New York does two things differently from almost every other state. Dental licensure runs through the State Education Department's Office of the Professions rather than a freestanding health board, and dentists hold a permanent license with a separate triennial registration. On the equipment side, the Department of Health is explicit that x-ray registrations cannot be transferred between owners, which makes a practice sale a two-form event rather than a name change.
Key takeaways
- Dentists must complete 60 contact hours of continuing education per three-year registration period, with at least 42 hours in live, instructor-interactive courses and up to 18 in self-study.
- Mandated coursework includes a one-time 2 hour course on the oral health effects of tobacco, a one-time 3 hour course in dental jurisprudence and ethics, CPR certification maintained continuously since January 1, 2009, and an infection control course every four years. Child abuse identification and reporting coursework is required for licensure.
- X-ray registrations are not transferable between owners. The selling owner submits a disposition form and returns the original certificate, and the buyer registers as a new facility. Until the disposition form is received, the installation stays active in the seller's name.
- Dental hygienists and dental assistants may perform dental radiographs. The Department of Health's December 2024 guidance identifies them as an exception to the general prohibition on unlicensed personnel operating x-ray equipment.
Rules change. Everything below was checked against an official New York or federal source in September 2026. Fees, coursework requirements and statutes change, and New York City operates its own radiation permit program. Confirm with the agency before acting.
Who regulates what
| Topic | Agency | Official link |
|---|---|---|
| Dentist, hygienist and registered dental assistant licensure | New York State Education Department, Office of the Professions | NYSED Office of the Professions, Dentistry |
| Dentist continuing education | NYSED Office of the Professions | Dentist continuing education Q and A |
| Dental hygiene and dental assisting scope | NYSED, Education Law Article 133 and Commissioner's Regulations Part 61 | Education Law Article 133 |
| X-ray equipment registration (outside NYC) | New York State Department of Health, Bureau of Environmental Radiation Protection | Radiation producing (x-ray) equipment registration |
| Registration questions and disposition forms | NYSDOH Bureau of Environmental Radiation Protection | Radiation equipment registration FAQ |
| X-ray equipment permits inside New York City | New York City Department of Health and Mental Hygiene | NYC Health, radiological equipment |
| Radiographic operator requirements | NYSDOH (dental hygienists and dental assistants may perform dental radiographs) | NYSDOH guidance on unlicensed operators of x-ray equipment |
| Infection control in the dental office | NYSED mandated infection control training (plus federal OSHA) | Mandated infection control training |
| Amalgam separators and dental wastewater | US EPA rule, enforced through your local pretreatment control authority | EPA Dental Effluent Guidelines |
| Corporate practice and practice ownership | NYSED Office of the Professions plus entity filings with the New York Department of State | Dentistry laws, rules and regulations |
| Sales and use tax on equipment | New York State Department of Taxation and Finance | NYS Department of Taxation and Finance |
License renewal and continuing education
New York separates the license from the registration. The license is permanent once granted, and you maintain a triennial registration in order to practice. The CE requirement is tied to that three-year registration period.
What the Office of the Professions publishes for dentists:
- 60 contact hours per three-year registration period. The current 60-hour requirement began July 1, 2008.
- At least 42 of the 60 hours must be completed through live courses, meaning interactive with an instructor. The remaining 18 may be self-study.
- Tobacco: a one-time 2 hour course on the oral health effects of tobacco and tobacco products.
- Jurisprudence and ethics: a one-time 3 hour course in dental jurisprudence and ethics, which must have been taken on or after January 1, 2008.
- CPR: certification maintained continuously beginning January 1, 2009.
- Infection control: a course every four years, which runs on a different clock than your three-year registration.
Two additional mandated trainings attach to licensure rather than to CE. Every applicant for dental licensure or a limited permit must complete coursework or training in the identification and reporting of child abuse, and dentists must complete approved coursework or training in infection control and barrier precautions appropriate to their practice. NYSED publishes lists of approved providers for both. There is also a Department of Health mandatory prescriber education requirement, which NYSED links from its dentist pages.
The 42-hour live minimum is the constraint that most often bites. If you buy a large block of online self-study to catch up in year three, most of it will not count. Build live courses into years one and two.
X-ray equipment: registration and inspection
Outside New York City, the Bureau of Environmental Radiation Protection inside the State Department of Health registers x-ray equipment. Inside New York City, the city Department of Health and Mental Hygiene runs its own radiation-producing equipment permit program. Check which applies before you file anything.
What the state bureau publishes:
- Opening a facility: contact the bureau two weeks before the first day of operation with the business name, radiation safety officer, address, equipment type and opening date.
- Transfers: registrations cannot be transferred between owners. The original owner submits a disposition form and returns the certificate, and the new owner registers separately as a new facility.
- Closing or disposing: a completed disposition form and the original certificate must be returned. The installation remains active until the bureau receives the completed disposition form.
- Billing and renewal: billing is annual, and renewal certification happens on a two-year basis. Certificates are mailed after payment processing.
- Inspection frequency: dentists and podiatrists every five years, veterinary facilities every three years. New or moved equipment requires an inspection.
- Yellow stickers on the equipment indicate when a machine was last inspected, which is a quick visual check during a walkthrough.
That last point is a useful due diligence trick. When you tour a practice you are considering buying, look for the inspection stickers on each tube head and read the dates. It takes ten seconds and tells you something the seller's broker will not.
Who may take radiographs
New York generally restricts operation of x-ray equipment to licensed practitioners and licensed radiologic technologists, and its December 2024 guidance letter to registrants is blunt about it: nurses, physician assistants, medical assistants and respiratory therapists may not position patients, set techniques or expose them to radiation unless they hold radiologic technologist licensure. Permitting, aiding or abetting an unlicensed person to perform activities requiring a license is described as a misdemeanor.
