Regulating beauty: What the government’s consultation means for non-surgical procedures
1. Introduction
Non-surgical cosmetic procedures are experiencing growing popularity across all age groups and are becoming increasingly accessible to the public. This beauty trend is encouraged by social media and influencers, but also by the rapid development of technologies and products. There is also a category of consumers who request non-surgical cosmetic procedures for medical purposes or to improve their life quality.
Consumers are seeking beauty, longevity and health, whereas businesses are competing on a mostly unregulated market to provide solutions to those demands. In this landscape, the UK Government needs to strike the balance between improving the safety of cosmetic procedures and encouraging innovation. In October 2023, we discussed here about the UK Government’s launch of the first consultation on a licensing scheme for non-surgical cosmetic procedures. On 7 August 2025, the UK Government published the consultation outcome, which is examined in greater detail in this article.
1.1. Consultation Outcomes and Demographic Analysis
The UK Government’s consultation on licensing non-surgical cosmetic procedures drew 11,848 responses, reflecting strong public and professional interest. Over half (55%) came from professionals, 41% from individuals sharing personal experiences, and 4% from businesses.
Among the 6,482 professionals who responded, aesthetic practitioners—such as beauticians and cosmetologists—made up the largest group (44%), followed by registered nurses (24%), medical practitioners (10%), dental professionals (6%), and business owners (4%). Notably, 82% of professional respondents actively provide non-surgical cosmetic treatments, and 37% of healthcare professionals are currently working in the cosmetic sector.
The majority of respondents (60%) were aged 25 to 44, indicating strong engagement from working-age individuals. Across all age groups, a high proportion reported having undergone non-surgical cosmetic procedures—ranging from 82–83% among those aged 16 to 54, to over 70% among older adults.
These findings highlight the widespread use of aesthetic treatments across demographics and underscore the importance of a robust licensing framework to ensure consistent standards, safety, and accountability in the beauty industry.
2. Identifying the Risky Procedures
The UK Government acknowledges that all cosmetic procedures bear a risk and that a certain flexibility of this licensing scheme ensures its functionality in the long run, in this rapidly-evolving industry. That is why the high-risk procedures are at the forefront of this initiative.
The definition of “Cosmetic Procedure” provided by the Health Care Act 2022 (the “2022 Act”) is used as a starting point for categorising various procedures. A “Cosmetic Procedure”, as defined under the 2022 Act, represents any non-surgical and non-dental intervention performed for cosmetic purposes. This includes a range of techniques such as injecting substances, applying substances that penetrate the skin, inserting needles or threads into or under the skin, and using treatments involving light, electricity, cold, or heat. However, the proposed licensing scheme aims to be narrower, focusing particularly on high-risk, invasive procedures, at least initially.
Depending on the varying degrees of risk and complications associated with the procedures, the UK Government proposes the following tiered licensing framework to enhance patient safety and practitioner accountability:
- Green for low-risk treatments that may be performed by any licensed practitioner who meets agreed standards. A non-exhaustive list of those procedures includes: microneedling, mesotherapy, intense pulsed light (IPL) and light emitting diode (LED) therapies, chemical peels of the outer most layer of the skin, “no-needle” fillers using pneumatic devices, semi-permanent make up, non-ablative laser hair removal, photo rejuvenation, just to name a few.
- Amber for medium-risk procedures that require non-healthcare professionals to be licensed and to operate under the oversight of a named regulated healthcare professional. Qualified and regulated healthcare professionals that meet agreed standards may perform these procedures without oversight. Examples of the medium-risk procedures are: botulinum toxin injections (i.e. Botox), semi-permanent dermal fillers injected into the face only, biorevitalization injections and/or any injections of hyaluronic acid, platelet rich plasma (“PRP”), spider vein treatment, weight loss injections, injection lipolysis and cryolipolysis, high intensity focused ultrasound (“HIFU”), radiofrequency treatments, medium depth peels targeting the inner layer of the skin, etc. Interestingly, the amber category also catches the combination of two or more technologies that create a hybrid device, such as microneedling (which on its own falls under the green category) combined with radiofrequency.
