service they offer is within the head and neck region only. Document this review.
Document Competency and Supervision Structures
Regulators are increasingly focused on what you can prove, not just what you claim. Ensure competency documentation and supervision agreements are current and on file.
Consult Healthcare Counsel If Needed
If your practice has complex provider arrangements or is unsure about any aspect of compliance, consult a healthcare attorney before the May 20 effective date.
What This Regulation Signals for the Industry
Virginia's new rules are part of a clear national pattern: regulators are tightening scope of practice definitions and demanding documented, verifiable training — not just claimed experience or job title.
Three things this regulation makes explicit:
- Scope is tied to credentials, not job title. Being a dentist or oral surgeon is not enough — specific training for specific procedures is now required.
- Training must be provable. Documentation, accreditation, and clinical hours are now the standard of proof. Informal training doesn't count.
- Experience alone isn't sufficient. Years of practice do not substitute for the required formal training pathway under this rule.
Med spa owners who stay ahead of these changes — and can communicate their practice's compliance clearly to patients — will be better positioned than those who are caught off guard.
Source: Virginia Register of Regulations, Volume 42, Issue 18, April 20, 2026. Regulatory citation: 18VAC60-21 (Virginia Board of Dentistry Regulations Governing the Practice of Dentistry). VA.R. Doc. No. R24-7739. Filed March 31, 2026. Effective May 20, 2026.