Nail studio, lashes, permanent make-up: which licence do you need?
Three treatments, three completely different answers — and all of them sit in the same Trade Act. Anyone may register a nail studio. Eyelash extensions require the cosmetics qualification. And permanent make-up does not belong to cosmetics at all, but to tattooing.
The one dividing line: shaping or caring
What almost everything turns on is not the tool and not the place, but the nature of the intervention. Whoever shapes something that rests on the body is usually in free territory. Whoever cares for the body or intervenes in the skin needs a qualification — and the deeper the intervention, the more independent the licence becomes.
Nail studio: expressly free
Here the statute is unusually clear. § 162 Abs 1 GewO begins with the sentence „Kein reglementiertes Gewerbe und kein Teilgewerbe sind:“ — the following are neither a regulated trade nor a partial trade — and lists under Z 13, verbatim, the modelling of fingernails (Nagelstudio). Gel, acrylic, nail art: register a free trade, no exam, no proof.
The boundary runs to care. A manicure — treating the cuticle and the nail bed — is cosmetics under § 94 Z 42 GewO and therefore regulated. In practice the two activities sit side by side at the same table; in law they sit on opposite sides of the line.
Eyelashes: regulated cosmetics
Eyelash extensions, tinting and lifting fall under Kosmetik (Schönheitspflege), § 94 Z 42 GewO. Unlike the nail studio, the statute grants no exception for them.
That does not leave you facing a closed door. Under § 19 GewO an individual qualification restricted to partial activities can be applied for — for decorative cosmetics including eyelash treatments, for example. One point is regularly overlooked: unlike an ordinary trade registration, work may begin only once the determination has taken legal effect, not already upon registration.
Permanent make-up: not cosmetics at all
This is where most lists on the internet get it wrong. Permanent make-up is not an add-on module to cosmetics. § 109 Abs 5 GewO expressly equates it with tattooing:
„Tätowieren im Sinne des Abs. 3 ist das Einfügen von Farbstoffen in die menschliche Haut oder Schleimhaut zu dekorativen Zwecken. Zum Tätowieren zählt auch das Anbringen von Permanent-Make-Up.“
In English: tattooing is the insertion of dyes into human skin or mucous membrane for decorative purposes, and applying permanent make-up counts as tattooing. The extended qualification for tattooing therefore applies. Whoever offers PMU on a cosmetics licence is to that extent exercising a trade without the required licence — even if the cosmetics qualification itself is beyond reproach.
And if you do it anyway
Exercising a trade without the required licence is an administrative offence under § 366 Abs 1 Z 1 GewO. In practice the second consequence usually weighs more: the authority can prohibit the operation. A fine is paid once; a prohibition hits the business.
Frequently asked
Do I need a cosmetics qualification for a nail studio?
No. § 162 Abs 1 GewO opens with the sentence „Kein reglementiertes Gewerbe und kein Teilgewerbe sind:“ — the following are neither a regulated trade nor a partial trade — and names under Z 13 the modelling of fingernails (Nagelstudio). For gel, acrylic and nail art, registering a free trade is enough: no exam, no proof of qualification.
Where does the free nail studio end and cosmetics begin?
At care. Shaping the nail is free; as soon as the cuticle and the nail bed are treated — the classic manicure — it is Kosmetik (Schönheitspflege) under § 94 Z 42 GewO and therefore regulated. Shaping is free, caring is not.
May I offer eyelash extensions without a cosmetics qualification?
No. Eyelash extensions, tinting and lifting are regulated cosmetics under § 94 Z 42 GewO — unlike pure nail modelling. Whoever does not hold the full qualification can apply under § 19 GewO for an individual qualification restricted to partial activities. One point is regularly missed: unlike an ordinary trade registration, work may begin only once the determination has taken legal effect, not already upon registration.
Does the cosmetics qualification cover permanent make-up?
No. § 109 Abs 5 GewO expressly equates it with tattooing: „Zum Tätowieren zählt auch das Anbringen von Permanent-Make-Up.“ The extended qualification for tattooing therefore applies, and that is a matter of its own — not an add-on module to cosmetics.
What happens if I work without the necessary licence?
That is the exercise of a trade without the required licence. § 366 Abs 1 Z 1 GewO makes it an administrative offence. The authority can also prohibit the operation — in practice that hits harder than the fine itself.
I hold the full cosmetics qualification. Do I need anything extra for lashes?
No. Whoever holds the cosmetics qualification under § 94 Z 42 GewO covers eyelash treatments with it. The converse is a neighbouring right: the Trade Act names Kosmetik (Schönheitspflege) zum Modellieren von Fingernägeln (Nagelstudio) — so a cosmetician may also do nail modelling, even though you do not need one for it.
What this page does not cover
This page assigns activities to licences. It says nothing about hygiene requirements, about the operating-plant permit for the actual premises, or about which devices count as medical products in a given case — those are separate areas of law with separate authorities. Nor does it replace a ruling from the competent district administrative authority: in a borderline case the classification of a specific treatment can come out differently than a general account suggests.
Sources
- GewO 1994 — full text (RIS): § 94 Z 42 (cosmetics), § 109 Abs 5 (permanent make-up), § 162 Abs 1 Z 13 (nail studio), § 19 (individual qualification), § 366 Abs 1 Z 1 (penalty). Retrieved 6 September 2026.