103 NP vs. 104 NP in California: The Setting Is the Whole Difference

What Actually Separates a 103 NP From a 104 NP?

One word: setting. Both certificates authorize the same list of clinical functions — the six in Business and Professions Code §2837.103(c) 1Ref 1California State Legislature (2024).Business and Professions Code § 2837.103 — Nurse practitioners: practice without standardized procedures (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.103(a)(2)(A)–(F) enumerates the six settings (clinic, health facility except correctional treatment center and state hospital, H&S Ch. 2.5 facility, medical group practice/professional medical corporation, home health agency, hospice) in which 'one or more physicians and surgeons practice with the nurse practitioner without standardized procedures'; §2837.103(c) lists the six functions; §2837.103(a)(1)(D) sets the transition to practice at 'a minimum of three full-time equivalent years of practice or 4600 hours' completed 'in California'; §2837.103(d) requires informing new patients that a nurse practitioner is not a physician and surgeon; §2837.103(f) requires the conspicuous BRN notice; §2837.103(h) requires professional liability insurance; §2837.103(i) exempts Department of Corrections and Rehabilitation settings.. Neither one enlarges that list. The Board of Registered Nursing puts it plainly: the two categories "do not significantly extend or alter the current NPs scope of practice," they add "additional authority to work without standardized procedures" 3Ref 3California Board of Registered Nursing (2026).Assembly Bill 890 — Nurse Practitioners: Scope of Practice: Practice Without Standardized Procedures (program page and frequently asked questions).BRN AB 890 FAQ: the two categories 'do not significantly extend or alter the current NPs scope of practice' but 'do have additional authority to work without standardized procedures'; 'a move to a 103 or 104 NP is not required; it is just an option'; 'an NP that works in a nursing corporation cannot practice as a 103 NP without standardized procedures or physician oversite'; 16 CCR 1482.4 requires three full-time-equivalent years or 4,600 hours of direct patient care in good standing, 'good standing' meaning a 'current, active, and unrestricted license' not subject to probation, suspension or public reproval; DNP doctoral direct-patient-care hours may apply; the posted consumer notice must be 'in at least 48-point Arial font'; if national board certification expires the NP 'must immediately begin practicing under standardized procedures'; the Board 'chose not to create additional initials or make any title changes'; the 103 NP certification 'does not automatically provide furnishing authority.'.

What changes is where you may exercise that authority. A 103 NP is confined to six enumerated settings, and in each one at least one physician and surgeon must also practice with the nurse practitioner without standardized procedures (BPC §2837.103(a)(2)) 1Ref 1California State Legislature (2024).Business and Professions Code § 2837.103 — Nurse practitioners: practice without standardized procedures (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.103(a)(2)(A)–(F) enumerates the six settings (clinic, health facility except correctional treatment center and state hospital, H&S Ch. 2.5 facility, medical group practice/professional medical corporation, home health agency, hospice) in which 'one or more physicians and surgeons practice with the nurse practitioner without standardized procedures'; §2837.103(c) lists the six functions; §2837.103(a)(1)(D) sets the transition to practice at 'a minimum of three full-time equivalent years of practice or 4600 hours' completed 'in California'; §2837.103(d) requires informing new patients that a nurse practitioner is not a physician and surgeon; §2837.103(f) requires the conspicuous BRN notice; §2837.103(h) requires professional liability insurance; §2837.103(i) exempts Department of Corrections and Rehabilitation settings.. A 104 NP performs those same functions outside those settings (BPC §2837.104(a)(1)) 2Ref 2California 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 of the settings or organizations specified under subparagraphs (A) to (F)'; §2837.104(b)(3) requires practice 'as a nurse practitioner in good standing for at least three years, not inclusive of the transition to practice' and permits the board to lower it at its discretion for a DNP; §2837.104(c)(1) limits practice to the NP's education, training, knowledge, experience and national certification; §2837.104(d),(f),(g) carry the patient-notification, posted-notice and liability-insurance duties; §2837.104(h) provides that 'corporations and other artificial legal entities shall have no professional rights, privileges, or powers,' subject to the §2837.104(i) exceptions. — a solo office, your own professional corporation, a house-call practice, a telehealth panel you own.

