The shifting landscape of aesthetic regulation in the UK

What practitioners should know moving into 2026

The UK aesthetics industry is undergoing a regulatory awakening. After years of fragmented oversight, mounting safety incidents, and growing political pressure, the government is now pressing ahead with reforms designed to bring clarity, accountability, and patient protection to the sector. For practitioners, understanding the impact of these changes is critical for managing risk, staying compliant, and structuring practices effectively.

This article seeks to outline the key recent developments, the emerging regulatory regime, and practical “watchouts” for those practising in the aesthetic sector.

Why regulation has long been inevitable

Before diving into the changes, it is helpful to revisit why more robust regulation has been a priority for some time.

1. Regulatory gap for non surgical aesthetics: 

Many aesthetic treatments (such as injectables, fillers, laser) sit outside formal medical regulation in the UK. As a result, non-medically qualified individuals could legally perform such treatments under minimal oversight. This has contributed to inconsistent standards, unsafe practice, adverse outcomes, and litigation risk.

2. Political, media, and public pressure: 

Adverse events - from serious complications, infections, to deaths - have raised public and political alarm. In particular, high-risk procedures like “liquid Brazilian butt lifts” (BBLs) have been repeatedly flagged. In 2024, the death of a 33 year old woman following a liquid BBL drew widespread attention and emphasised the urgency of reform.

3. Legislative authority: Health & Care Act 2022:

Parliament has already equipped the Secretary of State with the power to create a licensing scheme for non surgical cosmetic procedures in. This legal foundation makes regulatory change increasingly likely.

Key developments

Below is a summary of the most significant changes and proposals that have emerged across 2024-2025:

1. Government publishes regulatory proposals and consultation response

In August 2025, the Department of Health and Social Care (DHSC) published its response to the earlier 2023 consultation. The response sets out a plan to regulate non-surgical cosmetic procedures in England.

The key elements are as follows:

• A tiered (red amber green) risk classification for aesthetic procedures, based on safety/risk profiles.
• High risk (“red”) procedures (e.g. liquid BBL, fillers in breasts or genitals) will only be performed by qualified healthcare professionals (HCPs) such as doctors, registered nurses, and dentists in CQC registered premises.
• Lower risk treatments (e.g. botulinum toxin (‘botox’), dermal fillers) will require local authority licensing for both practitioner and premises, with standards that will need to be adhered to in relation to training, hygiene and insurance.
• Age restrictions: under 18s will be prohibited from receiving certain high-risk procedures unless approved by a qualified HCP.
• Enforcement regime: practitioners or premises who breach rules may face penalties, bans, or regulatory action by CQC or local authorities.

Future laws or regulations will clarify remaining procedural and enforcement details.

2. Prescribing changes and remote consultations

From 1 June 2025, the Nursing and Midwifery Council (‘NMC’) announced that nurse/midwife prescribers must conduct face-to-face consultations before prescribing non surgical cosmetic medicines (e.g. botox and fillers). Remote prescribing is no longer allowed.

This change aims to tighten clinical safety, ensure robust assessment, and reduce risk of misuse. Practitioners who previously relied on digital consult-to-prescribe models will need to update their processes.

3. Advertising oversight: ASA acts on risky procedures

In April 2025, the Advertising Standards Authority (ASA) banned adverts promoting liquid BBL procedures that misled consumers, trivialised risks, or used high-pressure tactics.

Even without full regulation, promotional content for high-risk procedures is under closer scrutiny. Practitioners must ensure marketing complies with ASA rules, particularly regarding risks, outcomes, practitioner credentials, and consent.

4. “Wild West” crackdown announcements and upcoming laws

In August 2025, the Health Secretary announced a crackdown on unqualified “cowboy” practitioners offering high-risk treatments. Proposed 2026 legislation will:

• Restrict high-risk procedures to qualified HCPs.
• Bring providers and premises under CQC or local licensing.
• Bring forward age restrictions.
• Strengthen enforcement against non-compliant providers.

Practical implications for practitioners

These regulatory shifts present both challenges and opportunities. Key recommendations:

Tip 1: Start preparing for compliance early

• Many proposals are not yet law but aligning with expected standards now is safer than waiting until implementation.

Tip 2: Review your procedural portfolio

• Map services likely to fall into red/high-risk categories.
• Consider restricting high-risk services, shifting them to medically qualified staff, or relocating to regulated premises.
• Evaluate whether treatments may become prohibited or heavily regulated.

Tip 3: Strengthen governance

• Verify qualifications, training, and CPD records.
• Confirm professional indemnity covers aesthetic risks, including future regulatory demands.
• Establish clear Standard Operating Procedures (SOPs) on infection control, complication management, record keeping, consent, and escalation.
• Maintain documentation ready for regulators, insurers, or auditors.

Tip 4: Marketing and patient communications

• Ensure all materials comply with ASA codes. Avoid exaggerating outcomes or trivialising risks.
• Clearly specify the qualifications needed for each procedure.
• Enhance informed consent with risk, downtime, reversibility, and practitioner competence information.
• Keep audit trails of consent, pre-procedure assessments, and aftercare.

Tip 5: Clinic premises and equipment compliance

• Assess premises for sterility, layout, cleanliness, and emergency protocols.
• Ensure devices comply with UK device regulations.
• Maintain logs for safety checks, maintenance, calibration, and licensing.

Tip 6: Engage with regulators proactively

• Monitor evolving regulations and guidance.
• Participate in consultations and industry dialogues.
• Consider external audits before compliance deadlines.

Areas of uncertainty and ongoing debates

Practitioners should be aware of:

• Definitions and thresholds: “high risk” vs. “medium risk” may shift.
• Timelines and grace periods for compliance.
• Interplay with GMC, NMC, GDC, and other professional regulators.
• Enforcement capacity across thousands of clinics.
• Cost and accessibility: balancing public safety with commercial viability.

Conclusion: The time to act is now

The regulatory environment is changing and the era of hands-off oversight for non-surgical aesthetics is ending. Even though many reforms are not yet implemented, the direction is clear: higher standards, stricter accountability, and enhanced patient protection.

If your practice is affected and you would like guidance from our expert regulatory team, please contact us.