What changed for UK clinics: October 2026

England: the licensing scheme is still not in force

Nothing has changed in law this month. The power to license non-surgical cosmetic procedures has existed since the Health and Care Act 2022, and the government's response to the 2023 consultation was published on 7 August 2025. It confirmed the plan for green, amber and red tiers, with the highest-risk procedures restricted to regulated healthcare professionals working from CQC-registered premises.

What has not happened yet is the detail: which procedures sit in which tier, the standards, the fees and a start date. The government had said it would consult again, and as of this month the official consultation page still shows the August 2025 response as its latest update. No regulations have been laid and no start date has been announced.

What it means for you: nothing to change today, but expect a transition period once the regulations arrive. Our guide to licensing in England covers what has been proposed.

Scotland: its own law is now on the books

The Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Act 2026 received Royal Assent on 12 May 2026. Its main provisions are not in force yet. When they are, procedures that pierce or penetrate the skin will have to take place in permitted premises such as registered independent clinics, and some procedures will be restricted for under-18s. Separately, council licensing for some lower-risk procedures is due from September 2027.

What it means for you: if you have a site in Scotland, or patients who travel from there, start checking which of your treatments will need permitted premises.

A high-street campaign for face-to-face consultations

On 12 October, Superdrug and Save Face launched a campaign called "Back Street To High Street", calling for stronger standards, proper qualifications and regulatory oversight in non-surgical aesthetics. It focuses on face-to-face consultations and cooling-off periods before treatments such as dermal fillers and anti-wrinkle injections.

The survey behind it, commissioned by Superdrug, found that 53% of people want stronger regulation and licensing of clinics and practitioners, and 51% see appropriate medical qualifications as essential. Save Face reports that 68% of the complaints it receives involve a lack of face-to-face consultation.

What it means for you: patients are being told to ask about qualifications and consultations, so expect more of those questions in your inbox. Have the answers ready: who does each treatment, what their qualifications are, and that every prescription treatment starts with a face-to-face consultation. Since June 2025, prescribers have had to see the patient face to face before prescribing cosmetic injectables.

Advertising: the ASA is watching by default

No new rules this month, but a reminder that the Advertising Standards Authority now monitors ads continuously. Its report in March on cosmetic surgery ads from clinics abroad described an AI-based system that captured more than 4,000 paid ads on Meta's platforms and followed up on the ones that broke the rules. The same approach applies to UK clinics. Botulinum toxin is a prescription-only medicine and still cannot be advertised to the public, on social media or anywhere else.

Our guide to advertising anti-wrinkle treatments explains how to promote consultations instead.

The front desk checklist for this month

1. Qualifications. Can your website, and whoever answers your messages, say who does each treatment and what they are qualified in?
2. Consultations. Does every reply about a prescription treatment offer a consultation first, rather than a price for the injection?
3. Wording. Check your replies and saved answers, not just your ads, for the names of prescription-only medicines.