So the decision question is not "how clinically independent do I want to be." It is: does a physician practice where I practice? If yes, the 103 is sufficient. If no — or if you intend to leave — you need the 104. The plain-language versions of each are at what a 103 NP is and what a 104 NP is.

Which Six Settings Does the 103 Certificate Confine You To?

Six, listed at BPC §2837.103(a)(2)(A)–(F) 1Ref 1California State Legislature (2024).Business and Professions Code § 2837.103 — Nurse practitioners: practice without standardized procedures (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.103(a)(2)(A)–(F) enumerates the six settings (clinic, health facility except correctional treatment center and state hospital, H&S Ch. 2.5 facility, medical group practice/professional medical corporation, home health agency, hospice) in which 'one or more physicians and surgeons practice with the nurse practitioner without standardized procedures'; §2837.103(c) lists the six functions; §2837.103(a)(1)(D) sets the transition to practice at 'a minimum of three full-time equivalent years of practice or 4600 hours' completed 'in California'; §2837.103(d) requires informing new patients that a nurse practitioner is not a physician and surgeon; §2837.103(f) requires the conspicuous BRN notice; §2837.103(h) requires professional liability insurance; §2837.103(i) exempts Department of Corrections and Rehabilitation settings.:

Two things NPs regularly miss. First, a nursing corporation is not on that list — the BRN states the consequence directly: "an NP that works in a nursing corporation cannot practice as a 103 NP without standardized procedures or physician oversite" 3Ref 3California Board of Registered Nursing (2026).Assembly Bill 890 — Nurse Practitioners: Scope of Practice: Practice Without Standardized Procedures (program page and frequently asked questions).BRN AB 890 FAQ: the two categories 'do not significantly extend or alter the current NPs scope of practice' but 'do have additional authority to work without standardized procedures'; 'a move to a 103 or 104 NP is not required; it is just an option'; 'an NP that works in a nursing corporation cannot practice as a 103 NP without standardized procedures or physician oversite'; 16 CCR 1482.4 requires three full-time-equivalent years or 4,600 hours of direct patient care in good standing, 'good standing' meaning a 'current, active, and unrestricted license' not subject to probation, suspension or public reproval; DNP doctoral direct-patient-care hours may apply; the posted consumer notice must be 'in at least 48-point Arial font'; if national board certification expires the NP 'must immediately begin practicing under standardized procedures'; the Board 'chose not to create additional initials or make any title changes'; the 103 NP certification 'does not automatically provide furnishing authority.'. Second, health care settings operated by the Department of Corrections and Rehabilitation are exempt from §2837.103 entirely (BPC §2837.103(i)) 1Ref 1California State Legislature (2024).Business and Professions Code § 2837.103 — Nurse practitioners: practice without standardized procedures (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.103(a)(2)(A)–(F) enumerates the six settings (clinic, health facility except correctional treatment center and state hospital, H&S Ch. 2.5 facility, medical group practice/professional medical corporation, home health agency, hospice) in which 'one or more physicians and surgeons practice with the nurse practitioner without standardized procedures'; §2837.103(c) lists the six functions; §2837.103(a)(1)(D) sets the transition to practice at 'a minimum of three full-time equivalent years of practice or 4600 hours' completed 'in California'; §2837.103(d) requires informing new patients that a nurse practitioner is not a physician and surgeon; §2837.103(f) requires the conspicuous BRN notice; §2837.103(h) requires professional liability insurance; §2837.103(i) exempts Department of Corrections and Rehabilitation settings..

How Long Does the Ladder From 103 to 104 Take?

