Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Board for Barbers and Cosmetology
 
Guidance Document Change: This guidance document currently provides guidance to regulated parties and the public regarding the implementation of the 1,000-hour cosmetology curriculum which became effective on September 1, 2024. The document establishes protocols for students already enrolled in a 1,500-hour cosmetology curriculum and outlines school responsibilities in meeting the 1,000-hour cosmetology program requirements. On September 29, 2025, the Board for Barbers and Cosmetology (“the Board”) amended this guidance to implement changes made to the Barbering and Cosmetology Regulations (18VAC41-20) as a result of the Board’s General Review of the Barbering and Cosmetology Regulations (Action 6339/ Stage 10871). The regulatory change (i) revised the cosmetology curricula while keeping the minimum training requirement of 1,000 hours; (ii) revised the barber curricula and reduced the minimum required training hours from 1,100 hours to 750 hours; (iii) revised the master barber curricula and reduced the minimum required training hours from 400 hours to 250 hours; and (iv) revised the dual barber/master barber curricula and reduced the minimum required training hours from 1,500 hours to 1,000 hours. The regulatory changes will become effective December 1, 2025. The amended guidance does not impose any new requirements. Please refer to the ORM review form for additional information.
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12/5/25  9:50 am
Commenter: Chandra Couch

Request to Extend Completion Dates
 

We would like to raise significant concerns regarding the implementation timeline for the Barber hour reduction and its impact on accredited schools and their currently enrolled part-time students. We respectfully request that the Board reconsider the current deadline or, alternatively, provide a specific exception for accredited institutions.

At present, our understanding is that the Board’s standard recommendation for students unable to complete their program by the deadline is to transition into the new curriculum. Unfortunately, this is not a viable option for accredited schools. These students have already been packaged for Title IV financial aid based on the published program length and curriculum in place at the time of enrollment. Reducing the required hours changes the total program length and jeopardizes Title IV eligibility for those students. The only alternative suggested—“disenrolling” affected students—is not compatible with federal financial aid regulations, accrediting standards, or practical instructional operations. Revising a program mid-stream creates compliance vulnerabilities across multiple areas and places institutions in an untenable position.

In addition to the funding implications, transitioning students into a new curriculum after instruction has already begun presents substantial academic complexities. It also exposes schools to potential misrepresentation concerns, as we take great pride in ensuring that our Enrollment Team provides accurate and compliant information regarding program structure and length. A State-mandated shift that invalidates previously disclosed program expectations places institutions in direct conflict with federal requirements for consistency and accuracy in consumer information.

These concerns are not new. We raised similar issues in 2024 when the Board reduced Cosmetology hours from 1500 to 1000. At that time, the Board established an August 31, 2026 transition deadline specifically to protect students—particularly part-time students—who were already enrolled under the previous program structure. We greatly appreciated that thoughtful accommodation. Given that precedent, it is unclear why the same approach was not applied to the Barber hour reduction.

For these reasons, we respectfully request that the Board either:

  1. Extend the transition deadline for the Barber program, or

  2. Create an exemption for accredited institutions allowing currently enrolled students, especially part-time students, to complete the program in which they originally enrolled, with full retention of their financial aid eligibility.

We would sincerely appreciate the Board’s reconsideration, as the current timeline creates compliance conflicts that accredited institutions cannot resolve without placing students at risk.

CommentID: 238454