ABA licensure in Minnesota: who needs a license, how to get one and how to keep it
The short answer
Since January 1, 2025, Minnesota law says an individual must not practice applied behavior analysis unless licensed as a behavior analyst by the Minnesota Board of Psychology or exempt under the statute. The license title is "licensed behavior analyst," and a person with a current and active Board Certified Behavior Analyst (BCBA) certification from the Behavior Analyst Certification Board (BACB) can apply. Minnesota's statute licenses behavior analysts; we found no license in it for assistant behavior analysts or technicians. Confirm with the Minnesota Board of Psychology before you rely on this.
What the law says
Minnesota's behavior analyst law is Minnesota Statutes sections 148.9981 to 148.9995, enacted in 2024 (2024 c 127, art. 19). The Board of Psychology carries it out, with a Behavior Analyst Advisory Council.
Who must be licensed.
"Effective January 1, 2025, an individual must not engage in the practice of applied behavior analysis unless the individual is licensed under sections 148.9981 to 148.9995 as a behavior analyst or is exempt under section 148.9987. A psychologist licensed under sections 148.88 to 148.981 who practices behavior analysis is not required to obtain a license as a behavior analyst under sections 148.9981 to 148.9995." (Minn. Stat. 148.9986, subd. 1)
Title.
"An individual must not use a title incorporating the words "licensed behavior analyst," or "behavior analyst," or use any other title or description stating or implying that they are licensed or otherwise qualified to practice applied behavior analysis, unless that person holds a valid license under sections 148.9981 to 148.9995." (Minn. Stat. 148.9986, subd. 2(a))
A licensed psychologist who practices applied behavior analysis within the psychologist's scope of practice may use the title "behavior analyst" but not "licensed behavior analyst" without a behavior analyst license. (subd. 2(b)) The statute makes a violation of this section a misdemeanor. (subd. 3)
What counts as practice.
"'Practice of applied behavior analysis' means the design, implementation, and evaluation of social, instructional, and environmental modifications to produce socially significant improvements in human behavior." (Minn. Stat. 148.9981, subd. 9(a))
The definition includes functional behavioral assessment and analysis. It "does not include the diagnosis of psychiatric or mental health disorders, psychological testing, neuropsychology, psychotherapy, cognitive therapy, sex therapy, hypnotherapy, psychoanalysis, or psychological counseling." (subd. 9(b))
Exemptions. Section 148.9987 says the license law "must not be construed to prohibit or restrict":
"(1) the practice of an individual who is licensed to practice psychology in the state or an individual who is providing psychological services under the supervision of a licensed psychologist in accordance with section 148.925;
(2) the practice of any other profession or occupation licensed, certified, or registered by the state by an individual duly licensed, certified, or registered to practice the profession or occupation or to perform any act that falls within the scope of practice of the profession or occupation;
(3) an individual who is employed by a school district from providing behavior analysis services as part of the individual's employment with the school district, so long as the individual does not provide behavior analysis services to any person or entity other than as an employee of the school district or accept remuneration for the provision of behavior analysis services outside of the individual's employment with the school district;
(4) an employee of a program licensed under chapter 245D from providing the services described in section 245D.091, subdivision 1;
(5) teaching behavior analysis or conducting behavior analysis research if the teaching or research does not involve the direct delivery of behavior analysis services;
(6) providing behavior analysis services by an unlicensed supervisee or trainee under the authority and direction of a licensed behavior analyst and in compliance with the licensure and supervision standards required by law or rule;
(7) a family member or guardian of the recipient of behavior analysis services from performing behavior analysis services under the authority and direction of a licensed behavior analyst; or
(8) students or interns enrolled in an accredited school or educational program, or participating in a behavior analysis practicum, from engaging in the practice of applied behavior analysis while supervised by a licensed behavior analyst or instructor of an accredited school or educational program. These individuals must be designated as a behavior analyst student or intern." (Minn. Stat. 148.9987(a))
The Board. "The board, in consultation with the advisory council, must ... adopt and enforce standards for licensure, licensure renewal, and the regulation of behavior analysts" and "issue licenses to qualified individuals." (Minn. Stat. 148.9982, subd. 1) The statute defines "Board" as "the Board of Psychology established in section 148.90." (148.9981, subd. 4)
Source: Minn. Stat. 148.9981, 148.9982, 148.9986, 148.9987 (Office of the Revisor of Statutes).