Two stacked periods, not one. First the transition to practice — a minimum of three full-time-equivalent years of practice, or 4,600 hours, completed in California (BPC §2837.103(a)(1)(D)) 1Ref 1California State Legislature (2024).Business and Professions Code § 2837.103 — Nurse practitioners: practice without standardized procedures (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.103(a)(2)(A)–(F) enumerates the six settings (clinic, health facility except correctional treatment center and state hospital, H&S Ch. 2.5 facility, medical group practice/professional medical corporation, home health agency, hospice) in which 'one or more physicians and surgeons practice with the nurse practitioner without standardized procedures'; §2837.103(c) lists the six functions; §2837.103(a)(1)(D) sets the transition to practice at 'a minimum of three full-time equivalent years of practice or 4600 hours' completed 'in California'; §2837.103(d) requires informing new patients that a nurse practitioner is not a physician and surgeon; §2837.103(f) requires the conspicuous BRN notice; §2837.103(h) requires professional liability insurance; §2837.103(i) exempts Department of Corrections and Rehabilitation settings.. Then, on top of that, at least three years having "practiced as a nurse practitioner in good standing," and "not inclusive of the transition to practice" (BPC §2837.104(b)(3)) 2Ref 2California 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 of the settings or organizations specified under subparagraphs (A) to (F)'; §2837.104(b)(3) requires practice 'as a nurse practitioner in good standing for at least three years, not inclusive of the transition to practice' and permits the board to lower it at its discretion for a DNP; §2837.104(c)(1) limits practice to the NP's education, training, knowledge, experience and national certification; §2837.104(d),(f),(g) carry the patient-notification, posted-notice and liability-insurance duties; §2837.104(h) provides that 'corporations and other artificial legal entities shall have no professional rights, privileges, or powers,' subject to the §2837.104(i) exceptions.. Note the statute says as a nurse practitioner; that those three years must be served specifically as a 103 NP is the BRN's reading, through 16 CCR 1482.4 and its 104 application instructions, rather than a phrase in the code 3Ref 3California Board of Registered Nursing (2026).Assembly Bill 890 — Nurse Practitioners: Scope of Practice: Practice Without Standardized Procedures (program page and frequently asked questions).BRN AB 890 FAQ: the two categories 'do not significantly extend or alter the current NPs scope of practice' but 'do have additional authority to work without standardized procedures'; 'a move to a 103 or 104 NP is not required; it is just an option'; 'an NP that works in a nursing corporation cannot practice as a 103 NP without standardized procedures or physician oversite'; 16 CCR 1482.4 requires three full-time-equivalent years or 4,600 hours of direct patient care in good standing, 'good standing' meaning a 'current, active, and unrestricted license' not subject to probation, suspension or public reproval; DNP doctoral direct-patient-care hours may apply; the posted consumer notice must be 'in at least 48-point Arial font'; if national board certification expires the NP 'must immediately begin practicing under standardized procedures'; the Board 'chose not to create additional initials or make any title changes'; the 103 NP certification 'does not automatically provide furnishing authority.'.

