Opposing Undue Licensing Burdens for Massage Workers in NYC
June 18, 2025
Re: Int. No. 970 – A Local Law to amend the administrative code of the city of New York, in relation to licensing massage therapy businesses
Dear Members of the New York City Council,
We are writing from the Woodhull Freedom Foundation to urge you to oppose Int. 970, a measure that would create a new licensing requirement for massage therapy businesses and provide civil penalties for those who operate in violation of the requirement. This bill is redundant in that there are already licensing requirements for massage therapy, and enforcement would disproportionately affect our most marginalized immigrant communities that are already being targeted by federal agencies. New York City should be creating policies that protect our communities instead of adding new barriers to employment and increasing the risk of exposure to criminalization.
The Woodhull Freedom Foundation is a national organization whose mission is to affirm sexual freedom as a fundamental human right. Woodhull protects and defends individuals’ rights across the United States to enjoy sexual dignity, privacy, and consensual sexual expression without societal or governmental interference, coercion, or stigmatization.
Massage therapy is already regulated and licensed to the point of inaccessibility in New York, especially for immigrant workers who make up a significant portion of the massage therapy workforce in New York City. Current law requires individual massage therapists to acquire a license – a process that structurally prevents any non-English speaking immigrant worker from attaining a license:
According to the New York State Education Department Office of Professions, to become a masseur, a person must show proof to work in the U.S., prove English proficiency, and complete a minimum of 1,000 hours of education, which can cost up to $15,000 in massage school fees and tuition costs.
The hurdles to licensing are stacked especially high for Asian immigrant women facing financial, criminalization, and deportation risks. Some workers have self-reported that, due to pressures to get licensed, they were “frauded by scam massage license agencies that have popped up to capitalize on these licensure regulations.”
Adding additional licensing requirements, fees, and civil penalties for a profession that already requires inaccessible provider licenses will create additional insurmountable barriers to employment for immigrant workers who should instead be uplifted by our city. Multiple licensing requirements that differ between the state and local levels will create confusion, and the prohibitive costs and confusing requirements will leave many businesses out of compliance, regardless of their attempts to follow regulations. Targeting massage therapy businesses in this way will deprive many New Yorkers of access to a necessary service.
Passage of this bill would increase surveillance of massage therapy businesses, which are already a target of local law enforcement and ICE. Enforcement of stricter licensing requirements would increase workers’ likelihood of interacting with law enforcement, increasing their vulnerability to immigration consequences. There is no compelling argument that this bill would improve public safety or health to a substantial degree, justifying the harms it would cause. The committee report issued about Int. 970 in October 2024 alludes to human trafficking occurring in massage therapy businesses; however, adding new licensing requirements in addition to those that already exist is not a viable anti-trafficking measure and will instead put victims at an increased risk of harm and potential deportation. Mayor Adams’ Operation Restore Roosevelt has increased criminalization of operating without a license, which has already led to a dramatic increase in arrests for immigrant women, particularly Asian workers who made up 92% of arrests for massage without a license in 2024, according to NYC Open Data’s reported NYPD arrest data. This new bill, combined with the existing pattern of policing and fears of being detained by immigration outside of courts, could put workers in even more danger.
It is more critical now than ever for New York City to protect its immigrant communities. Leaning into the harmful rhetoric of “good” and “bad” immigrants spread by federal anti-immigrant efforts and Operation Restore Roosevelt alike will only continue to make many feel unwelcome and unsafe in the neighborhoods they call home and contribute to. We must continue our city’s legacy of thriving immigrant communities.
We urge you to take a stand for New Yorkers and oppose Int. 970.