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Where this applies
California (state licensing law and the Board of Behavioral Sciences). Other states have their own rules.
Facts checked
Who it’s for

Undocumented students and graduates working toward an LMFT, LCSW or LPCC license in California, plus DACA recipients and the professors, supervisors and advisors who help them. The steps apply to everyone; the status notes are for people without a work permit.

On this page

Take the next step

This page covers the path to a California therapist license. For other licenses, see Can I get a professional license in California without a Social Security number? This is general information, not legal advice.

Can I get a therapist license without papers?

Yes. Since January 1, 2016, no board in the California Department of Consumer Affairs may deny you a license because of your citizenship or immigration status (Business and Professions Code 135.5). The Board of Behavioral Sciences (BBS) is one of those boards. It licenses marriage and family therapists (LMFT), clinical social workers (LCSW), professional clinical counselors (LPCC) and educational psychologists (LEP).

You give the Board either an ITIN or a Social Security number. The Board may not make you tell it your status, and may not deny you only because of it (Business and Professions Code 30). If you get a Social Security number later, for example through DACA or a green card, update your Board record.

A license is not a work permit. An employer that hires you as an employee must still check your papers on Form I-9. What a license does is let you work in your own practice once you are fully licensed. See How to earn money working for yourself.

What are the steps?

Every path has the same shape. The Board lists them for LMFT on its LMFT applicant page:

  1. Finish a qualifying master's degree, including practicum (supervised work as a trainee while in school).
  2. Register as an associate (AMFT, ASW or APCC) and send fingerprints by Live Scan. The Board runs a state and FBI background check.
  3. Take the California Law and Ethics Exam. You must take it each year to renew your associate registration until you pass, and you must pass it to get a later registration.
  4. Gain 3,000 supervised hours over at least 104 weeks, with a qualified supervisor.
  5. Apply to take the clinical exam and pass it. LMFT applicants take the California MFT Clinical Exam through Pearson VUE. LCSW applicants take the national ASWB Clinical Exam.
  6. Ask for your license and pay the initial fee within one year of passing the clinical exam.
  7. Renew every two years and keep up your continuing education.

What do I need before I graduate?

Your status does not keep you out of a graduate program. California's in state tuition law (AB 540) covers graduate study too. See How to apply to graduate school as an undocumented student and Paying for college in California, whatever your status.

While you are in school:

  • Get an ITIN if you do not have a Social Security number. You will need one for the Board. See About the ITIN (IRS).
  • Ask your program about practicum sites that take unpaid trainees. Trainees may not work in a private practice or a professional corporation (Business and Professions Code 4980.43.3).
  • Check your coursework. California requires some topics, such as human sexuality, abuse reporting and aging. If your program missed one, you can take it later at an approved school.
  • Talk with an immigration attorney before fingerprinting if you have ever been arrested or have any immigration case. See Free legal help in the Bay Area.

How many hours do I need?

Hours must be gained within the six years before the Board gets your license application, so plan to finish on time.

License Total Time Key minimums
LMFT 3,000 hours At least 104 weeks 1,750 hours of direct counseling, including 500 with couples, families and children; up to 1,250 nonclinical hours (4980.43)
LCSW 3,000 hours At least 104 weeks 2,000 hours of clinical diagnosis, assessment and treatment, including 750 face to face therapy hours; 1,700 hours under an LCSW (4996.23)
LPCC 3,000 hours At least 104 weeks 1,750 hours of direct counseling (4999.46)

No more than 40 hours count in any seven days. Check the latest Board handbook for your license before you plan your hours, because the details matter.

How do I get hours without a work permit?

This is the step where most undocumented associates get stuck. Be clear on the rule first.

California law says an associate may provide mental health services only as an employee or a volunteer, never as an independent contractor. The rule is the same for MFT, social work and counselor associates (4980.43.3, 4996.23.2, 4999.46.3). When you apply:

  • Employees send W-2 forms for each year of hours.
  • Volunteers send a letter from the employer confirming volunteer status for those dates.