The BRN reads "in good standing" through 16 CCR 1482.4 as practice "under a current, active, and unrestricted license," where unrestricted means the applicant was not subject to board discipline including probation, suspension, or public reproval 3Ref 3California Board of Registered Nursing (2026).Assembly Bill 890 — Nurse Practitioners: Scope of Practice: Practice Without Standardized Procedures (program page and frequently asked questions).BRN AB 890 FAQ: the two categories 'do not significantly extend or alter the current NPs scope of practice' but 'do have additional authority to work without standardized procedures'; 'a move to a 103 or 104 NP is not required; it is just an option'; 'an NP that works in a nursing corporation cannot practice as a 103 NP without standardized procedures or physician oversite'; 16 CCR 1482.4 requires three full-time-equivalent years or 4,600 hours of direct patient care in good standing, 'good standing' meaning a 'current, active, and unrestricted license' not subject to probation, suspension or public reproval; DNP doctoral direct-patient-care hours may apply; the posted consumer notice must be 'in at least 48-point Arial font'; if national board certification expires the NP 'must immediately begin practicing under standardized procedures'; the Board 'chose not to create additional initials or make any title changes'; the 103 NP certification 'does not automatically provide furnishing authority.'. The board may, at its discretion, lower the three-year requirement for an applicant holding a Doctor of Nursing Practice degree, based on direct patient care provided during the doctoral portion of that education (BPC §2837.104(b)(3)) 2Ref 2California 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 of the settings or organizations specified under subparagraphs (A) to (F)'; §2837.104(b)(3) requires practice 'as a nurse practitioner in good standing for at least three years, not inclusive of the transition to practice' and permits the board to lower it at its discretion for a DNP; §2837.104(c)(1) limits practice to the NP's education, training, knowledge, experience and national certification; §2837.104(d),(f),(g) carry the patient-notification, posted-notice and liability-insurance duties; §2837.104(h) provides that 'corporations and other artificial legal entities shall have no professional rights, privileges, or powers,' subject to the §2837.104(i) exceptions.3Ref 3California Board of Registered Nursing (2026).Assembly Bill 890 — Nurse Practitioners: Scope of Practice: Practice Without Standardized Procedures (program page and frequently asked questions).BRN AB 890 FAQ: the two categories 'do not significantly extend or alter the current NPs scope of practice' but 'do have additional authority to work without standardized procedures'; 'a move to a 103 or 104 NP is not required; it is just an option'; 'an NP that works in a nursing corporation cannot practice as a 103 NP without standardized procedures or physician oversite'; 16 CCR 1482.4 requires three full-time-equivalent years or 4,600 hours of direct patient care in good standing, 'good standing' meaning a 'current, active, and unrestricted license' not subject to probation, suspension or public reproval; DNP doctoral direct-patient-care hours may apply; the posted consumer notice must be 'in at least 48-point Arial font'; if national board certification expires the NP 'must immediately begin practicing under standardized procedures'; the Board 'chose not to create additional initials or make any title changes'; the 103 NP certification 'does not automatically provide furnishing authority.'.

The hours rule is where most of the surprises live — see the 4,600-hour transition to practice.

Which Certificate Does Your Business Structure Require?

If you are employed by a clinic, hospital, medical group or physician-owned corporation and a physician practices alongside you, the 103 is the certificate that matches your structure. If you intend to own the entity that bills for your care, you are in 104 territory — and in a different body of law.

BPC §2837.104(h) provides that "corporations and other artificial legal entities shall have no professional rights, privileges, or powers," with narrow exceptions in subdivision (i) for an inactive, surrendered, revoked or restricted certificate and for NPs employed under the BPC §2401 exemptions 2Ref 2California 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 of the settings or organizations specified under subparagraphs (A) to (F)'; §2837.104(b)(3) requires practice 'as a nurse practitioner in good standing for at least three years, not inclusive of the transition to practice' and permits the board to lower it at its discretion for a DNP; §2837.104(c)(1) limits practice to the NP's education, training, knowledge, experience and national certification; §2837.104(d),(f),(g) carry the patient-notification, posted-notice and liability-insurance duties; §2837.104(h) provides that 'corporations and other artificial legal entities shall have no professional rights, privileges, or powers,' subject to the §2837.104(i) exceptions.. California's corporate-practice-of-medicine doctrine is not disturbed by AB 890; it sits underneath all of this, and the ownership arithmetic for a nursing corporation is set out on the 104 page.

That is legal information, not legal advice. Before you form an entity or sign an ownership agreement, confirm the structure with a California health-law attorney.

What Stays the Same Under Both Certificates?

