Behavior Analyst Licensure in Minnesota: BCBA and State License Requirements

Minnesota issues a single credential: the licensed behavior analyst, defined as an individual who holds a valid licence under sections 148.9981 to 148.9995 to practise applied behavior analysis.

Both practice and title are restricted, and the penalty is criminal: a violation of the section is a misdemeanor.

Since January 1, 2025, you must not engage in the practice of applied behavior analysis without a licence or an exemption.

Separately, you must not use a title incorporating the words licensed behavior analyst or behavior analyst, or any description stating or implying that you are licensed or otherwise qualified, without holding the licence.

The psychologist carve-out is precise: a licensed psychologist practising applied behavior analysis within their scope may use the title behavior analyst, but may not use licensed behavior analyst unless they hold the behavior analyst licence.

A BCBA who moves to Minnesota is therefore certified, not licensed, until the Board of Psychology issues the licence.

Section 148.9983 sets no separate Minnesota degree or coursework requirement; it relies on the certifying entity's certification, or its equivalent.

An applicant files a written application on the board's forms with the fee specified under section 148.9995, and must submit evidence satisfactory to the board of either a current and active national certification as a board-certified behavior analyst issued by the certifying entity, or completed equivalent requirements for that certification.

The certifying entity is defined as the Behavior Analyst Certification Board, Inc., a successor organization, or another organization approved by the board in consultation with the advisory council.

Every applicant must also complete a background check under section 214.075.

The practical sequence for a new graduate: finish BACB certification first, then apply to the Board of Psychology, because route (1) requires evidence of a current and active BCBA certification.

The exam requirement lives inside the route, not in a Minnesota-run test.

On the certification route the applicant submits a current and active board-certified behavior analyst certification; no separate Minnesota examination appears in the sections read.

On the equivalent route the applicant must have completed the equivalent requirements for certification by the certifying entity, including satisfactorily passing a psychometrically valid examination administered by a nationally accredited credentialing organization.

Whether the board's administrative rules add a state jurisprudence or law exam is not stated in the sources read, because the rules were not among the documents read.

Check the Board of Psychology's application instructions before scheduling anything; the BCBA examination itself is the certifying entity's, and its length and content are covered in the how-to-become article rather than here.

Minnesota has no assistant licence and no technician registration; technicians fall under the supervisee exemption.

That exemption has real conditions.

An unlicensed supervisee or trainee may provide behavior analysis services only under the authority and direction of a licensed behavior analyst and in compliance with the licensure and supervision standards required by law or rule — so the exemption, and the work itself, ends if the supervision arrangement does.

Students and interns in an accredited school or educational program, or in a behavior analysis practicum, must be supervised by a licensed behavior analyst or an instructor of the accredited school or program and designated as a behavior analyst student or intern.

A family member or guardian of a recipient may perform behavior analysis services under a licensee's authority and direction.

A licensed psychologist may supervise an unlicensed supervisee, trainee, student or intern only if the supervision is authorized under the Minnesota Psychology Practice Act.

The statute does not mention RBT certification.

The statute defines the practice of applied behavior analysis as the design, implementation and evaluation of social, instructional and environmental modifications to produce socially significant improvements in human behavior, including functional behavioral assessment and analysis.

It also draws the outer line by exclusion, ruling out the diagnosis of psychiatric or mental health disorders, psychological testing, neuropsychology and the listed therapies (psychotherapy, cognitive therapy, sex therapy, hypnotherapy, psychoanalysis, psychological counseling).

The licence requirement then yields to exemptions that decide where you can work without the licence: psychologists and individuals providing psychological services under a licensed psychologist's supervision in accordance with section 148.925; any other profession or occupation the state licenses, certifies or registers, within its own scope of practice; school district employees within their district employment, on the conditions quoted below; employees of programs licensed under chapter 245D, for the services described in section 245D.091, subdivision 1; and teaching or research that does not involve direct delivery of behavior analysis services.

This is a new chapter.

Each of the four sections the sources read carries a single history credit — 2024 c 127 art 19 — with no later amendment noted, and the operative change is the date: the practice restriction took effect January 1, 2025 (the title restriction in subd.

2 carries no separate date in the text read).

The sections read do not describe what applied in Minnesota before that date, and they contain no grandfathering or transition provision, so a clinician who was already practising ABA in Minnesota in 2024 should confirm transition arrangements with the Board of Psychology rather than assume one.

Renewal periods, fee amounts under section 148.9995 and the advisory council's composition sit in sections that were not among the documents read, which leaves them open questions for the board.