How to Apply for 104 NP Certification With the California BRN

When Did the 104 Application Open, and Who Can File It?

January 1, 2026 is the date California nurse practitioners became eligible for 104 status for the first time 4Ref 4Sheppard, Mullin, Richter & Hampton LLP — Healthcare Law Blog (2025).Pulse Check: How is Your California Practice Leveraging “103 NPs” – and Preparing for the Arrival of “104 NPs” in 2026?.'On January 1, 2026, nurse practitioners licensed in California will be eligible for ‘104 NP’ status for the first time'; after three years of practising as a 103 NP, such NPs may apply to practise without standardized procedures outside the defined settings.. The delay was structural rather than administrative: BPC §2837.104(b)(3) requires three years of practice in good standing as a nurse practitioner "not inclusive of the transition to practice," and the 103 certificate itself did not exist until January 2023 3Ref 3California State Legislature (2024).Business and Professions Code § 2837.104 — Nurse practitioners: practice outside specified settings (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.104(a)(1) authorizes the §2837.103(c) functions outside the six settings; (a)(2)–(3) medical staff membership eligibility and department voting subject to bylaws conflict-of-interest policies; (b)(1)–(3) eligibility including the active California RN license, master's or doctoral degree, and three years in good standing 'not inclusive of the transition to practice' with board discretion to lower it for a DNP; (c)(1)–(4) the scope limit, the four mandatory physician-consultation circumstances, sole responsibility for services provided, and the referral plan 'specific to the practice area' with five required criteria; (d) and (f) the new-patient notification and posted notice; (g) professional liability insurance; (h) corporations and other artificial legal entities have no professional rights, privileges or powers..

The application is live now. The BRN's Advanced Practice and PHN Certification page carries a "Nurse Practitioner - Independent Practice (104 NP)" section — described as "A Nurse Practitioner who practices without standardized procedures in an independent setting, within the limits of their knowledge and experience and national certification" — with an Apply Online link, the step-by-step instruction packet, and a separate Verification of Doctorate of Nursing Practice Clinical Hours form 2Ref 2California Board of Registered Nursing (2026).Advanced Practice and PHN Certification — application instructions, including “Nurse Practitioner - Independent Practice (104 NP)”.BRN Advanced Practice and PHN Certification page: a live 'Nurse Practitioner - Independent Practice (104 NP)' section describing 'A Nurse Practitioner who practices without standardized procedures in an independent setting, within the limits of their knowledge and experience and national certification,' with an Apply Online link, the 104 NP online instructions and a 'Verification of Doctorate of Nursing Practice Clinical Hours' form; the same page also hosts the 103 NP application section..

Eligibility is unchanged from the statute: every 103 requirement, an active California RN license plus a master's or doctoral degree, and the three further years in good standing (BPC §2837.104(b)) 3Ref 3California State Legislature (2024).Business and Professions Code § 2837.104 — Nurse practitioners: practice outside specified settings (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.104(a)(1) authorizes the §2837.103(c) functions outside the six settings; (a)(2)–(3) medical staff membership eligibility and department voting subject to bylaws conflict-of-interest policies; (b)(1)–(3) eligibility including the active California RN license, master's or doctoral degree, and three years in good standing 'not inclusive of the transition to practice' with board discretion to lower it for a DNP; (c)(1)–(4) the scope limit, the four mandatory physician-consultation circumstances, sole responsibility for services provided, and the referral plan 'specific to the practice area' with five required criteria; (d) and (f) the new-patient notification and posted notice; (g) professional liability insurance; (h) corporations and other artificial legal entities have no professional rights, privileges or powers.. The eligibility detail sits on what a 104 NP is.

How Do You File the 104 Application in BreEZe?

