Cosmetology License Defense
Representation Before the State Board of Cosmetology
The State Board of Cosmetology licenses cosmetologists, estheticians, nail technicians, teachers, salons and schools in the Commonwealth. Bureau inspectors examine salons and schools, and inspection findings are a frequent source of Board matters.
Many matters begin with a citation for a sanitation finding, an expired license or the employment of an unlicensed person. Although a citation may appear minor, payment is an admission that becomes part of the licensee's record, and repeated findings may lead to formal charges against the salon and the individuals working there.
Mimm Law, LLC represents individual licensees, salon owners and schools at every stage of a Board matter, from a citation or inspection through final order.
Governing Law
- Board
- State Board of Cosmetology
- Statute
- Cosmetology Law, 63 P.S. §§ 507-527
- Regulations
- 49 Pa. Code Chapter 7
- Licensees
- Individual licensees, salons and schools
- Renewal
- Biennial; licenses expire January 31
Who the Board Regulates
- Cosmetologist, esthetician and nail technician licenses
- Cosmetology teacher and limited practice teacher licenses
- Cosmetology, esthetics and nail technology salon licenses
- Cosmetology school license
- Multistate privileges under the Cosmetology Licensure Compact (2026 Act 43), once the compact takes effect
- Apprentice registration and temporary license
Grounds for Discipline
Section 13 of the Cosmetology Law authorizes the Board, after a hearing, to refuse, revoke, refuse to renew or suspend a license for:
- Violation of any provision of the Cosmetology Law
- Violation of the Board's rules and regulations
- Gross incompetency
- Dishonest or unethical practices
- Failure to permit an inspection of the licensee's salon during business hours
- A guilty or nolo contendere plea to, or conviction of, a felony under The Controlled Substance, Drug, Device and Cosmetic Act or a similar state or federal law (49 Pa. Code § 7.98, applying section 13)
Sanctions the Board May Impose
The Board may refuse, revoke, refuse to renew or suspend a license, and the Law authorizes civil penalties. An individual license that has been expired or in escrow for five years requires re-examination before it can be renewed. A licensee whose license is revoked ordinarily may not reapply for five years. Citations issued under the schedule of civil penalties must be paid or contested within the time stated on the citation.
In addition to the sanctions in the Board's own statute, Chapter 31 of Title 63 of the Pennsylvania Consolidated Statutes authorizes each licensing board to impose a civil penalty of up to $10,000 per violation and to assess the costs of investigation against a licensee found to have violated the law.
Obligations That Often Lead to Board Matters
Salon Inspections
A salon must be inspected before it is first licensed and again when it relocates, and Board inspectors may inspect during business hours. A refusal to permit an inspection is itself a ground for discipline.
Licensed Staff
Every person who provides cosmetology services must hold a current license. Employing an unlicensed person exposes the salon owner to penalties and the salon license to discipline.
Apprentices and Students
Apprentices must be trained by a licensed teacher in a salon that meets the staffing ratios in the Law, and a school may permit students to serve the public only after the client has been informed the operator is a student.
Matters We Handle
- Citations and civil penalties following an inspection
- Sanitation and safety findings
- Practice on an expired license or employment of unlicensed staff
- Customer complaints concerning services
- Criminal charges and convictions affecting licensure
- Applications and reinstatement following a lapse
- Booth rental arrangements
- Practicing outside a licensed salon
How We Can Help
Board Investigations
Upon receipt of a letter of inquiry, a subpoena or contact from an investigator, the firm evaluates the allegations, reviews the licensee's records, prepares a written response and attends any investigative interview. In some matters, an early, well-documented response may resolve the matter before formal charges are filed.
Formal Charges and Hearings
When the Commonwealth files an Order to Show Cause, the time to respond is short, and a respondent who misses the deadline may be held in default and the facts alleged deemed admitted. The firm prepares and files the answer, negotiates a consent agreement where one serves the client's interests, and tries the matter before the hearing examiner or the Board where it does not.
Applications and Reinstatement
For applicants whose history may raise questions, and for licensees seeking reinstatement after suspension, revocation or lapse, the firm assembles the application and supporting record and presents the matter to the Board.
Questions Licensees Ask
I received a citation after an inspection. Should I pay it?
Payment resolves the citation but is treated as an admission of the violation. A licensee who disputes the findings, or who has prior citations, should consider contesting it. The regulations allow 10 days from the date the citation is issued to respond, and a failure to respond results in a default judgment for the full amount of the penalty and may lead to further discipline.
Is the salon responsible for an employee's expired license?
Yes. The salon owner and the designated person in charge are responsible for the salon's compliance, including ensuring that every person providing services holds a current license. An expired license may lead to citations against both the individual and the salon.
Does a customer complaint about a service lead to discipline?
A complaint about an unsatisfactory result is not by itself a violation. The Board's concern is incompetence, unsafe or unsanitary practice and dishonesty. A prompt, documented response, including records of the service provided, is usually the best course.
Should I speak with an investigator before I have counsel?
A licensee who receives a letter of inquiry, a subpoena or a telephone call from an investigator with the Bureau of Enforcement and Investigation should be courteous and should note the investigator's name and contact information, but should not give a substantive statement before obtaining advice. Anything said to an investigator may be included in the report reviewed by the prosecuting attorney and, later, by the Board. Counsel can determine what is being alleged, gather the relevant records and prepare a response that is accurate, complete and appropriately limited.
Must I report a criminal conviction, plea or ARD, or discipline in another state?
Yes. Pennsylvania law requires every licensee to notify the licensing board in writing within 30 days of discipline imposed by a licensing authority in another jurisdiction and of a finding of guilt, guilty plea, plea of nolo contendere, probation without verdict, disposition in lieu of trial or Accelerated Rehabilitative Disposition on a felony or misdemeanor charge. Some boards' regulations impose additional or earlier reporting duties, including, for nurses and massage therapists, a duty to report the filing of criminal charges within 30 days. A failure to report is itself a ground for discipline, and it is frequently charged alongside the underlying conduct.
Meet Your Attorney
Steven A. Mimm, Esq.
Founder, Mimm Law, LLC. Admitted in Pennsylvania (2008) and New Jersey (2022).
From 2014 to 2022, Attorney Steven A. Mimm served as a prosecuting attorney bringing disciplinary actions on behalf of the Bureau of Professional and Occupational Affairs before Pennsylvania's licensing boards. That experience informs how the firm evaluates evidence, negotiates with the Commonwealth and prepares cases for hearing. Where a licensee also faces criminal charges, the firm handles the licensing matter and coordinates with the licensee's criminal defense counsel.
Related: All Licensing Boards · Licensing and FAQs
Last reviewed September 2026. The information on this page is general in nature and is not legal advice. Contacting the firm does not create an attorney-client relationship.