Licensing for non-surgical cosmetic procedures in England: what's confirmed and what isn't

This summarises the position as reported up to late August 2026. The scheme is still being developed, so check GOV.UK and your professional body before acting on any detail. It is not legal advice.

For years, almost anyone in England has been able to offer injectables and other non-surgical cosmetic treatments without a licence. That is changing. The government has the power to introduce a licensing scheme, and has said it will do so, but much of the detail is still open.

What is already confirmed

• The legal power exists. Section 180 of the Health and Care Act 2022 allows the government to create a licensing scheme for non-surgical cosmetic procedures in England.
• The government intends to go ahead. It consulted in 2023, and in August 2025 published its response confirming it will proceed, starting with the highest-risk procedures.
• Under-18s are already protected. Since October 2021, the Botulinum Toxin and Cosmetic Fillers (Children) Act has made it a criminal offence to give these treatments to under-18s for cosmetic purposes.
• It covers England only. Scotland, Wales and Northern Ireland are developing their own approaches.

What was proposed, and is still unresolved

• A traffic-light system. The 2023 consultation proposed sorting procedures into green, amber and red tiers by risk. Botulinum toxin and facial dermal fillers were proposed for amber; the highest-risk procedures for red. The final allocation isn't confirmed.
• Who runs it. Local councils were proposed to license green and amber procedures, with red procedures restricted to regulated healthcare professionals in premises registered with the Care Quality Commission (CQC).
• Personal and premises licences. Practitioners would be likely to need a personal licence and a licensed premises, with evidence of training, insurance and safe practice.
• Non-medical practitioners. Whether suitably qualified non-medics can carry on with amber treatments, and under what supervision, remains disputed.
• Timing. Further consultation and secondary legislation are expected before anything comes into force.

Sensible ways to prepare now

1. Get your records in order. Consultations, consent forms, patch tests, batch numbers and aftercare notes, kept consistently for every patient.
2. Keep training and insurance evidence to hand. Certificates, CPD and indemnity documents in one place.
3. Write down your aftercare process. Who responds to a concern, how fast, and how it is recorded. Inspectors and patients both care about this.
4. Know your age checks. The under-18 law already applies; be clear how you confirm age before treatment.
5. Watch for the next consultation. It is the best chance to have a say in how amber-tier treatments are handled.

Where a front desk helps

A good front desk won't make you compliant on its own, but it does keep a clear, timestamped record of every enquiry, every request and every aftercare concern, and it flags concerns to a clinician rather than answering them itself. That is the kind of record that makes any future inspection easier.