Through your existing BreEZe account, and — as with the 103 — not through "Start a New Application." The BRN's instructions direct you to the drop-down menu under Nurse Practitioner and then to "NP Independent Practice" 1Ref 1California Board of Registered Nursing (2026).Step by Step Guide for Applying for NP Independent Practice (104 NP).BRN 104 NP step-by-step instructions: header note that the applicant 'has practiced as a Nurse Practitioner Group Setting without Standardized Procedures (103 NP) in good standing for at least three full-time equivalent years or 4,600 hours in direct patient care'; log in to BreEZe, 'Select drop down menu under Nurse Practitioner. NOTE: Do not choose “Start a New Application”. Select NP Independent Practice'; 'The Start date of obtaining the 4,600 hours as a 104 NP must be after obtaining designation of 103 NP'; 'The overall total hours associated with three years in direct patient care, must add up and be equal to or greater than 4,600 hours'; 'Do not attach any items. The attachment option does not apply to this application'; 'Click the blue “Proceed to Payment” button to submit the application, no fee is due at this time'; the national-certification message directing applicants to have verification sent to the board's advanced-practice documents address..

The sequence, as the board publishes it 1Ref 1California Board of Registered Nursing (2026).Step by Step Guide for Applying for NP Independent Practice (104 NP).BRN 104 NP step-by-step instructions: header note that the applicant 'has practiced as a Nurse Practitioner Group Setting without Standardized Procedures (103 NP) in good standing for at least three full-time equivalent years or 4,600 hours in direct patient care'; log in to BreEZe, 'Select drop down menu under Nurse Practitioner. NOTE: Do not choose “Start a New Application”. Select NP Independent Practice'; 'The Start date of obtaining the 4,600 hours as a 104 NP must be after obtaining designation of 103 NP'; 'The overall total hours associated with three years in direct patient care, must add up and be equal to or greater than 4,600 hours'; 'Do not attach any items. The attachment option does not apply to this application'; 'Click the blue “Proceed to Payment” button to submit the application, no fee is due at this time'; the national-certification message directing applicants to have verification sent to the board's advanced-practice documents address.: introduction, Information Privacy Act agreement, function suitability questions, application questions (answer No until your category/specialty appears, then Yes), name and personal details, address detail summary, then the national certification block, where answering No ends the application. After that comes the employment-information block described below, then attachments, summary, attestation and submission.

Two screens surprise people. Attachments: the instructions say "Do not attach any items. The attachment option does not apply to this application" 1Ref 1California Board of Registered Nursing (2026).Step by Step Guide for Applying for NP Independent Practice (104 NP).BRN 104 NP step-by-step instructions: header note that the applicant 'has practiced as a Nurse Practitioner Group Setting without Standardized Procedures (103 NP) in good standing for at least three full-time equivalent years or 4,600 hours in direct patient care'; log in to BreEZe, 'Select drop down menu under Nurse Practitioner. NOTE: Do not choose “Start a New Application”. Select NP Independent Practice'; 'The Start date of obtaining the 4,600 hours as a 104 NP must be after obtaining designation of 103 NP'; 'The overall total hours associated with three years in direct patient care, must add up and be equal to or greater than 4,600 hours'; 'Do not attach any items. The attachment option does not apply to this application'; 'Click the blue “Proceed to Payment” button to submit the application, no fee is due at this time'; the national-certification message directing applicants to have verification sent to the board's advanced-practice documents address.. Payment: you complete the attestation with the Yes radio button and then click "Proceed to Payment" to submit — and the board's own note reads that this submits the application, "no fee is due at this time" 1Ref 1California Board of Registered Nursing (2026).Step by Step Guide for Applying for NP Independent Practice (104 NP).BRN 104 NP step-by-step instructions: header note that the applicant 'has practiced as a Nurse Practitioner Group Setting without Standardized Procedures (103 NP) in good standing for at least three full-time equivalent years or 4,600 hours in direct patient care'; log in to BreEZe, 'Select drop down menu under Nurse Practitioner. NOTE: Do not choose “Start a New Application”. Select NP Independent Practice'; 'The Start date of obtaining the 4,600 hours as a 104 NP must be after obtaining designation of 103 NP'; 'The overall total hours associated with three years in direct patient care, must add up and be equal to or greater than 4,600 hours'; 'Do not attach any items. The attachment option does not apply to this application'; 'Click the blue “Proceed to Payment” button to submit the application, no fee is due at this time'; the national-certification message directing applicants to have verification sent to the board's advanced-practice documents address.. The button name is not a fee.

