Regulation, CQC requirements and professional responsibility
A detailed look at the regulatory and ethical framework surrounding weight-loss treatments, including CQC registration, advertising rules, safeguarding and the psychological risks linked to body image and eating disorders.
Although weight management has rapidly entered the aesthetics arena, its delivery, when it comes to GLP1s, should sit within regulated healthcare, not cosmetic enhancement.
As demand for GLP-1 receptor agonists increases and cultural narratives shift toward extreme thinness, practitioners must navigate a complex intersection of legal regulation, psychological risk, safeguarding, and professional accountability.
This chapter explores the regulatory framework – including when CQC registration applies – and the ethical responsibility practitioners hold in protecting both patients and themselves.
Under the Health and Social Care Act, weight-loss services involving the prescribing, supply or administration of medicines (including GLP-1 agonists) fall under CQC-regulated activity. According to the CQC’s Services in Slimming Clinics guidance, clinics typically require registration when they:
Provide medical assessment for weight-loss treatment
Prescribe or administer medications such as semaglutide or tirzepatide
Monitor patients for side effects or treatment progress
Deliver structured, medically supervised programmes
Government guidance on GLP-1 weight-loss medicines highlights the need for clinical oversight, safe prescribing and integrated lifestyle support, reflecting the growing public health role of these treatments.
It emphasises that GLP-1 medicines must be prescribed within strict clinical criteria. NICE recommends semaglutide for patients with a BMI ≥ 30, or ≥ 27 with weight-related comorbidities, while tirzepatide is recommended for those with a BMI ≥ 35 and at least one comorbidity, with adjusted thresholds for minority ethnic groups due to higher metabolic risk.
Guidance for the public reinforces that all GLP-1 medicines are prescription-only medicines (POMs), legally supplied only through registered pharmacies. It warns against purchasing weight-loss pens online – particularly through social media marketplaces – highlighting the risk of counterfeit products, incorrect dosing, improper storage and lack of medical supervision.
The MHRA has removed large numbers of illegal online listings and continues to monitor misuse under its Black Triangle Scheme, which applies to newer medicines requiring enhanced safety surveillance. In addition, officers from the Criminal Enforcement Unit (CEU) of the MHRA recently dismantled a major illicit manufacturing facility, making and distributing unlicensed weight-loss jabs, during a raid on a warehouse in Northampton.
Government guidance also stresses the need for dose titration, starting patients on the lowest dose and increasing gradually to minimise gastrointestinal side effects such as nausea, diarrhoea and constipation. More serious risks, including pancreatitis and gallbladder complications, require careful assessment and prompt review. For this reason, prescribers are expected to conduct regular monitoring and consider discontinuing treatment if adequate weight loss is not achieved within a reasonable timeframe.
Dietary and lifestyle changes remain core components of government recommendations.(See Chatper 3 of this guide). GLP-1 medicines must be used alongside a reduced-calorie diet, increased physical activity, and long-term behavioural support to improve metabolic health and prevent weight regain.
You can read the Government guidance here and download the report on Weight loss medicines in England from the House of Commons Library here.
Regulators have raised concerns about unsafe prescribing and the growth of counterfeit GLP-1 pens across online pharmacies and social media marketplaces. Investigations reveal:
Fake weight-loss pens circulating in the UK
Non-medics selling prescription medications illegally
Online clinics prescribing without adequate medical checks
Patients experiencing harm after accessing unregulated products
Patients buying drugs without a prescrption or regulated prescriber
Hamilton Fraser has repeatedly highlighted that using unlicensed or grey-market medicines may invalidate a practitioner’s insurance.
Work only with licensed pharmacies
Maintain detailed, defensible clinical records
Conduct thorough health screening and face-to-face assessments
Apply titration and monitoring protocols
Refer when red flags or psychological risk factors are present
Many online consultations are being done via video or just by filling out forms, bringing the issue of remote prescribing to the fore once again.
“Online is the biggest concern for me”, says Piroska. “These drugs are so readily available, you just click online and you can get yourself some. It is dangerous. These are drugs that affect your gut; they affect your brain. In the right hands, they can be an amazingly useful tool, but in the wrong hands, they can cause you some real serious issues.
I don’t think remote prescribing is viable and definitely not initially. You need to meet the person and have a one-to-one. You can't assess someone from a photograph or a video. You should be weighing them, you should be assessing their muscle mas,s you should be assessing their fat percentage, their visceral fat, you should be measuring them with a tape measure, you should be taking photographs and you should be monitoring their progress.
Advertising GLP-1 medicines to the public is illegal. As prescription-only medicines, they cannot be promoted directly, and providers must adhere to strict ASA and MHRA rules governing indirect marketing or influencer-led content.
The Advertising Standards Authority (ASA) recently issued an updated enforcement notice prohibiting any advertising of GLP-1 medications, including:
Brand names such as Ozempic, Wegovy or Mounjaro
Injection pen images
Implied promotion (“skinny jabs,” “fat-loss injections”)
Linking general weight-loss ads to POM-related content
Clinics may promote consultations or lifestyle programmes, but must not reference prescription medications. The CAP Compliance team now uses AI-assisted monitoring, with breaches potentially leading to sanctions, removal of posts or referral to regulators.
Alongside regulatory requirements, practitioners must recognise the emotional and psychological risks associated with weight-loss treatments. The aesthetic sector sits at the centre of conversations around beauty ideals, and recent cultural trends show a shift back towards extreme thinness, amplified by high-profile celebrities openly discussing GLP-1 use.
A recent Women in Aesthetic Medicine (WIAM) article discussed how “size zero” trends are re-emerging with GLP-1 medications influencing both patient and practitioner perceptions of body weight.
Body Dysmorphic Disorder (BDD) is a significant concern. While 1.7–2.9% of the general population is affected, prevalence is far higher among aesthetic patients:
Up to 24% in cosmetic surgery populations
Around 8.2% of aesthetic practitioners show symptoms consistent with BDD
An April 2025 Aesthetics Journal report highlights additional risks:
Individuals with eating disorders are increasingly accessing weight-loss injections
NHS leaders warn of rising harm, including 82 deaths linked to GLP-1 medications, 22 of which were related to weight-loss use
GLP-1 drugs can exacerbate psychological distress, anxiety and disordered eating
These findings underscore the need for:
Detailed psychological screening
Awareness of “red flag” behaviours
Open conversations about body image pressures
Supportive referral pathways.
Key takeaway: CQC registration, ethical governance and a strong focus on psychological safety form the foundation of responsible weight-management practice in the aesthetics sector.
