Why regulation matters in aesthetics
Why is regulation so important to the sector? Where are we currently, and where are we heading?
The UK aesthetic sector is standing at a pivotal junction. The UK Government has recently issued its response to the 2023 public consultation on licensing of non-surgical cosmetic procedures in England. And it couldn’t have come soon enough.
Ever since Sir Bruce Keogh described the market as the ‘Wild West’ of healthcare, following his 2013 report, the landscape for non-surgical cosmetic procedures has been on a slow but significant journey towards formalised regulation.
Hamilton Fraser has worked closely with the Joint Council for Cosmetic Procedures (JCCP), government and national bodies seeking greater regulation for non-surgical aesthetic treatments, with the ultimate aim of making it safer for the public. Our founder and CEO Eddie Hooker is one of the trustees and has been a key voice in the push for regulation, with almost 30 years of experience working in the sector.
While that work has been going on behind the scenes, demand for treatments has continued to rise unabated, and the industry has been marked by uneven standards, variable training, and a lack of statutory regulation for non-healthcare professionals offering injectables.
This has led to increasing public concern, high-profile complications, and mounting political pressure.
This Morning recently ran a week-long series of segments as part of its Cosmetic Cowboys Investigation, highlighting the areas where we, as a sector, are falling short.
Research carried out by the investigation showed that half of women have required medical assistance following aesthetic treatment, while 15% had ended up in hospital or A&E after receiving a non-surgical cosmetic procedure.
In addition, half of the cosmetic procedures took place in non-clinical settings, including living rooms or kitchens, and were not carried out by someone medically qualified.
With one in three women also admitting that they would go to someone who is not medically qualified to save money on a procedure, the risks are clear.
We’ve also seen recent warnings issued by Trading Standards over unsafe practices and unregulated products on the market. In addition, in June and July 2025, the UKHSA confirmed 38 cases of iatrogenic botulism in England, all traced to unlicensed or counterfeit botulinum toxin injections administered in non-clinical settings, posing a huge safeguarding risk to the public.
For more on this, you can read our article and access and download a new guide – The Invisible Risk Behind Unregulated Botulinum Toxin (Botox Like) Treatments – written by award-winning aesthetic nurse and educator Julie Scott, supported by the Joint Council for Cosmetic Practitioners (JCCP).
With all this going on, it has never been more important for practitioners and clinic owners to understand the direction of travel for aesthetic regulation. It is not only crucial for compliance within currently existing scopes but also for safeguarding patient safety, building trust, and future-proofing their business.
2013 – The Keogh ReviewIn April 2013, the Keogh Review was published, commissioned by the Department of Health and led by Sir Bruce Keogh. The report issued a stark warning about the lack of regulation in the aesthetics industry, noting that patients seeking non-surgical procedures were afforded little more protection than consumers buying everyday products. This landmark review was a catalyst for future calls to improve patient safety.
2015 – Health Education England (HEE) FrameworkIn 2015, Health Education England (HEE) was tasked with creating a training and education framework to improve standards across the aesthetics sector. Over 18 months, HEE collaborated with regulators, universities, and industry groups, producing two major reports in November 2015 that laid the groundwork for enhanced practitioner competence and safety.
2017–2018 – Establishment of the JCCPThe Joint Council for Cosmetic Practitioners (JCCP) was formed in 2017 and officially launched in 2018 to adopt and enforce HEE’s standards through a voluntary register. Working alongside the Cosmetic Practice Standards Authority (CPSA), the JCCP set out to raise training and practice standards by establishing competency frameworks and encouraging practitioners to demonstrate adherence to best practice.
2020 – Updated Code of PracticeThe JCCP and CPSA published a revised version of their Code of Practice and Guidance for Practitioners Who Provide Cosmetic Interventions, following extensive consultation. Approved in 2020 (with a third edition published in March 2023), this document continues to shape ethical and professional standards in aesthetics.
2021 – A 10-Point Plan and new legislationIn 2021, the JCCP launched its influential 10-point plan outlining campaigns for statutory regulation, mandatory education, clearer treatment definitions, improved prescribing, stricter advertising standards, complications reporting, insurance requirements, and consumer awareness.
July 2021 also saw the All-Party Parliamentary Group (APPG) publish findings from its inquiry, reinforcing the need for minimum educational standards to protect patients.
In October 2021, the first major piece of legislation directly affecting aesthetics came into effect: a ban on cosmetic injectables for individuals under 18. This law was a turning point, reflecting growing ethical and safety concerns.
2022 – Health and Care Act and Select Committee ReportThe Health and Care Act 2022 laid the foundations for a mandatory licensing scheme covering practitioners and premises. This framework is designed so that anyone carrying out aesthetic procedures meets consistent standards of training and hygiene.