What Does the Board Ask About Your 4,600 Hours?

It asks you to enter the employment behind them, and it enforces one timing rule hard. The instruction packet's note is unambiguous: "The Start date of obtaining the 4,600 hours as a 104 NP must be after obtaining designation of 103 NP" 1Ref 1California Board of Registered Nursing (2026).Step by Step Guide for Applying for NP Independent Practice (104 NP).BRN 104 NP step-by-step instructions: header note that the applicant 'has practiced as a Nurse Practitioner Group Setting without Standardized Procedures (103 NP) in good standing for at least three full-time equivalent years or 4,600 hours in direct patient care'; log in to BreEZe, 'Select drop down menu under Nurse Practitioner. NOTE: Do not choose “Start a New Application”. Select NP Independent Practice'; 'The Start date of obtaining the 4,600 hours as a 104 NP must be after obtaining designation of 103 NP'; 'The overall total hours associated with three years in direct patient care, must add up and be equal to or greater than 4,600 hours'; 'Do not attach any items. The attachment option does not apply to this application'; 'Click the blue “Proceed to Payment” button to submit the application, no fee is due at this time'; the national-certification message directing applicants to have verification sent to the board's advanced-practice documents address.. The two qualifying periods stack; they do not overlap.

The board then checks that "the overall total hours associated with three years in direct patient care, must add up and be equal to or greater than 4,600 hours," and if you are short you add another employment entry 1Ref 1California Board of Registered Nursing (2026).Step by Step Guide for Applying for NP Independent Practice (104 NP).BRN 104 NP step-by-step instructions: header note that the applicant 'has practiced as a Nurse Practitioner Group Setting without Standardized Procedures (103 NP) in good standing for at least three full-time equivalent years or 4,600 hours in direct patient care'; log in to BreEZe, 'Select drop down menu under Nurse Practitioner. NOTE: Do not choose “Start a New Application”. Select NP Independent Practice'; 'The Start date of obtaining the 4,600 hours as a 104 NP must be after obtaining designation of 103 NP'; 'The overall total hours associated with three years in direct patient care, must add up and be equal to or greater than 4,600 hours'; 'Do not attach any items. The attachment option does not apply to this application'; 'Click the blue “Proceed to Payment” button to submit the application, no fee is due at this time'; the national-certification message directing applicants to have verification sent to the board's advanced-practice documents address.. The header of the packet restates the underlying premise: the applicant "has practiced as a Nurse Practitioner Group Setting without Standardized Procedures (103 NP) in good standing for at least three full-time equivalent years or 4,600 hours in direct patient care" 1Ref 1California Board of Registered Nursing (2026).Step by Step Guide for Applying for NP Independent Practice (104 NP).BRN 104 NP step-by-step instructions: header note that the applicant 'has practiced as a Nurse Practitioner Group Setting without Standardized Procedures (103 NP) in good standing for at least three full-time equivalent years or 4,600 hours in direct patient care'; log in to BreEZe, 'Select drop down menu under Nurse Practitioner. NOTE: Do not choose “Start a New Application”. Select NP Independent Practice'; 'The Start date of obtaining the 4,600 hours as a 104 NP must be after obtaining designation of 103 NP'; 'The overall total hours associated with three years in direct patient care, must add up and be equal to or greater than 4,600 hours'; 'Do not attach any items. The attachment option does not apply to this application'; 'Click the blue “Proceed to Payment” button to submit the application, no fee is due at this time'; the national-certification message directing applicants to have verification sent to the board's advanced-practice documents address..

