Non-Surgical Cosmetic Procedures - Ripe for Regulation?

The cosmetics industry is booming, and the non-surgical cosmetic options are no exception; treatments such as Botox, dermal fillers, laser hair removal and chemical peels are increasingly accessible and enormously popular.

According to the British Beauty Council, the cosmetics and personal care sector contributed £24.5 billion to UK GDP in 2022.  A British College of Aesthetic Medicine study found that in 2023, 7.7 million people in the UK underwent an aesthetic treatment including a reported 900,000 Botox injections.

To date, there has been no mandatory requirement for practitioners to have specific qualifications or to undertake training before carrying out these procedures; as such, anyone can perform non-surgical procedures in England. This, coupled with the rapid growth in their use, has seen a rise in reports of supposedly ‘botched’ or unsafe procedures.

There are numerous accounts of procedures taking place in Airbnbs, hotel rooms and even garden sheds, along with high rates of adverse outcomes, including infection, necrosis and severe disfigurement.

A number of investigations and reports have been produced looking into these issues; the All-Party Parliamentary Group on Beauty, Aesthetics and Wellbeing 2021 Inquiry, for example, found that ‘There is a need for the beauty industry and the medical professions to work together to seek solutions that raise standards and protect the safety and wellbeing of consumers.’ 

Recommendations have therefore been made to regulate and standardise the industry by introducing minimum education and training requirements, as well as centralised registration. 

In April 2022, the Health and Care Act (section 180) gave the Secretary of State for Health and Social Care the power to establish a licensing scheme for non-surgical cosmetic procedures for England and Wales with a view to ensuring that consumers who choose to undergo such procedures can be confident that the treatment is safe and will be performed to a high standard. However, the question still remained as to what changes were going to be put in place and when.

DHSC Consultation – what is changing?

A consultation was held in 2023 by the Department of Health and Social Care regarding the design of the scheme, and the Department responded in August 2025 with details of their proposals for mandatory training, the need for appropriate indemnity insurance and that premises meet the correct standards of hygiene. In addition, a traffic light system has been proposed as follows;

• Green procedures - low risk e.g. micro needling, intense pulsed light

It is proposed that these procedures could be carried out by any licensed practitioner who meets agreed standards. The practitioner must be licensed personally, not just operating under a general license for a business and various checks are made before licenses are issued.

• Amber procedures - medium risk , e.g. Botox, semi-permanent dermal fillers

The consultation proposes that these could be carried out by non-healthcare practitioners, but only under the oversight of a named, regulated healthcare professional who has gained an accredited qualification to prescribe, administer, and supervise cosmetic procedures. What was previously a “gold” standard is now a required standard, requiring more intensive training and therefore restricting who can give injectables.

Qualified healthcare professionals would be able to carry out the procedures independently if they meet the required standards. 

It is proposed that the green and amber schemes be administered by local authorities and fall within the scope of the new licensing scheme.

• Red procedures - higher risk, e.g. BBLs, thread lifting procedures, chemical peels

The consultation proposes that these procedures would be limited to suitably qualified and regulated healthcare professionals who would fall under the Care Quality Commission (CQC) regulation, meaning they could only be performed at CQC-registered premises. These activities would fall outside the scope of the new licensing scheme, unlike the green and amber procedures. 

All procedures would also be restricted to those aged 18 and over, except with medical oversight. 

Landscape

Regulation of this rapidly growing industry is underway and certainly a welcome development, though the timescale for its implementation is unknown. However, given the speed at which the Scottish Parliament recently passed its own legislation in March 2026, it is thought that the scheme will be formalised within the next 12 months. However, there may be, like in Scotland, a transition period to allow practitioners time to prepare.  

It is hoped that the specific training requirements and need for indemnity insurance will not only enhance patient safety but will improve outcomes and reduce the likelihood of claims arising from so-called ‘botched’ procedures. 

Providers of these services will need to ensure they have the correct staff with the proper training, premises and indemnity insurance to avoid falling foul of any new regulations. 

How can we help?

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