That same year, the Health and Social Care Select Committee published a report on the impact of body image on mental and physical health, highlighting the mental and physical health impacts of non-surgical cosmetic procedures and recommending robust regulation.
2023 – Consultation on Licensing SchemeIn January 2023, the Government reaffirmed its commitment to introducing the licensing scheme, with an initial implementation target of 2026. A formal public consultation ran from September to October 2023, seeking feedback on the proposed framework.
As of mid-2024, the sector was still awaiting the Government’s response, raising concerns about delays, particularly following the change in Government in July 2024.
2025 – Scotland and England respond to consultations on licensing and the NMC makes changes prescribing rules
In early 2025, the Scottish government confirmed that a new licensing system will be introduced by May 2026, following its own national consultation. Many anticipate that England will adopt a similar model.
This was followed in August 2025 by an announcement by The Department of Health and Social Care outlining new measures to crack down on cosmetic procedures.
Also in 2025, the Nursing and Midwifery Council (NMC) implemented a ban on remote prescribing for non-surgical cosmetic medicines, including toxins and aesthetic emergency drugs.
Nurse and midwife prescribers must now see patients for face-to-face consultations before issuing prescriptions, to support more thorough patient assessment and safer practice.
As featured in Hamilton Fraser’s recent podcast with Andrew Rankin – Regulation in aesthetics – where are we now – the current system in England is fragmented. While healthcare professionals are regulated by their respective statutory bodies, there is still no legal requirement for non-healthcare professionals performing cosmetic procedures to meet the same clinical or ethical standards.
However, the groundwork for change has been laid and the UK Government has now issued its long awaited response to the 2023 consultation on a proposed licensing scheme for non-surgical cosmetic procedures in England.
The consultation, which received widespread industry feedback, including from Hamilton Fraser and the Joint Council for Cosmetic Practitioners (JCCP), closed in late 2023.
Among the proposed measures are:
Only qualified healthcare professionals will be able to perform the highest risk procedures, such as non-surgical Brazilian Butt Lifts. These must be done by specialised healthcare workers working in providers that are registered with the Care Quality Commission (CQC).
Clinics administering lower-risk cosmetic treatments, including botulinum toxin, lip fillers and facial dermal fillers, will also come under stricter oversight through a new local authority licensing system.
Practitioners will be required to meet rigorous safety, training, and insurance standards before they can legally operate. Once regulations are introduced, practitioners who break the rules on the highest risk procedures will be subject to CQC enforcement and financial penalties.
The Government also plans to bring in restrictions for under-18s on high-risk cosmetic procedures, unless authorised by a healthcare professional. This means children will also be protected from dangerous beauty trends on social media.
The regulations will be subject to public consultation and parliamentary scrutiny before they are introduced.
Minister of State for Health Karin Smyth MP said: “The cosmetics industry has been plagued by a Wild West of dodgy practitioners and procedures. There are countless horror stories of cosmetic cowboys causing serious, catastrophic damage.
This government is taking action to protect those seeking treatments, support honest and competent practitioners, and root out the cowboys as part of our Plan for Change. This isn’t about stopping anyone from getting treatments – it’s about preventing rogue operators from exploiting people at the expense of their safety and keeping people safe. We’re giving them peace of mind and reducing the cost to the NHS of fixing botched procedures.”
Professor David Sines CBE PhD, Executive Chair and Registrar JCCP, said, “The Joint Council for Cosmetic Practitioners warmly welcomes the UK Government’s decision to introduce legislation to regulate and licence cosmetic procedures according to the risks they present. Their ‘Plan for Change’ signals a commitment in the strongest terms and it accords with the JCCP’s widely publicised call for statutory regulation.
The introduction of standards to ensure that patients are safeguarded and protected from harm, ensuring that all cosmetic practitioners are regulated and licensed to a new national education and training standard, that they are appropriately insured and that they work from safe premises at all times has become imperative. These proposals have our full support and we welcome the opportunity to engage in further consultation.
Eddie Hooker, Founder and CEO of Hamilton Fraser, who is also a trustee of the JCCP, commented, “Hamilton Fraser supports and welcomes the Government’s announcement. For too long, the aesthetics sector has had to contend with a small but damaging minority of untrained practitioners whose shortcuts put patients, reputable clinicians and the NHS at risk. Mandating that only suitably qualified healthcare professionals can perform higher-risk procedures, and the requirement of robust licensing, training and insurance for all treatments, will draw a clear line between safe, accountable practice and the ‘Wild West’ operators the Minister has rightly condemned.