Dental settings are an explicit exception. The guidance permits dental hygienists and dental assistants to perform dental radiographs. The bureau asks that the letter be posted in a conspicuous location.
What we could not confirm is whether a New York dental assistant needs a specific radiography credential or completed course before doing so, and how that interacts with the registered dental assistant credential issued by NYSED. Confirm with both NYSED and the Bureau of Environmental Radiation Protection before assigning radiography duties.
For the general mechanics, see dental x-ray registration and inspections.
Buying and selling used equipment in New York
Registration does not transfer, and it stays open until you close it
This is the New York-specific item worth a calendar reminder. When a practice changes hands, two filings happen: the seller files a disposition form and returns the original certificate, and the buyer registers as a new facility. Neither one happens automatically, and the bureau is explicit that the installation remains active until it receives the completed disposition form.
For a seller, that means an unfiled form leaves you on the hook as the registrant of record for equipment in a building you no longer own. For a buyer, it means you cannot rely on inheriting the seller's registration and should start your own well before your first patient. Two weeks of lead time before the first day of operation is the bureau's own stated expectation.
The same logic applies to a single machine. Sell a used pan to a colleague across the county and the disposition paperwork matters. Buy one and it is new equipment at your facility, which triggers an inspection requirement for new or moved equipment.
Put both filings in the closing checklist. Our practice acquisition due diligence checklist is the right place for it, alongside the inspection sticker check.
Amalgam separators and wastewater
The federal EPA dental rule at 40 CFR Part 441 applies. If you place or remove amalgam and discharge to a publicly owned treatment works, you need a compliant amalgam separator, you follow the best management practices (no flushing scrap amalgam, no bleach or other oxidizing line cleaners), and you file a one-time compliance report with your pretreatment control authority. In New York that is often a city or county water and sewer authority, and in New York City the Department of Environmental Protection.
New York has had dental amalgam requirements at the state and city level historically, so expect local requirements that are at least as detailed as the federal rule. Call your control authority at the point of sale and ask what the incoming owner must file. See amalgam separators.
Lead, chemicals and decommissioning
Spent fixer and developer, lead foil, failed aprons and lead-lined panels all go through a licensed waste vendor with a manifest. See dental waste disposal for the streams and disconnecting dental equipment safely for the physical removal. Before you commit to a used imaging purchase, run the pre-purchase equipment checklist.
Non-competes and employment
We could not confirm a New York statute that bans or specifically limits dentist non-compete agreements. New York has repeatedly considered broad non-compete legislation in recent sessions without a general ban taking effect, so the operative law remains judge-made.
The general landscape: New York courts apply a reasonableness test, asking whether the restraint is no greater than required to protect a legitimate interest of the employer, whether it imposes undue hardship on the employee, and whether it injures the public. New York has historically taken a relatively narrow view of what counts as a protectable interest in a professional services context, focusing on unique or extraordinary services, trade secrets and confidential client information. Courts also have discretion to narrow an overbroad covenant rather than voiding it.
For a New York associate contract, the practical questions are the same as anywhere: the radius, whether it floats with new locations, the length of the tail, whether it survives a without-cause termination, and whether there is a buyout figure you could realistically pay. Because the law here comes from decisions rather than a statute you can read, this is a conversation to have with a New York employment attorney who works with health care employers, not something to settle from a summary.
The federal question is settled. The FTC's non-compete rule is not in effect. The Commission voted on September 5, 2025 to dismiss its appeals and accede to the vacatur of the rule, so New York law governs. See non-compete agreements for dentists and the associate contract review checklist.
What we could not confirm
- Whether a New York dental assistant needs a specific radiography credential or completed course before exposing dental radiographs, and how it relates to the registered dental assistant credential.
- New York State x-ray registration fee amounts.
- How the New York City permit program differs in practice from the state registration program. If you practice in the five boroughs, confirm directly with NYC Health.
- New York dental hygienist CE hours. Confirm from the Office of the Professions hygienist pages.
- Whether New York restricts dentist non-competes by statute. We found no general ban in effect.
- Sales and use tax treatment of dental equipment in New York, including private-party purchases. Confirm with the Department of Taxation and Finance and your CPA.
- New York's limits on non-dentist ownership of a dental practice. Professional entity rules are involved. Confirm with a New York dental attorney.
Where to verify
- NYSED Office of the Professions: Dentistry, dentist continuing education Q and A, dentist license requirements, and mandated infection control training
- New York State Department of Health: radiation producing equipment registration, the registration FAQ, and the December 2024 guidance on unlicensed operators
- New York City Department of Health and Mental Hygiene: radiological equipment permits
- US Environmental Protection Agency: dental effluent guidelines, 40 CFR Part 441
- Federal Trade Commission: September 2025 statement on the non-compete rule
- New York State Department of Taxation and Finance: tax.ny.gov
Putting it to work
Two New York habits. Build CE around the 42-hour live minimum from the start of the registration period, and track the four-year infection control course on its own calendar because it will not line up with your triennial. On the equipment side, treat every ownership change and every machine that leaves the building as a disposition form, and confirm the bureau received it, because in New York the registration stays open until it does.
Related reading: x-ray registration and inspections, the compliance chapter, the due diligence checklist, and the rest of the state resources directory.
This guide is educational content and does not constitute legal, financial, tax, or clinical advice. Laws and regulations vary by state and change over time. Consult your own dental-specific attorney, CPA, and state dental board before acting.