Injecting Change: Tighter Rules for Non-Surgical Aesthetics

The use of non-surgical cosmetic procedures, such as Botox and dermal fillers, is on the rise as they become more accessible via high street providers and aesthetic clinics.

Background issues

There are few restrictions on who can actually perform these procedures, with the onus typically instead on the doctor/nurse who is prescribing the treatment having appropriately assessed the patient and confirming it is safe to go ahead. 

However, as with any system, it has been open to exploitation, and in recent years a number of doctors/nurses have been caught signing off on remote prescriptions without speaking to the patient, relying instead on the consultations carried out by those administering the treatment, who typically have no medical training. 

This, of course, led to serious concerns about patient safety in this extremely popular, but largely unregulated industry. In an effort to understand the public’s perceptions of remote prescribing and the impact that potential changes to the regulations may have on those administering and receiving non-surgical cosmetic medicines, in 2024, the NMC commissioned independent public-facing research by the agency ‘Thinks’. The NMC has shared the findings of the research, which found that many people who had undergone non-surgical cosmetic procedures had not fully considered how the medicine was obtained when the person administering or injecting it was not a healthcare professional, nor did they realise that it was a prescribed medicine. The research also found that many people perceived these types of procedures to be overly accessible, taking place within unregulated environments and they were unsure whether those administering or injecting medicines had sufficient training.

The changes

What is going to change as a result of this research? Effective from 1 June 2025, in an effort to enhance patient safety, the NMC require all nurses and midwife practitioners eligible to prescribe prescription-only medicines to conduct a face-to-face consultation and document an appropriate clinical assessment of the patient before they prescribe any products used for any elective non-surgical cosmetic procedures.  The NMC has updated its "useful information for prescribers" guidance to reflect their new expectations. This applies not only to the initial consultation, but also to any follow-up appointments. It will also be mandatory for any nursing or midwifery professional to refuse to supply or administer any medicinal product if they have concerns that the prescribing has not been carried out appropriately.

Potential impact

The potential impact is wide reaching; 

• beauty clinics and studios may have to review their protocols and potentially adjust their practices and setups to meet these new requirements, possibly even having to expand their current spaces to allow for the face-to-face consultations to take place;
• insurers who were not previously minded to extend cover to prescription consultations due to the potential risks associated with the same, may now have more of an appetite to do so; but
• it may also be that we see a decline in these types of clinical negligence claims as the consultation and consenting process becomes more thorough, allowing additional symptoms or risk factors that may not have been picked up on paper, to be identified and addressed in any proposed treatment plan.  

Whilst the NMC’s requirements do not apply to non-registered practitioners, some were involved in the consultation, and it is hoped that they will adopt the same standards and thereby widening the reach of these changes. Ultimately, the potential impact remains to be seen but with patient safety at the forefront, it is hoped that it is a positive one.

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