If you hold a DNP, the board publishes a separate Verification of Doctorate of Nursing Practice Clinical Hours form for the doctoral hours BPC §2837.104(b)(3) allows it to consider at its discretion 2Ref 2California Board of Registered Nursing (2026).Advanced Practice and PHN Certification — application instructions, including “Nurse Practitioner - Independent Practice (104 NP)”.BRN Advanced Practice and PHN Certification page: a live 'Nurse Practitioner - Independent Practice (104 NP)' section describing 'A Nurse Practitioner who practices without standardized procedures in an independent setting, within the limits of their knowledge and experience and national certification,' with an Apply Online link, the 104 NP online instructions and a 'Verification of Doctorate of Nursing Practice Clinical Hours' form; the same page also hosts the 103 NP application section.3Ref 3California State Legislature (2024).Business and Professions Code § 2837.104 — Nurse practitioners: practice outside specified settings (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.104(a)(1) authorizes the §2837.103(c) functions outside the six settings; (a)(2)–(3) medical staff membership eligibility and department voting subject to bylaws conflict-of-interest policies; (b)(1)–(3) eligibility including the active California RN license, master's or doctoral degree, and three years in good standing 'not inclusive of the transition to practice' with board discretion to lower it for a DNP; (c)(1)–(4) the scope limit, the four mandatory physician-consultation circumstances, sole responsibility for services provided, and the referral plan 'specific to the practice area' with five required criteria; (d) and (f) the new-patient notification and posted notice; (g) professional liability insurance; (h) corporations and other artificial legal entities have no professional rights, privileges or powers.. The underlying hour rules are set out in the 4,600-hour transition to practice — note that page describes the first qualifying period, not this second one.

What Changes the Day Your 104 Certificate Is Approved?

One permission, two governance rights, and four standing duties.

The permission. You may perform the six functions in BPC §2837.103(c) outside the six settings listed at §2837.103(a)(2) — the solo office, your own entity, the house-call or telehealth practice (BPC §2837.104(a)(1)) 3Ref 3California State Legislature (2024).Business and Professions Code § 2837.104 — Nurse practitioners: practice outside specified settings (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.104(a)(1) authorizes the §2837.103(c) functions outside the six settings; (a)(2)–(3) medical staff membership eligibility and department voting subject to bylaws conflict-of-interest policies; (b)(1)–(3) eligibility including the active California RN license, master's or doctoral degree, and three years in good standing 'not inclusive of the transition to practice' with board discretion to lower it for a DNP; (c)(1)–(4) the scope limit, the four mandatory physician-consultation circumstances, sole responsibility for services provided, and the referral plan 'specific to the practice area' with five required criteria; (d) and (f) the new-patient notification and posted notice; (g) professional liability insurance; (h) corporations and other artificial legal entities have no professional rights, privileges or powers..

The governance rights. You become eligible for membership of an organized medical staff, and as a member you may vote at meetings of the department to which nurse practitioners are assigned — both subject to applicable conflict-of-interest policies of the bylaws (BPC §2837.104(a)(2)–(3)) 3Ref 3California State Legislature (2024).Business and Professions Code § 2837.104 — Nurse practitioners: practice outside specified settings (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.104(a)(1) authorizes the §2837.103(c) functions outside the six settings; (a)(2)–(3) medical staff membership eligibility and department voting subject to bylaws conflict-of-interest policies; (b)(1)–(3) eligibility including the active California RN license, master's or doctoral degree, and three years in good standing 'not inclusive of the transition to practice' with board discretion to lower it for a DNP; (c)(1)–(4) the scope limit, the four mandatory physician-consultation circumstances, sole responsibility for services provided, and the referral plan 'specific to the practice area' with five required criteria; (d) and (f) the new-patient notification and posted notice; (g) professional liability insurance; (h) corporations and other artificial legal entities have no professional rights, privileges or powers.. That is broader than the 103's narrow voting right.