More than most comparison charts admit. Under either certificate you must inform all new patients, in a language understandable to the patient, that a nurse practitioner is not a physician and surgeon (BPC §2837.103(d); §2837.104(d)) 1Ref 1California State Legislature (2024).Business and Professions Code § 2837.103 — Nurse practitioners: practice without standardized procedures (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.103(a)(2)(A)–(F) enumerates the six settings (clinic, health facility except correctional treatment center and state hospital, H&S Ch. 2.5 facility, medical group practice/professional medical corporation, home health agency, hospice) in which 'one or more physicians and surgeons practice with the nurse practitioner without standardized procedures'; §2837.103(c) lists the six functions; §2837.103(a)(1)(D) sets the transition to practice at 'a minimum of three full-time equivalent years of practice or 4600 hours' completed 'in California'; §2837.103(d) requires informing new patients that a nurse practitioner is not a physician and surgeon; §2837.103(f) requires the conspicuous BRN notice; §2837.103(h) requires professional liability insurance; §2837.103(i) exempts Department of Corrections and Rehabilitation settings.2Ref 2California 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 of the settings or organizations specified under subparagraphs (A) to (F)'; §2837.104(b)(3) requires practice 'as a nurse practitioner in good standing for at least three years, not inclusive of the transition to practice' and permits the board to lower it at its discretion for a DNP; §2837.104(c)(1) limits practice to the NP's education, training, knowledge, experience and national certification; §2837.104(d),(f),(g) carry the patient-notification, posted-notice and liability-insurance duties; §2837.104(h) provides that 'corporations and other artificial legal entities shall have no professional rights, privileges, or powers,' subject to the §2837.104(i) exceptions.. You must post a conspicuous public notice — the BRN specifies at least 48-point Arial — naming the Board of Registered Nursing with its telephone number and website (BPC §2837.103(f); §2837.104(f)) 1Ref 1California State Legislature (2024).Business and Professions Code § 2837.103 — Nurse practitioners: practice without standardized procedures (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.103(a)(2)(A)–(F) enumerates the six settings (clinic, health facility except correctional treatment center and state hospital, H&S Ch. 2.5 facility, medical group practice/professional medical corporation, home health agency, hospice) in which 'one or more physicians and surgeons practice with the nurse practitioner without standardized procedures'; §2837.103(c) lists the six functions; §2837.103(a)(1)(D) sets the transition to practice at 'a minimum of three full-time equivalent years of practice or 4600 hours' completed 'in California'; §2837.103(d) requires informing new patients that a nurse practitioner is not a physician and surgeon; §2837.103(f) requires the conspicuous BRN notice; §2837.103(h) requires professional liability insurance; §2837.103(i) exempts Department of Corrections and Rehabilitation settings.3Ref 3California Board of Registered Nursing (2026).Assembly Bill 890 — Nurse Practitioners: Scope of Practice: Practice Without Standardized Procedures (program page and frequently asked questions).BRN AB 890 FAQ: the two categories 'do not significantly extend or alter the current NPs scope of practice' but 'do have additional authority to work without standardized procedures'; 'a move to a 103 or 104 NP is not required; it is just an option'; 'an NP that works in a nursing corporation cannot practice as a 103 NP without standardized procedures or physician oversite'; 16 CCR 1482.4 requires three full-time-equivalent years or 4,600 hours of direct patient care in good standing, 'good standing' meaning a 'current, active, and unrestricted license' not subject to probation, suspension or public reproval; DNP doctoral direct-patient-care hours may apply; the posted consumer notice must be 'in at least 48-point Arial font'; if national board certification expires the NP 'must immediately begin practicing under standardized procedures'; the Board 'chose not to create additional initials or make any title changes'; the 103 NP certification 'does not automatically provide furnishing authority.'. You must carry professional liability insurance appropriate to the setting 1Ref 1California State Legislature (2024).Business and Professions Code § 2837.103 — Nurse practitioners: practice without standardized procedures (amended by Stats. 2024, Ch. 481 (SB 1451), effective January 1, 2025).BPC §2837.103(a)(2)(A)–(F) enumerates the six settings (clinic, health facility except correctional treatment center and state hospital, H&S Ch. 2.5 facility, medical group practice/professional medical corporation, home health agency, hospice) in which 'one or more physicians and surgeons practice with the nurse practitioner without standardized procedures'; §2837.103(c) lists the six functions; §2837.103(a)(1)(D) sets the transition to practice at 'a minimum of three full-time equivalent years of practice or 4600 hours' completed 'in California'; §2837.103(d) requires informing new patients that a nurse practitioner is not a physician and surgeon; §2837.103(f) requires the conspicuous BRN notice; §2837.103(h) requires professional liability insurance; §2837.103(i) exempts Department of Corrections and Rehabilitation settings.2Ref 2California 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 of the settings or organizations specified under subparagraphs (A) to (F)'; §2837.104(b)(3) requires practice 'as a nurse practitioner in good standing for at least three years, not inclusive of the transition to practice' and permits the board to lower it at its discretion for a DNP; §2837.104(c)(1) limits practice to the NP's education, training, knowledge, experience and national certification; §2837.104(d),(f),(g) carry the patient-notification, posted-notice and liability-insurance duties; §2837.104(h) provides that 'corporations and other artificial legal entities shall have no professional rights, privileges, or powers,' subject to the §2837.104(i) exceptions..