- Red for high-risk procedures that will be regulated by the Care Quality Commission (“CQC”) and restricted to qualified, regulated healthcare professionals only. Such high-risk procedures include but are not limited to: procedures that augment any part of the body (such as Brazilian Butt Lifts or BBL), all thread lifting procedures, hay fever injections, liposuction performed with ultrasound and large bore cannula, deeper chemical peels such as phenol peels, lasers used for extensive fully ablative resurfacing such as CO2 lasers, all intravenous injectables and infusions.
2.1. Reactions to Classification and Restriction
According to over 60% of the total number of respondents to the Government’s consultation on the licensing scheme, a three-tier classification is needed and the high-risk procedures should be restricted to qualified and regulated healthcare professionals only.
Unsurprisingly, regarding the restriction of high-risk procedures to healthcare professionals, 63% of individuals sharing personal views supported this initiative. Among professionals, 62% supported the restriction, though aesthetic practitioners were notably divided: 47% strongly disagreed, while only 31% agreed. In contrast, the majority of healthcare professionals working in cosmetics (82%) and healthcare professionals not working in cosmetics (89%) strongly agreed with the proposal, reflecting a clear preference among medically trained respondents for tighter regulation.
Responses from organisations and policy professionals also leaned heavily in favour of the restriction, reinforcing the broader consensus that high-risk procedures should be reserved for those with appropriate medical qualifications.
3. Oversight and Standards in the Beauty Sector
Regulated healthcare professionals—such as doctors, nurses, dentists, and pharmacists—are subject to statutory oversight by bodies like the General Medical Council (“GMC”). While the regulators do not set specific standards for aesthetic procedures, they require registrants to demonstrate the necessary skills and knowledge and to comply with relevant guidance and legislation.
Also, the Regulated Activity of Surgical Procedures applies to surgical procedures performed by a healthcare professional for medical, religious or cosmetic purposes.
The CQC serves as the independent regulator of health and social care services in England. Its statutory responsibilities include registering and overseeing providers that deliver one or more regulated activities, as defined under the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. These activities encompass a broad range of services, including personal care, nursing care, treatment for disease or injury, mental health services, surgical procedures, diagnostic and screening services, maternity and midwifery care, termination of pregnancies, and services provided in slimming clinics, among others. In instances of substandard care, CQC is empowered to take enforcement action against healthcare professionals, with the most serious measures including the issuance of penalty notices and the initiation of legal proceedings.
By contrast, non-healthcare practitioners are not subject to mandatory training requirements and are under no legal obligation to join industry associations or to register with bodies accredited by the Professional Standards Authority.
To address this gap, National Occupational Standards (“NOS”) have been developed by SkillsActive and the Hair and Beauty Industry Authority, in collaboration with stakeholders. These standards aim to establish consistent benchmarks for competence and safety in non-surgical cosmetic procedures. However, in the absence of a statutory requirement, practitioners are not currently obliged to meet NOS criteria in order to perform aesthetic treatments.
3.1. Practical Implications of the Licensing Scheme
Under the new licensing scheme, high-risk cosmetic procedures—within the red category—shall exclusively be performed by regulated healthcare professionals. Also, medium-risk cosmetic procedures—within the amber category— shall be performed by regulated healthcare professionals or by licensed non-healthcare professionals operating under the oversight of a named regulated healthcare professional.
This licensing scheme raises important practical implications, some of which are examined in this section.
- Ambiguity in Oversight Responsibilities
Regarding the amber category, the requirement for non-healthcare professionals to operate under the oversight of a named regulated healthcare professional lacks clarity on the scope, duration, and legal accountability. It remains uncertain how that “oversight” will be enforced and how it must be performed.
Do the non-healthcare professional and the named regulated healthcare professional have to operate on the same premises, during the same work hours?
Will the supervising professional bear liability for complications or misconduct?
Hopefully, those questions will be addressed by the Government, with the stakeholders' involvement, in the next phase of regulatory development.