The duties that attach. BPC §2837.104(c) brings the scope limit, the four mandatory physician-consultation circumstances, the written referral plan with five specific criteria, and sole responsibility for the services you provide 3Ref 3California State Legislature (2024).Business and Professions Code § 2837.104 — Nurse practitioners: practice outside specified settings (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.104(a)(1) authorizes the §2837.103(c) functions outside the six settings; (a)(2)–(3) medical staff membership eligibility and department voting subject to bylaws conflict-of-interest policies; (b)(1)–(3) eligibility including the active California RN license, master's or doctoral degree, and three years in good standing 'not inclusive of the transition to practice' with board discretion to lower it for a DNP; (c)(1)–(4) the scope limit, the four mandatory physician-consultation circumstances, sole responsibility for services provided, and the referral plan 'specific to the practice area' with five required criteria; (d) and (f) the new-patient notification and posted notice; (g) professional liability insurance; (h) corporations and other artificial legal entities have no professional rights, privileges or powers.. They are not optional and they are not a formality — what replaces standardized procedures works through each one.

What does not change: no new initials or title. Verification runs through the Department of Consumer Affairs License Search, which displays 103 or 104 authority alongside RN license status 2Ref 2California Board of Registered Nursing (2026).Advanced Practice and PHN Certification — application instructions, including “Nurse Practitioner - Independent Practice (104 NP)”.BRN Advanced Practice and PHN Certification page: a live 'Nurse Practitioner - Independent Practice (104 NP)' section describing 'A Nurse Practitioner who practices without standardized procedures in an independent setting, within the limits of their knowledge and experience and national certification,' with an Apply Online link, the 104 NP online instructions and a 'Verification of Doctorate of Nursing Practice Clinical Hours' form; the same page also hosts the 103 NP application section..

What Does the BRN Not Publish About the 104 Application?

The 103's forward-looking gaps, without even its retrospective averages — and one more.

No processing-time estimate. The BRN's Processing Times page, certification table updated 21 July 2026, lists timeframes for Nurse Practitioner, Nurse Practitioner Furnishing, Nurse-Midwife, Nurse Anesthetist, Clinical Nurse Specialist, Psychiatric/Mental Health Nurse and Public Health Nurse certifications — and carries no row for the 104 NP 5Ref 5California Board of Registered Nursing (2026).Processing Times (certification table updated July 21, 2026).BRN Processing Times page, certification table updated 7/21/2026: rows for Nurse Practitioner, Nurse Practitioner Furnishing, Nurse-Midwife, Nurse-Midwife Furnishing, Nurse Anesthetist, Clinical Nurse Specialist, Psychiatric/Mental Health Nurse and Public Health Nurse Certification. No row exists for the 103 NP or the 104 NP certification.. No published board estimate exists.

No published fee. The instruction packet states no fee is due at submission 1Ref 1California Board of Registered Nursing (2026).Step by Step Guide for Applying for NP Independent Practice (104 NP).BRN 104 NP step-by-step instructions: header note that the applicant 'has practiced as a Nurse Practitioner Group Setting without Standardized Procedures (103 NP) in good standing for at least three full-time equivalent years or 4,600 hours in direct patient care'; log in to BreEZe, 'Select drop down menu under Nurse Practitioner. NOTE: Do not choose “Start a New Application”. Select NP Independent Practice'; 'The Start date of obtaining the 4,600 hours as a 104 NP must be after obtaining designation of 103 NP'; 'The overall total hours associated with three years in direct patient care, must add up and be equal to or greater than 4,600 hours'; 'Do not attach any items. The attachment option does not apply to this application'; 'Click the blue “Proceed to Payment” button to submit the application, no fee is due at this time'; the national-certification message directing applicants to have verification sent to the board's advanced-practice documents address.; the board has published no separate 104 fee line.

No cohort data yet. Because the category opened in 2026, the board's last sunset report predates any 104 issuance figures. There is currently no public number for how many 104 certificates have been granted, how many were denied, or on what grounds.

Anyone quoting you a 104 approval timeline is estimating. That is worth knowing before you set a practice-opening date, sign a lease, or give notice.

What Should You Line Up Before the Certificate Arrives?

Certification is the licensing step, not the operating one. Four things sit outside the BRN's process entirely.