So you cannot take a 1099 contract job to earn hours. Without a work permit, an employer cannot legally hire you as an employee either. That leaves volunteer positions, usually at nonprofits, clinics and community agencies.

Two things to watch:

  • Payment beyond expenses changes your status. If you get only reimbursement for expenses you actually paid, the Board treats you as an employee, and you must be able to prove the money only covered real costs (4980.43.3(g)). Ask the agency in writing how it handles stipends before you start.
  • Private practice has limits. An associate applicant may not work or volunteer in a private practice until the Board issues the associate registration.

Where people look: the agency where they did practicum, community clinics that serve immigrants, school based programs and nonprofits with their own licensed supervisors. Ask your graduate program's field placement office and your campus undocumented student center for sites that have taken undocumented associates before.

How do I protect the hours I earn?

Hours are easy to lose. Guard them from day one:

  • Check your supervisor. Each supervisor needs an active California license and the Board's supervisor training. Look them up on the DCA license search. Hours under an unqualified supervisor can be thrown out.
  • Sign a supervision agreement before you start counting hours.
  • Log as you go, every week, with dates, settings and type of hour. Do not rebuild a log months later.
  • Get your volunteer letter from each site before you leave it, while your supervisor is still there.
  • Renew your registration on time. An associate registration renews each year.
  • Get malpractice insurance. Many sites require it.

What does it cost?

The Board cut most of its fees in half from July 1, 2026 through June 30, 2030 (approved fee change, OAL notice February 4, 2026):

Fee Before July 1, 2026 Now
Associate registration application $150 $75
Associate registration yearly renewal $150 $75
California Law and Ethics Exam $150 $75
MFT clinical exam $250 $125
Application for licensure $250 $125
Initial license $200 $100
License renewal, every two years $200 $100

The ASWB exam for LCSW applicants has its own fee, paid to ASWB. Live Scan sites also charge a fee. Add prep courses, malpractice insurance and any missing classes.

What if I have DACA?

With DACA and a valid work permit, you can be hired as a paid employee and gain hours like anyone else. Keep your work permit current, because an employer must reverify it when it expires. Give the Board your new Social Security number. If your DACA could lapse during your hours, plan a backup volunteer site. See What happens to my job if my DACA work permit ends?

What happens after I am licensed?

You can practice on your own once your license shows as active in the Board's lookup. Do not see clients without supervision before that. A licensed therapist without a work permit can work for themselves, for example in their own practice as a sole owner or LLC, paying taxes with an ITIN. See Can I start a business without a Social Security number? and How to pay taxes on self employment income with an ITIN.

Plan for insurance billing early. Each insurance plan and Medi-Cal sets its own provider enrollment rules, including which ID numbers it accepts. Before you build a practice around billing, ask each plan you want to join, and check Medi-Cal's provider enrollment portal (DHCS PAVE).

Questions people ask

Will the Board report me to immigration? The law bars the Board from making you disclose your status. It does let the state tax agency and EDD ask a board for licensees' ITIN or Social Security numbers.

Can I count hours from before I registered? Generally no. Postdegree hours count only after you register as an associate, with a limited 90 day rule. Read the LMFT page or your license's handbook.

I failed the law and ethics exam. What now? You can renew your associate registration as long as you take the exam each year. You must pass it to get a later registration.

Can I get licensed in another state later? Each state has its own rules on status. Check that state's board first.

Who can help?

Contact them to confirm hours, languages and openings. Being listed here is not a referral or a promise of service.

  • Board of Behavioral Sciences: questions about your file, fees and hours. bbs.ca.gov
  • Department of Consumer Affairs: (800) 952-5210. Boards and bureaus
  • Immigrants Rising: free licensure checklist and guides for undocumented professionals. immigrantsrising.org
  • Your graduate program and campus undocumented student center: practicum and associate site lists.
  • Free immigration legal help before you fingerprint: Free legal help in the Bay Area

Is there a checklist I can print?

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