Can You Teach the 26+2 Sequence Without Bikram Certification?

Yes. You can teach the 26+2 hot yoga sequence without a certificate from Bikram Choudhury or his organization. A US federal appeals court ruled in 2015 that the sequence is not protected by copyright, so nobody needs permission to teach it.

We know this ruling well, because our name is on it. The case is Bikram's Yoga College of India v. Evolation Yoga, and our co-founders, Mark Drost and Zefea Samson, were the teachers being sued.

This guide explains what the court decided, what it left untouched, and what you need in practice to teach 26+2 with confidence.

Why so many teachers still think they need permission

For about two decades, teaching this sequence came with a warning attached. Bikram Choudhury introduced his teacher training course in 1994 and treated it as the only legitimate route to teaching the 26 postures and two breathing exercises.

In 2002 he registered a copyright claim covering the sequence, and his lawyers began sending cease-and-desist letters to studios that taught it without his authorization. Most studios complied, dropped the class, or rearranged the postures. Very few took the question to court.

That history left a lasting impression. Many teachers and studio owners still assume the sequence is licensed property, and the idea of an "official" certificate still carries weight it does not legally have.

The case that settled it

The question was answered in a lawsuit that ran for more than four years.

• 2002 and 2005: Mark Drost and Zefea Samson each complete the three-month Bikram Yoga Teacher Training course.

• 2009: They found Evolation Yoga, offering several styles of yoga, including a hot class of 26 postures and two breathing exercises.

• July 2011: Choudhury and Bikram's Yoga College of India sue Evolation, Mark and Zefea in federal court in California for copyright infringement.

• 2012: The US Copyright Office states that a selection and arrangement of yoga poses will be refused registration. In December, District Judge Otis Wright rules that the sequence cannot be copyrighted.

• October 8, 2015: The Ninth Circuit Court of Appeals affirms. Judge Kim McLane Wardlaw writes that copyright protects the expression of an idea, not the idea itself, and that the sequence is an idea, process or system.

Choudhury argued that the sequence deserved protection as a compilation or as choreography. The court rejected both arguments. Yoga Alliance filed a brief in support of Evolation, warning that a win for Choudhury would be devastating for the wider yoga community.

If you want to read the decision yourself, it is Bikram's Yoga College of India, L.P. v. Evolation Yoga, LLC, 803 F.3d 1032 (9th Cir. 2015).

What the ruling covers, and what it doesn't

The ruling frees the sequence. It does not free everything connected to it. Three limits matter for working teachers.

Books, scripts and videos are still protected. The court was clear that Choudhury's 1979 book remains under copyright: its words, photographs and drawings. His registered works also include a written teaching dialogue. Teach the postures in the order you like, but write and speak your own instructions instead of copying someone else's text.

The name is a separate question. The decision was about copyright in the sequence. Brand names fall under trademark law, which the ruling did not decide. This is one reason so many studios now list the class under a descriptive name.

It is a US decision. The Ninth Circuit covers the western United States, and the Copyright Office policy applies nationwide. Other countries have their own copyright rules. If you plan to open a studio abroad or build a brand around the sequence, talk to a local lawyer first.

This article is general information, not legal advice.

What you actually need to teach 26+2

Legally, very little. In the United States and most other countries there is no government license for teaching yoga. What you need is whatever studios, insurers and students expect from a competent teacher.

• A recognized 200-hour training. Most studios ask for a 200-hour certificate, usually from a Yoga Alliance Registered Yoga School. Registering with Yoga Alliance is voluntary, but many employers treat it as the baseline.

• Real fluency in the sequence. All 26 postures and both breathing exercises: the setup, the alignment, the common mistakes, and how to adapt each posture for different bodies.

• Heat-specific safety knowledge. A 105°F room changes things. You need to recognize overheating and dehydration, understand water and salt balance, and know when to tell a student to sit down.

• Your own teaching voice. Clear verbal cues that you wrote and practiced yourself, not a script you memorized.

• Liability insurance. Most studios require it from independent teachers.

Notice what is missing from that list: permission.