How to get licensed
An applicant must submit a written application on the Board's forms with the fee and evidence satisfactory to the Board that the applicant:
"(1) has a current and active national certification as a board-certified behavior analyst issued by the certifying entity; or
(2) has completed the equivalent requirements for certification by the certifying entity, including satisfactorily passing a psychometrically valid examination administered by a nationally accredited credentialing organization." (Minn. Stat. 148.9983, subd. 2)
The "certifying entity" is "the Behavior Analyst Certification Board, Inc., or a successor organization or other organization approved by the board in consultation with the advisory council." (148.9981, subd. 5) The applicant "must complete a background check pursuant to section 214.075." (148.9983, subd. 3)
The Board's own checklist for an initial behavior analyst application says the applicant submits an online application and the non-refundable fees, "Provides evidence of active national certification (BCBA or BCBA-D credential number)" (the Board gets primary-source verification from the BACB), completes the background check, and supplies license verification from any state in which the applicant is or was licensed or credentialed, to show no pending discipline. Board staff review the file, and "Ethical concerns may cause application to be referred for further Board review." The checklist says licensed behavior analysts "are independent practitioners."
Source: Minn. Stat. 148.9983; Minnesota Board of Psychology, Initial BA Application for Licensure Checklist.
Assistants, RBTs and technicians
Sections 148.9981 to 148.9995 license "behavior analysts." We found no license or registration in them for assistant behavior analysts (BCaBAs), registered behavior technicians (RBTs) or other technicians. The statute exempts work "by an unlicensed supervisee or trainee under the authority and direction of a licensed behavior analyst and in compliance with the licensure and supervision standards required by law or rule." (Minn. Stat. 148.9987(a)(6))
Minnesota's Medical Assistance EIDBI program has separate provider qualifications that reference licensed behavior analysts, BCaBAs and RBTs. Additional employment, education, experience or training requirements depend on the provider level and qualification route. These are program qualifications, not separate state licenses for assistants or technicians. (Minn. Stat. 256B.0949, subd. 15)
Source: Minn. Stat. 148.9987; Minn. Stat. 256B.0949.
Renewal and state-required training
Cycle. "A license must be renewed every two years." (Minn. Stat. 148.9984, subd. 1) At least 60 calendar days before the deadline the Board "must mail a renewal notice" to the licensee's last known address, and a licensee's failure to receive it "does not relieve the licensee of the obligation to meet the renewal deadline." (subd. 2)
What renewal takes. The licensee submits a signed renewal application, the renewal fee, and:
"evidence satisfactory to the board that the licensee holds a current and active national certification as a behavior analyst from the certifying entity or otherwise meets renewal requirements as established by the board, in consultation with the advisory council." (Minn. Stat. 148.9984, subd. 3(a)(3))
We did not find a state-set number of continuing education hours, or a state-required topic such as ethics, jurisprudence or human trafficking, in sections 148.9981 to 148.9995. The Board may set other renewal requirements, so check its current renewal notice.
Late and expired licenses. A late fee applies if the renewal application is postmarked or received after the expiration date, or after the following business day when the expiration date falls on a Saturday, Sunday, or holiday. (Section 148.9984, subdivision 5) The Board must terminate a license when its renewal is at least 60 days overdue and the Board has sent the overdue notice required by section 148.9985(a). The Board retains jurisdiction over complaints about conduct during licensure. (Section 148.9985) A licensee whose renewal is postmarked or received by the deadline may keep practicing while it is pending. (148.9984, subd. 4)
Duty to update. A licensee must tell the Board within 30 days of a change of name, address, place of employment, telephone number or other application information. (Minn. Stat. 148.9989)
Competence. Behavior analysts must limit practice to populations and services for which they have competence or are developing competence. When developing competence, they must obtain the professional education, training, continuing education, consultation, supervision or experience, or combination thereof, necessary to demonstrate competence. (Minn. Stat. 148.9991, subds. 1 and 2) Written informed consent is required before services begin, except for emergency or crisis services. If services continue after the emergency or crisis has abated, informed consent must be obtained. (Section 148.9993)
Source: Minn. Stat. 148.9984, 148.9985, 148.9989, 148.9991, 148.9993.
Training the staff you supervise
If you run a program in Minnesota and need new technicians or aides trained in the basics, this is what our Intro to ABA Level 1 course covers.
The Intro to ABA Level 1 course teaches methods and techniques of Applied Behavior Analysis (ABA) for parents and caregivers, teachers, paraprofessionals and behavior technicians who work with a child every day. Topics include what autism is, what ABA is, pairing, errorless teaching and prompting, and active student responding. Complete the course and pass its 40-question final exam with a score of at least 80%. Completing this course earns a Special Learning certificate of completion. That certificate is not a continuing education (CE) certificate. It is basic training in ABA methods for daily practice, not a professional credential. It is not the 40-hour training required for the RBT credential. We do not claim Minnesota state approval or continuing education credit for this course.
Two ways to start
- For one person: try the first two sessions free for 7 days; account creation is required, with no payment information requested. The full course costs $199, paid once, with no subscription or recurring charge. Activate your license code within 90 days of purchase; the published completion window is 10 weeks after activation. You may request a later start date, no later than three months after purchase. Start the free sessions
- For your team: tell us how many people need training and when, and we will send a quote; each participant who completes the course and passes its 40-question final exam with a score of at least 80% earns an individual certificate of completion. Ask for a team quote
Last reviewed: October 30, 2026.