08/14/2025
Good morning!
I know some of you may have heard about this "new" rule regarding establishment licenses. (The quotes are around "new" because it's actually been this way for a while, but 50% of LMTs and law instructors—myself included—had an incorrect interpretation of it, so the Board just wanted to make sure we were all clear on it.) The Board is giving us a grace period until the end of the year to get this corrected if needed.
I hope this email provides some clarification, but as always, if you have questions, don't hesitate to reach out.
What Does This Mean?
In the simplest terms: If you are working out of a business with an establishment license but you are working as your OWN business, you will need to obtain a separate establishment license.
Important: How you are classified tax-wise DOES NOT MATTER for this. W-2, 1099, etc. has nothing to do with this requirement.
Here's the key distinction:
If you are working for the business and receive a tax form from them (1099/W-2), you are working on their behalf and do NOT need a separate establishment license.
If you are subleasing a room from someone else, seeing your own clients, running your own books, etc., then you WILL need your own establishment license.
Examples
Example 1: You work at a business that has an establishment license. The business books the clients, takes payment, and pays you for the massage. You do NOT need an establishment license because you are working FOR that business. (It doesn't matter if you work there four days a week and receive a paycheck every Friday, or if your friend who runs a spa contacts you in a panic to fill in for a therapist who called out and hands you cash on your way out the door—you are working on behalf of another business that has its own establishment license.)
Example 2: You have a friend who has their own room, but they want to sublease it to you for two days a week so you can see your own clients, hand out your own business cards that direct clients to your own website, use your own booking software, etc. In this case, you WILL need to get your own establishment license because you are a separate business from the person who is subleasing to you.
Example 2 is actually the scenario I'm in, so even I will have to obtain an establishment license due to this clarification. Honestly, I'm not upset about it—I'm actually very grateful that the Board is giving us a grace period to correct what has been misinterpreted (and taught by far better teachers than myself!) for quite a few years.
Action Required
If you need it, make sure you get your establishment license by December 31, 2025. If you get it after that date, you will face fines for running an unlicensed establishment.
If you have any questions, please email me. I am fully booked through Tuesday, August 19th, but will be checking email randomly.
Also, if needed, I have scheduled a law class for the evening of August 29th, and I'll definitely be clarifying this again there: https://www.ticketleap.events/events/mandi
Note: If you are an LMT, you do NOT need to take a separate law class to obtain your establishment license. LMTs are exempt from that requirement because we have to take the law class every two years for our massage license.
Have a wonderful day!
Mandi Parker, LMT & soon-to-be establishment license holder
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