Your national certification must stay current: if it lapses, the BRN says the NP "must immediately begin practicing under standardized procedures" until it is regained 3Ref 3California Board of Registered Nursing (2026).Assembly Bill 890 — Nurse Practitioners: Scope of Practice: Practice Without Standardized Procedures (program page and frequently asked questions).BRN AB 890 FAQ: the two categories 'do not significantly extend or alter the current NPs scope of practice' but 'do have additional authority to work without standardized procedures'; 'a move to a 103 or 104 NP is not required; it is just an option'; 'an NP that works in a nursing corporation cannot practice as a 103 NP without standardized procedures or physician oversite'; 16 CCR 1482.4 requires three full-time-equivalent years or 4,600 hours of direct patient care in good standing, 'good standing' meaning a 'current, active, and unrestricted license' not subject to probation, suspension or public reproval; DNP doctoral direct-patient-care hours may apply; the posted consumer notice must be 'in at least 48-point Arial font'; if national board certification expires the NP 'must immediately begin practicing under standardized procedures'; the Board 'chose not to create additional initials or make any title changes'; the 103 NP certification 'does not automatically provide furnishing authority.'. Neither certificate creates new initials or a title change 3Ref 3California Board of Registered Nursing (2026).Assembly Bill 890 — Nurse Practitioners: Scope of Practice: Practice Without Standardized Procedures (program page and frequently asked questions).BRN AB 890 FAQ: the two categories 'do not significantly extend or alter the current NPs scope of practice' but 'do have additional authority to work without standardized procedures'; 'a move to a 103 or 104 NP is not required; it is just an option'; 'an NP that works in a nursing corporation cannot practice as a 103 NP without standardized procedures or physician oversite'; 16 CCR 1482.4 requires three full-time-equivalent years or 4,600 hours of direct patient care in good standing, 'good standing' meaning a 'current, active, and unrestricted license' not subject to probation, suspension or public reproval; DNP doctoral direct-patient-care hours may apply; the posted consumer notice must be 'in at least 48-point Arial font'; if national board certification expires the NP 'must immediately begin practicing under standardized procedures'; the Board 'chose not to create additional initials or make any title changes'; the 103 NP certification 'does not automatically provide furnishing authority.'. And neither is compulsory — the BRN is explicit that "a move to a 103 or 104 NP is not required; it is just an option," and that the ability to work under standardized procedures remains either way 3Ref 3California Board of Registered Nursing (2026).Assembly Bill 890 — Nurse Practitioners: Scope of Practice: Practice Without Standardized Procedures (program page and frequently asked questions).BRN AB 890 FAQ: the two categories 'do not significantly extend or alter the current NPs scope of practice' but 'do have additional authority to work without standardized procedures'; 'a move to a 103 or 104 NP is not required; it is just an option'; 'an NP that works in a nursing corporation cannot practice as a 103 NP without standardized procedures or physician oversite'; 16 CCR 1482.4 requires three full-time-equivalent years or 4,600 hours of direct patient care in good standing, 'good standing' meaning a 'current, active, and unrestricted license' not subject to probation, suspension or public reproval; DNP doctoral direct-patient-care hours may apply; the posted consumer notice must be 'in at least 48-point Arial font'; if national board certification expires the NP 'must immediately begin practicing under standardized procedures'; the Board 'chose not to create additional initials or make any title changes'; the 103 NP certification 'does not automatically provide furnishing authority.'. What the 104 sheds is covered in do 104 NPs still need standardized procedures.