What to call your class

Use a descriptive name for the class itself. These are the most common:

• 26+2 or 26&2

• Original Hot Yoga

• Hot 26

• Traditional hot yoga

A descriptive name tells students exactly what they are getting: the same 90-minute sequence they can walk into anywhere in the world. Over the past decade many studios have moved away from the Bikram name while continuing to teach the sequence unchanged.

People do still search for "Bikram yoga", so it is common to mention the term in a class description so students can find you. Treat that as explanation, not as your brand.

How to choose a 26+2 teacher training

Since no certificate is legally required, the question changes. It is no longer "which training is official?" but "which training will make me good?" Six things to check:

1. Is the school registered with Yoga Alliance? That is what makes you eligible to register as an RYT 200.

2. Does it teach understanding or memorization? You should learn why each posture is taught the way it is, including the anatomy and alignment behind it.

3. How big is the group? You need hours of practice teaching with individual feedback, which is hard to get in a very large group.

4. Will you learn anything beyond 26+2? Teachers who can also lead flow or yin have more classes open to them.

5. Does the format fit your life? Intensive in-person, self-paced online and hybrid routes all exist.

6. What happens after graduation? Ask about mentoring, repeat attendance and help finding teaching work.

At Evolation, our hot yoga teacher training is built around the 26+2 sequence and registered with Yoga Alliance at the 200 and 300-hour levels. Groups are small, you can train in person or online, and graduates can come back to the same training again at no cost. New to the idea? Start with what hot yoga teacher training involves.

Frequently asked questions

Is the Bikram yoga sequence copyrighted?

No. In 2015 the Ninth Circuit Court of Appeals ruled that the sequence of 26 postures and two breathing exercises is an idea, process or system, which copyright law does not protect. Books, scripts and videos that describe the sequence are still protected.

Do I need Bikram certification to teach 26+2?

No. There is no legal requirement to hold a certificate from Bikram Choudhury or his organization. Most studios look for a 200-hour certificate from a Yoga Alliance Registered Yoga School and solid knowledge of the sequence.

Can I call my class Bikram yoga?

The 2015 ruling covered copyright in the sequence, not use of the name, which is a trademark question. Most studios use descriptive names such as 26+2 or Original Hot Yoga. Ask a lawyer before building a brand on the name.

Can I change the sequence?

Yes. Nobody owns it, so you can teach it as it is, shorten it, or adapt postures for your students. Many studios offer a 60-minute version alongside the full 90 minutes.

Can I learn to teach 26+2 online?

Yes. Yoga Alliance allows registered schools to deliver teacher training online. You can complete a 200-hour hot yoga training remotely and practice the sequence in a heated space at home or at a local studio.

Train with the teachers who kept the sequence free

We have taught 26+2 since 2009, and we spent more than four years in court so that every teacher could do the same. If you want to teach this sequence well, we would love to train you.

See the hot yoga teacher training, check the upcoming dates, or start from home with the online 200-hour course.

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Can You Teach 26+2 Without Bikram Certification?

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Yes. A 2015 federal court ruling made the 26+2 hot yoga sequence free to teach. The school that won the case explains what you need to start.

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teach 26+2 without Bikram certification

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is the Bikram sequence copyrighted; do I need Bikram certification; 26 and 2 teacher training; can I call my class Bikram yoga

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Teacher leading a 26+2 hot yoga class at Evolation Yoga

Three things to check before publishing:

• Confirm the Evolation details in the training checklist section are current: RYS 200 and 300, small groups, in person and online, free return to the same training.

• Add the five FAQ questions as FAQ schema if your page template supports it.

• Link to this post from the hot yoga teacher training page, so the link runs both ways.

I had no keyword tool available, so search volumes for these phrases are not verified. The topic was chosen because Evolation is a named party in the case, which no competing school can claim.

Sources

• Ninth Circuit opinion, Bikram's Yoga College of India v. Evolation Yoga, October 8, 2015: training and founding dates, filing date, Copyright Office policy statement, holdings.

• Courthouse News, December 20, 2012: District Judge Otis Wright's ruling.

• National Law Review, "Hold That Pose": district court ruling date and the Yoga Alliance brief.

• Evolation Yoga blog: existing posts and internal link targets.