Can I practice somatic work without a license in Oregon?

Yes, within two limits: under ORS 675.825(4), Oregon's counseling law does not limit a person who does not practice "the assessment, diagnosis or treatment of mental, emotional or behavioral disorders," and touch work needs a massage license unless an exemption such as ORS 687.031(1)(j) applies with all four of its conditions^{1, 2}. Outside those limits, the counseling board can levy up to $2,500 per violation under ORS 675.825(6), and unlicensed massage is a Class A misdemeanor under ORS 687.991(1)(a)^{1, 2}.

This page quotes the 2025 edition of the Oregon Revised Statutes and the current Oregon Administrative Rules, checked on October 9 and 10, 2026.

Bottom line for unlicensed practitioners in Oregon

• Do not assess, diagnose or treat mental, emotional or behavioral disorders without a listed status or exemption¹.
• Touch work needs a massage license unless an exemption applies, such as ORS 687.031(1)(j) with all four of its conditions².
• The massage board writes that using massage techniques inside an exempt practice counts as massage³.
• Oregon counseling rules apply when the client is in Oregon, also online⁴.

When does my work count as professional counseling in Oregon?

1. ORS 675.705(8)(a) defines professional counseling as "the assessment, diagnosis or treatment of mental, emotional or behavioral disorders"¹. Under ORS 675.825(1)(d), you may not practice it without a listed status or exemption¹.
2. The counseling law does not limit your profession if you do not practice counseling as defined in ORS 675.705(8)(a)¹. It also does not limit a person who "Does not meet the requirements of ORS 675.715 (1)(b)"¹. That paragraph asks for a graduate degree in counseling or marriage and family therapy with training in the diagnosis of mental disorders¹.
3. The list of what counseling "may include" also names "Provision of counseling services to address personal growth or wellness"¹. The statute does not say how this list and the subsection (4) carve-out fit together for a given service.

If your sessions assess, diagnose or treat a disorder, the statute names four options: licensure, registration as an associate, graduate study in counseling or marriage and family therapy, or an exemption under subsection (3)¹. Subsection (3) covers, among others, a person "Licensed, certified, registered or similarly regulated under the laws of this state" who works within that scope¹. The board investigates licensees and also "any person alleged to be practicing in violation of Board law"⁵.

Does the movement-awareness exemption cover my touch work?

Only if every condition in ORS 687.031(1)(j) holds. The board's rule, OAR 334-010-0027, adds detail.

The massage board writes that "if a practitioner uses massage techniques during the performance of an exempted practice, the practitioner is practicing massage"³. Its guidance quotes the broad definition of massage in ORS 687.011(4)(a), which includes "pressure, friction, stroking, tapping or kneading on the human body"³. By our reading, work that goes beyond the (1)(j) methods is practice of massage under ORS 687.021 unless another ORS 687.031 exemption applies^{2, 3}.

ORS 687.031(1)(h) separately exempts practitioners of "psychotherapy or counseling modalities that use physical techniques" within a license, or with an express agreement that the touch serves only the psychotherapy or counseling². By our reading, neither massage exemption authorizes counseling under ORS 675.825(1)(d)¹.

Can the massage board check whether my certification qualifies?

Yes. ORS 687.031(2) gives the State Board of Massage Therapists authority "to verify that a practitioner claiming to be exempt" holds the certification that (1)(j)(C) requires². Under OAR 334-010-0027(3), that check "may include, but is not limited to, consultation with the practitioners certifying organization or agency"⁶.

The rule puts the burden on you: "It is the exempt practitioner's responsibility to insure they meet the criteria for being exempt"⁶. Questions go to the board at 503-365-8657³. The certification guide compares what several training institutes require.

Do Oregon rules apply if I see an Oregon client online?

For counseling, yes. OAR 833-110-0071(1) says a person engages in professional counseling in Oregon if "the client, patient, consultee, supervisee, research subject, or any other individual or group receiving those services is located in Oregon" at the time of the service⁴. By our reading, this covers you even when you work from another state⁴.

We did not check whether the massage law has a matching rule. The guides for Washington, California, Colorado and New York cover the rules in those states.

Is there an alternative health practitioner safe harbor in Oregon?

We did not verify any Oregon statute that gives unlicensed alternative practitioners a general safe harbor.

SB 388 from 2025 is not one. Its title reads "Relating to the Oregon Health Policy Board"⁷. It would have asked that board for a report by December 31, 2026⁷. The bill stayed in the Senate Committee on Health Care, and the legislature's record shows "In committee upon adjournment" on June 27, 2025^{7, 8}. The record lists no chapter number, so we read it as not enacted.

Do I have to give a Good Faith Estimate?

That depends on whether federal rules count you as a provider. 45 CFR 149.610(a)(2)(viii) covers a provider "acting within the scope of practice of that provider's license or certification under applicable State law"⁹. Whether a certification that meets ORS 687.031(1)(j)(C) counts as certification under Oregon law is unknown.

Where the rule applies, CMS says the provider must give uninsured or self-pay clients an estimate on request, or when they schedule "at least 3 business days in advance"¹⁰.

If the rule covers you, our free good faith estimate template shows what an estimate must contain and makes the PDF.

Which titles are reserved in Oregon?

Under SB 1547 section 21, the core sections of this new license become operative on January 1, 2027¹¹. Section 2(1) requires a bachelor's degree and at least 700 hours of supervised practice in an approved program, plus an exam and other board requirements¹¹. Under section 1(3), its scope includes "Psychoeducation" and "Skills training and skills support"¹¹. Section 6 bars these licensees from diagnosing or independently treating a behavioral, emotional or mental disorder¹¹.

How can I show my training without a license title?

Name your certificate and the institute that issued it, not a license title. A verified OneSomatic profile shows clients the same in one place, after OneSomatic reviews your proof of training. The profile does not by itself confirm a state license^{12, 13}.

Sources

1. Oregon Legislature, "ORS Chapter 675, 2025 edition". Checked October 10, 2026.
2. Oregon Legislature, "ORS Chapter 687, 2025 edition". Checked October 10, 2026.
3. Oregon Board of Massage Therapists, "The Practice of Massage, Massage Therapy and Bodywork" (Rev. 04/2023). Checked October 10, 2026.
4. Oregon Secretary of State, "OAR 833-110-0071". Checked October 9, 2026.
5. Oregon Board of Licensed Professional Counselors and Therapists, "Complaints". Checked October 9, 2026.
6. Oregon Secretary of State, "OAR 334-010-0027 Exempt Practices". Checked October 10, 2026.
7. Oregon Legislative Information System, "SB 388, 2025 Regular Session". Checked October 10, 2026.
8. Oregon Legislative Information System, "SB 388 measure history, 2025 Regular Session". Checked October 10, 2026.
9. Electronic Code of Federal Regulations, "45 CFR 149.610". Checked October 9, 2026.
10. Centers for Medicare and Medicaid Services, "Good Faith Estimate". Checked October 9, 2026.
11. Oregon Legislature, "Oregon Laws 2026, Chapter 26 (SB 1547)". Checked October 10, 2026.
12. OneSomatic, "Home". Checked October 9, 2026.
13. OneSomatic, "llms.txt". Checked October 9, 2026.