How Many California NPs Have Actually Made the Move?

Far fewer than the headlines suggest. The BRN's own 2026 sunset report shows 103 NP certifications issued of 843 in FY 2022/23, 1,030 in FY 2023/24, and 849 in FY 2024/25 — 2,722 across the three fiscal years the board reports 4Ref 4California Board of Registered Nursing (2026).Board of Registered Nursing Sunset Review Report 2026 (Table 7a, Licensing Data by Type: Nurse Practitioner 103).BRN Sunset Review Report 2026, Table 7a (Licensing Data by Type: Nurse Practitioner 103): certification applications received/issued of 2,896/843 in FY 2022/23, 1,837/1,030 in FY 2023/24 and 1,935/849 in FY 2024/25, with 366 applications pending at the close of FY 2024/25; footnote 'NP 103 License not created until January 2023.' The table's 'Application Process Times' columns give average process times for complete 103 NP applications of 35 days (FY 2022/23), 78 days (FY 2023/24) and 35 days (FY 2024/25).. Over the same period the board oversaw approximately 45,838 nurse practitioners, as of the figures published in the 2026 sunset review 5Ref 5California Senate Committee on Business, Professions and Economic Development (2026).Background Paper for the Board of Registered Nursing — Joint Oversight Hearing, Sunset Review 2026 (Issue #7: Transition to Practice).Senate Committee on Business, Professions and Economic Development background paper for the 2026 BRN sunset review: 'Currently, the BRN oversees approximately 3,071 Clinical Nurse Specialists (CNSs), 45,838 Nurse Practitioners (NPs), 3,460 Certified Registered Nurse Anesthetists (CRNAs)…'. Read together, that is on the order of six percent of California NPs holding the entry-level certificate — a rough share drawn from two differently dated tables, not a precise rate.

Applications received outran certificates issued in each of those years — 2,896, 1,837 and 1,935 received, against the issuance counts above, with 366 still pending at the close of FY 2024/25 4Ref 4California Board of Registered Nursing (2026).Board of Registered Nursing Sunset Review Report 2026 (Table 7a, Licensing Data by Type: Nurse Practitioner 103).BRN Sunset Review Report 2026, Table 7a (Licensing Data by Type: Nurse Practitioner 103): certification applications received/issued of 2,896/843 in FY 2022/23, 1,837/1,030 in FY 2023/24 and 1,935/849 in FY 2024/25, with 366 applications pending at the close of FY 2024/25; footnote 'NP 103 License not created until January 2023.' The table's 'Application Process Times' columns give average process times for complete 103 NP applications of 35 days (FY 2022/23), 78 days (FY 2023/24) and 35 days (FY 2024/25).. That gap is a volume signal rather than a delay estimate: the board sets no forward-looking target for either certificate and gives them no Processing Times row, but the same table does publish retrospective averages for the 103 — 35 days in FY 2022/23, 78 in FY 2023/24 and 35 in FY 2024/25 4Ref 4California Board of Registered Nursing (2026).Board of Registered Nursing Sunset Review Report 2026 (Table 7a, Licensing Data by Type: Nurse Practitioner 103).BRN Sunset Review Report 2026, Table 7a (Licensing Data by Type: Nurse Practitioner 103): certification applications received/issued of 2,896/843 in FY 2022/23, 1,837/1,030 in FY 2023/24 and 1,935/849 in FY 2024/25, with 366 applications pending at the close of FY 2024/25; footnote 'NP 103 License not created until January 2023.' The table's 'Application Process Times' columns give average process times for complete 103 NP applications of 35 days (FY 2022/23), 78 days (FY 2023/24) and 35 days (FY 2024/25).. The scarcity has a practical edge: employers, credentialing committees and carriers are still forming their reference points for what these certificates mean, which is one reason credentialing tends to lag the certificate.