There may be scenarios where a licensed non-healthcare professional possesses extensive experience and a proven track record of safe and effective practice, yet is required to operate under the oversight of a regulated healthcare professional who may lack comparable expertise in the specific procedure. Questions arise about the efficacy and appropriateness of such oversight.
The Government’s consultation paper indicates that further clarification will be provided in due course regarding the criteria practitioners must meet to provide clinical oversight. It also notes that the requirements for clinical supervision will be subject to review upon the adoption of the training and qualifications framework.
- Fragmentation Between CQC and Local Authority Oversight
The division of regulatory responsibility—CQC for red-category procedures and local authorities for amber and green—could result in inconsistent enforcement, duplication of oversight, or gaps in accountability, particularly where procedures evolve or straddle categories.
For instance, under the proposed licensing scheme, microneedling alone is classified as a green category procedure. When combined with radiofrequency, it falls into the amber category. If an amber procedure such as radiofrequency microneedling is poorly performed by a regulated healthcare professional, it would be investigated by the CQC. However, further clarity is needed on whether the same procedure—if performed by a licensed non-healthcare professional under the oversight of a healthcare professional—would fall under the jurisdiction of the CQC, the local authority, or both.
- No Standardised Training Pathway
While licensing will require practitioners to meet agreed standards, there is still no unified, mandatory training curriculum for non-healthcare professionals. This could lead to inconsistent qualifications and varying levels of competence across the sector.
Similarly, the scheme permits regulated healthcare professionals to perform medium and high risk procedures independently. However, it does not appear to distinguish between general healthcare qualifications and specific procedural experience. A healthcare professional may be licensed but lack substantive training or hands-on experience in a particular cosmetic procedure, potentially posing risks comparable to—or greater than—those associated with experienced non-healthcare practitioners.
The Government acknowledged in this consultation outcome from July 2025 that further work is needed to establish the educational and training standards, infection control and cleanliness requirements, indemnity requirements and licensing fees.
4. Medical Devices and Prescription-Only Medicines (“POM”)
The Medicines and Healthcare products Regulatory Agency (MHRA) is responsible for regulating medicines, medical devices, and blood components for transfusion in the UK. As part of its evolving regulatory framework, the MHRA intends to expand the scope of UK Medical Device Regulations 2002 to include products marketed for aesthetic or non-medical purposes—such as dermal fillers—where their function and risk profile closely resemble those of medical devices. Consequently, all dermal fillers irrespective of their intended use will be subject to more rigorous oversight. At present, dermal fillers in the UK are regulated as medical devices when the manufacturer makes medical claims regarding their use. Where dermal fillers have no medical claims and are intended solely for aesthetic purposes, they are not considered medical devices. In cases where they are classified as medical devices, they must carry either a UKCA mark—indicating compliance with UK regulatory standards—or a CE mark, which reflects conformity with European requirements.
Additionally, the Government has proposed that any cosmetic procedure involving a POM must be overseen, at minimum, by a qualified and regulated healthcare professional. This includes both procedures that directly administer POMs (e.g. injectable toxins) and those that use POMs adjunctively (e.g. lidocaine for anaesthesia or hyaluronidase for managing complications). The proposal reflects the need for practitioners to have access to experienced clinicians with independent prescribing rights, particularly in managing medical emergencies and adverse outcomes. However, further clarity is needed around what such “oversight” should entail in practice, the level of involvement required from the supervising healthcare professional, and whether physical presence is necessary.
5. Conclusion
The UK Government’s licensing scheme for non-surgical cosmetic procedures is progressing steadily, with further development expected throughout 2025 and 2026. Key areas—such as training standards, hygiene and infection control, insurance requirements, and fee structures—will be shaped in collaboration with industry experts and regulators.
Public consultations on specific elements will follow, and final regulations will be subject to parliamentary approval. A transition period is anticipated before the scheme takes full effect across England, supported by published guidance to help practitioners and premises meet licensing requirements.
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This article was co-authored by Ioana Birsan, Trainee Solicitor