At Hamilton Fraser, we have championed higher standards and comprehensive insurance cover for nearly three decades. We stand ready to work with government, regulators, patient-safety groups, and our insured practitioners to implement these measures smoothly, making sure patients receive safe, ethical treatment and our industry continues to innovate and grow on a foundation of trust.
You can read the full response here.
Hamilton Fraser has played an active role in shaping the regulatory conversation. CEO and founder Eddie Hooker sits on the JCCP board and is a vocal advocate for improved standards.
In a recent podcast episode, Eddie and co-host Vicky Eldridge were joined by JCCP Practitioner Register Committee chair Andrew Rankin to discuss where we are now and how insurance fits into the regulation puzzle.
Rankin, a long-standing nurse practitioner, emphasised that safeguarding the public begins with practitioner accountability — and that insurance providers will play a critical role in verifying qualifications, ethical practice, and continuing professional development as part of future licensing. For more on how insurance fits into regulation, listen to our podcast with Eddie Hooker and Andrew Rankin.
Meanwhile, in his ongoing contributions, Professor David Sines, Executive Chair and Registrar of the JCCP, has called for a new era of governance, where mandatory licensing, robust enforcement, and better collaboration across the UK nations form the foundation of safer aesthetic care.
In June 2025, the Scottish Government released its official response to its national consultation on the regulation and licensing of non-surgical cosmetic procedures, confirming that a new licensing system will be introduced by May 2026. This was followed in October 2025 by the publication of the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill.
The Bill was published by the Scottish Parliament on 8 October 2025 and marks another major step forward in the UK’s journey toward improving regulation, patient safety, and professional accountability within the aesthetics sector.
The Scottish Government has also released a series of impact assessments to accompany the Bill, including the:
Business and Regulatory Impact Assessment
Equality and Fairer Scotland Duty Impact Assessment
Child Rights and Wellbeing Impact Assessment
Island Communities Impact Assessment consideration
The new legislation outlines specific conditions under which non-surgical cosmetic procedures – previously categorised as Groups 2 and 3 – may be performed.
These include treatments such as dermal fillers and botulinum toxin injections.
Permitted premises: Only “permitted premises” will be authorised to provide non-surgical procedures. This includes independent hospitals and clinics registered with Healthcare Improvement Scotland (HIS), or where services are delivered or overseen by qualified healthcare professionals.
NHS procedures excluded: Treatments carried out within the NHS, or those undertaken for the prevention, diagnosis, or treatment of illness, are not covered by the Bill.
Offences introduced: It will be an offence to perform non-surgical procedures on under-18s or to carry out these treatments from non-permitted premises.
Enhanced enforcement: HIS will gain strengthened inspection and enforcement powers to make sure standards are maintained and public safety is prioritised
This divergence between the nations could pose future challenges for practitioners operating across borders, but it also offers a testing ground for reform.
As Harley Academy highlights in a comprehensive article and interview with David Sines, the Scottish model could influence the shape of regulation in England, particularly around practitioner training, clinical oversight, and access to redress
As regulation inches closer to reality, practitioners should begin preparing now. Key steps include:
Staying informed: Follow updates from trusted sources such as Hamilton Fraser, the JCCP, and professional bodies. Regularly review content from Hamilton Fraser’s Content Hub and podcasts for expert insights
Documenting your qualifications: Make sure your training, CPD, and indemnity records are up to date and in line with JCCP and CPSA expectations
Audit your insurance: Check that your insurance reflects your scope of practice and includes appropriate cover for all treatments you offer
Prepare for a licence: While the details are still to be confirmed, a licensing scheme is likely to include mandatory training standards, treatment restrictions, premises requirements, and accountability measures
Practice ethically: Follow the highest standards of consent, record-keeping, safeguarding, and adverse event reporting — regardless of whether you are a medic or non-medic
Ready to start preparing your clinic for licensing? Head to Chapter 5 for a practical checklist.
As regulation progresses, insurance providers like Hamilton Fraser are expected to play a key role in verifying practitioner legitimacy and supporting the licensing process.
Having full malpractice insurance in place, robust complaints procedures and redress will be key.
Through his position on the JCCP board, Eddie Hooker continues to advocate for a collaborative approach that brings together educators, insurers, regulators, and practitioners to raise standards across the board.
The next 12–24 months will be critical for the aesthetic industry in the UK. With regulatory frameworks beginning to take shape in both Scotland and England, the expectation is that a more structured, enforceable, and consistent approach to safety will emerge.
For responsible practitioners, it’s an opportunity to demonstrate credibility, build patient confidence, and raise the bar for the entire sector. The time to prepare is now.
As regulation in the aesthetic sector edges closer, one thing is clear: the rules and expectations for different professional groups are shifting.