The referral plan. BPC §2837.104(c)(4) requires a plan "specific to the practice area" with specific referral criteria addressing five categories 3Ref 3California State Legislature (2024).Business and Professions Code § 2837.104 — Nurse practitioners: practice outside specified settings (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.104(a)(1) authorizes the §2837.103(c) functions outside the six settings; (a)(2)–(3) medical staff membership eligibility and department voting subject to bylaws conflict-of-interest policies; (b)(1)–(3) eligibility including the active California RN license, master's or doctoral degree, and three years in good standing 'not inclusive of the transition to practice' with board discretion to lower it for a DNP; (c)(1)–(4) the scope limit, the four mandatory physician-consultation circumstances, sole responsibility for services provided, and the referral plan 'specific to the practice area' with five required criteria; (d) and (f) the new-patient notification and posted notice; (g) professional liability insurance; (h) corporations and other artificial legal entities have no professional rights, privileges or powers.. It is a document you write, and it should exist before your first independent patient.

Insurance and entity. Professional liability insurance appropriate for the practice setting is required (BPC §2837.104(g)) 3Ref 3California State Legislature (2024).Business and Professions Code § 2837.104 — Nurse practitioners: practice outside specified settings (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.104(a)(1) authorizes the §2837.103(c) functions outside the six settings; (a)(2)–(3) medical staff membership eligibility and department voting subject to bylaws conflict-of-interest policies; (b)(1)–(3) eligibility including the active California RN license, master's or doctoral degree, and three years in good standing 'not inclusive of the transition to practice' with board discretion to lower it for a DNP; (c)(1)–(4) the scope limit, the four mandatory physician-consultation circumstances, sole responsibility for services provided, and the referral plan 'specific to the practice area' with five required criteria; (d) and (f) the new-patient notification and posted notice; (g) professional liability insurance; (h) corporations and other artificial legal entities have no professional rights, privileges or powers., and the setting is changing. Entity formation runs into BPC §2837.104(h) and California corporate law rather than into AB 890 — this is legal information, not legal advice, and the structure is worth confirming with a California health-law attorney before you sign anything.

Payer enrollment. Credentialing and contracting are a separate track that does not move with BRN certification, and a new billing entity generally restarts it — see credentialing and start a private practice. Gale, the practice OS this library belongs to, is built to run that track for independent clinicians.

The consumer notice. Both halves follow you into the new setting and neither was repealed in 2024: inform all new patients, in a language understandable to them, that a nurse practitioner is not a physician and surgeon (BPC §2837.104(d)), and post the conspicuous Board of Registered Nursing notice (BPC §2837.104(f)) 3Ref 3California State Legislature (2024).Business and Professions Code § 2837.104 — Nurse practitioners: practice outside specified settings (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.104(a)(1) authorizes the §2837.103(c) functions outside the six settings; (a)(2)–(3) medical staff membership eligibility and department voting subject to bylaws conflict-of-interest policies; (b)(1)–(3) eligibility including the active California RN license, master's or doctoral degree, and three years in good standing 'not inclusive of the transition to practice' with board discretion to lower it for a DNP; (c)(1)–(4) the scope limit, the four mandatory physician-consultation circumstances, sole responsibility for services provided, and the referral plan 'specific to the practice area' with five required criteria; (d) and (f) the new-patient notification and posted notice; (g) professional liability insurance; (h) corporations and other artificial legal entities have no professional rights, privileges or powers.. Only the separate right-to-see-a-physician statement is one the board may not require of you (BPC §2837.104(e)) 3Ref 3California State Legislature (2024).Business and Professions Code § 2837.104 — Nurse practitioners: practice outside specified settings (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.104(a)(1) authorizes the §2837.103(c) functions outside the six settings; (a)(2)–(3) medical staff membership eligibility and department voting subject to bylaws conflict-of-interest policies; (b)(1)–(3) eligibility including the active California RN license, master's or doctoral degree, and three years in good standing 'not inclusive of the transition to practice' with board discretion to lower it for a DNP; (c)(1)–(4) the scope limit, the four mandatory physician-consultation circumstances, sole responsibility for services provided, and the referral plan 'specific to the practice area' with five required criteria; (d) and (f) the new-patient notification and posted notice; (g) professional liability insurance; (h) corporations and other artificial legal entities have no professional rights, privileges or powers..