Does Establishment Licensing Actually Work?
Nobody Knows. That’s the Problem. Help me change that.
Every few months, another state legislature debates adding establishment licensing for massage therapy businesses. Advocates say it’s a critical tool to fight human trafficking and shut down sexually oriented businesses disguised as massage. Critics say it burdens legitimate therapists without touching the criminals. Both sides argue loudly. Neither side has real data.
That’s not an opinion. That’s the gap this work is trying to close.
Today I’m releasing a resource I’ve been building for the Massage Therapy Nexus HUB: a state-by-state analysis of every establishment licensing law currently on the books in the United States. Twenty-three states. Five questions answered for each one and a clear-eyed look at what we actually know — and what we urgently need to find out. ( I did this all myself - yes with the help of AI but I am checking everything so let me know of any errors or misinformation.)
Why this matters
The only published academic research on this question — a peer-reviewed study comparing Texas and Oklahoma1 during the period when Texas implemented licensing — found no evidence that massage therapist licensing reduced crime rates. That study had real limitations, and the authors acknowledged them. But its core finding was damning: we passed these laws, we told the profession it would help, and we never measured whether it did.
The FSMTB’s establishment licensing toolkit argues these laws are valuable tools. The profession’s two largest associations, ABMP and AMTA, have pushed back, arguing that establishment licensing treats massage therapy differently from every other healthcare profession and puts the burden of a criminal problem on civil licensing2. They’re both right about something. They’re both missing data.
The argument that has never been settled — because nobody has done the work to settle it — is this:
Does establishment licensing actually reduce the presence and operation of sexually oriented businesses disguised as massage, or does it simply create a compliance burden for licensed therapists while bad actors adapt and reopen somewhere else?
The scoping document in my research files puts it plainly: “Legislative whack-a-mole. Traffickers adapt and more and tougher establishment licensing laws are not the answer.” That might be true. But it also might not be. We don’t know.
The full guide — all 23 states, all five questions, every verify flag and research gap — is available as a downloadable PDF through the link. This is the foundation document for the research that needs to happen next.
The survey. No one has asked licensed massage therapists in establishment licensing states how the law has affected their practices. I built one.
Take the survey today.
Now I need more help.
I am asking for help in submitting public records requests to state boards for establishment license counts, denial rates, and enforcement actions. I am asking for your help first - ask your state board for the information. I have the full instructions here.
Twenty-three states have some form of establishment licensing. Every single one of them passed that law without a benchmark, without a measurement plan, and without asking the people most affected — licensed massage therapists — whether it helped.
That’s not good enough. The profession deserves to know whether the laws being passed in its name are actually working. The victims in these businesses deserve better policy, not more paperwork. And the licensed therapists who carry the compliance burden every single day deserve someone asking whether it was worth it.
Here’s where I need your help.
I need people who are willing to help me request public records from state boards. Enforcement data, establishment license counts, denial rates — this information is public record. It just takes someone willing to submit the requests and wait for the responses. Sign up here to let me know you are working on your state.
Download the form letter to request public records. https://docs.google.com/document/d/1vEAdFykthdY9r6VJcqMNzz4OR_btf_OFtLC6OC_ihdU/edit?usp=sharing
I need LMTs in states that are currently debating establishment licensing to let me know what’s happening in your legislature. These debates are happening right now, with the same recycled arguments on both sides and no new data. We can change that.
For 128 years this profession has been fighting to separate itself from businesses that have nothing to do with massage therapy. We’ve tried associations, certifications, individual licensing, and now establishment licensing. Each tool has been adopted with confidence and evaluated with almost no rigor.
It’s time to actually look.
If you’re in state with establishment licensing, sign up to investigate your state! Let’s find out together what’s working, what isn’t, and what we should be asking for instead.
— Julie Onofrio, LMT
www.lookbeforeyoubookamassage.com
www.massagetherapynexus.com
Tired of waiting for our associations to do something. I am not even sure if this will work or provide us with the information we need to help create better laws. I won’t be stopping until we figure it out!
Deyo, Darwyyn; Hoarty, Blake; Norris, Conor; and Timmons, Edward. “Licensing Massage Therapists in the Name of Crime: The Case of Harper v Lindsay.” Journal of Entrepreneurship and Public Policy, Vol. 10, No. 1. Published by Emerald Publishing.


