Understanding the new regulations for non-surgical cosmetic procedures: Enhancing patient safety

The UK government has announced new licensing rules for non-surgical aesthetic procedures with aims to bring increased standards in the aesthetics industry.

The new rules have been introduced in recognition of the dangers associated with the currently unregulated aesthetics landscape, with a view to enhancing patient safety and to reduce the burden on the NHS caused by botched cosmetic procedures.

In recent years, the popularity of non-surgical cosmetic procedures has grown, particularly botox, cosmetic fillers, chemical peels and energy-based treatments. This can be attributed to the impact of social media and the affordability of high street providers and clinics. 

Published statistics from the British Beauty Council show that the cosmetic and personal care sector supported a total GDP contribution of £24.5bn and tax contributions of £6.8bn to HM Treasury in 2022. 

In July 2025, 38 cases of botulism poisoning were recorded in England after the suspected use of unlicensed botox-like products in cosmetic procedures, highlighting the importance of undergoing treatment by a suitably qualified practitioner using licensed products. There are countless horror stories of aesthetics practitioners causing serious, catastrophic damage.

The current framework

The current framework regulating non-surgical cosmetic procedures places few limitations on who can perform the procedures, which has presented issues surrounding patient safety, consent and the competency of those providing the procedures.

The industry comprises both regulated healthcare professionals and aesthetics practitioners such as beauty therapists. This has resulted in an unregulated landscape where both competent practitioners and poorly trained practitioners can perform non-surgical cosmetic procedures. 

The current legislative framework makes no requirement for practitioners to operate with training and infection control standards. A licence is not currently required to perform cosmetic procedures in England; this is now changing as the government announce licenses for a number of non-surgical aesthetic procedures. 

Summary of the changes 

The new framework categorises non-surgical procedures according to the risks associated with them.

Green procedures can be carried out by all practitioners with a licence. Amber procedures will require non-healthcare professionals to be licensed and have relevant oversight by a regulated healthcare professional.

Finally, red procedures, which include high-risk procedures such as the Brazilian butt lift, will be brought under the regulation of the Care Quality Commission (CQC) meaning they fall outside of the licensing scheme and can only be carried out by qualified and regulated healthcare professionals. Practitioners who do not adhere to the new rules on the highest risk procedures will face CQC enforcement and financial penalties.

The new regulations will bring consistent standards in the aesthetics industry, ensuring protection to individuals from potentially harmful impacts of improper non-surgical procedures. 

Under the new licensing scheme, those who perform non-surgical aesthetic procedures will be suitably knowledgeable, trained and qualified; hold the appropriate indemnity cover; and operate from premises which meet the necessary standards of hygiene. They will be trained in infection control and cleanliness.

The licensing scheme will operate in England and will be under the control of the local authorities. It aims to:

• identify risky procedures;
• proposes both a practitioner license and a premises licence;
• make it an offence for non-surgical procedures to be carried out without a licence; and
• introduces a minimum age of 18 for undergoing non-surgical procedures.

This is the first consultation on the licensing scheme and further work, including stakeholder engagement and public consultation is to be considered, to determine the principles which will underpin the scheme.

Conclusion

The new regulations will change the landscape for those offering non-surgical aesthetic procedures. It will be important for providers to understand the requirements and have the correct licenses in place to avoid non-compliance. It will also be crucial to ensure that the correct indemnity cover is in place. Insurers will likely need to re-evaluate their policies and how they assess risk.

At Browne Jacobson, we have extensive experience in helping clients navigate legislative change and enhanced safety requirements. We are insurance specialists and have vast knowledge and expertise in advising underwriters and dealing with claims where things go wrong.