_SECTION
TWO

In this chapter:

_{JCCP Annual Report}

^Introduction

The Joint Council for Cosmetic Practitioners (JCCP) Charity was established and launched formally at the House of Peers in February, 2018 following an extensive stakeholder consultation process undertaken by Health Education England (HEE) in accordance with the recommendations outlined in the Keogh Review (2013) on cosmetic treatments in England. The HEE standards were formally transferred to the JCCP by HEE in June, 2018 as advised on the NHSE website). One of the key recommendations included in the 2015 HEE Report called for the establishment of statutory regulation for the sector and for the immediate creation of a voluntary register. The JCCP now fulfils such a function.

The JCCP is a ‘not for profit’ UK charitable body charged with the responsibility of voluntary ‘self-regulation’ of the non-surgical aesthetic and hair restoration surgical sectors in the four UK countries. The Mission Statement for the JCCP and its values are set out below:

‘The Joint Council for Cosmetic Practitioners (JCCP) is a Professional Standards Authority (PSA) accredited voluntary self-regulator of the non-surgical aesthetic and hair restoration surgery sector in England and provides an informed and legitimate point of access for the public seeking information

about this area of practice and where appropriate for raising concerns about practitioners. The JCCP places public protection and patient safety as the focus of its activities’.

The Charity's objects refer to the promotion of the health and safety of, and protection of the public by the development and implementation of high standards of performance and practice among non-surgical cosmetic practitioners and hair restoration surgeons, including the definition, creation, and maintenance of an effective structure to inform the standard of professional education and training amongst non-surgical cosmetic practitioners and hair restoration surgeons.

The JCCP provides two voluntary registers;

Practitioner Register (Approved by the PSA)
Approved Qualifications and Education & Training Provider Register (Approved by the JCCP and lists those education and training provider organisations and qualifications whose standards and qualifications accord with the JCCP’s published education and training standards required for entry to its PSA Approved Practitioner Register).

JCCP Practitioner Registrants and Approved Qualifications, Education and Training Provider Organisations are recognised, approved, and registered by the JCCP in line with Professional Standards Authority (PSA) and JCCP/CPSA accredited standards. For practitioner registrants this requires evidence of the possession of relevant knowledge, experience or qualifications leading to core and modality specific competency as set out by the JCCP’s sister body the Cosmetic Practice Standards Authority in their practice standards (February, 2018) and by the JCCP’s Competency Framework (September, 2018), adherence to a published Code of Practice and Standards set out by the JCCP/CPSA (2023), good character, compliance with premises/infection control/health protection standards and possession of adequate insurance and indemnity cover in relation to treatments provided.

The JCCP has continued to function as a productive and influential charitable organisation throughout 2024/2025 and has engaged regularly with the UK Government, UK Devolved Government Administrations, National Government Agencies, Professional Statutory Regulatory Bodies, Other Regulators (such as the CQC and MHRA), Professional Membership Associations, Insurance Companies, Pharma Companies, Pharmacies and Professional Stakeholder Organisations in order to determine and publish guidelines on how to work safely, ethically, professionally, and legally within the aesthetics sector. The JCCP regularly contributed this year to a range of regional, national and global webinars, published standards and guidance on its website and responded to numerous individual and corporate enquiries during the reporting year with particular regard to governance and regulatory reform within the aesthetics sector. This work has dominated much of the JCCP’s activity and stakeholder engagement activities again this year.

The transaction of the JCCP’s functions is dependent upon receipt of charitable donations received from a wide range of stakeholders in the form of pro bono goods and services and in the form of financial contributions. The JCCP gratefully acknowledges the significant support and charitable assistance provided by its multiple sponsors: [Allergan] AbbVie PLC; Bevan Brittan LLP; Clinisept+; Church Pharmacy Ltd; Galderma Ltd; Hamilton Fraser Resolutions Ltd; Harley Academy; Merz Ltd; NEC Software Systems; Teoxane, sk:n Ltd and Healthxchange Pharmacy.

The JCCP has continued to receive excellent executive support from Paul Burgess. Administrative support has been provided by the Hamilton Fraser Administrative Team. Zoe Cooper - the JCCP’s Project Development Officer has also transformed the way in which the JCCP functions both operationally and through our multiple media channels. The Council’s financial management, accountancy and audit services are outsourced to independent accountancy companies. Social media and communications have also been outsourced whilst the management of the JCCP website has continued to be graciously provided and maintained ‘pro bono’ by HF Resolutions. In a similar way pro bono legal advice has been provided to the JCCP again this year by our legal advisors Bevan Brittan.

The JCCP’s full time Project Development Officer during the reporting year, Zoe Cooper been seconded to the Council by Hamilton Fraser. Zoe Cooper has enabled the Council to achieve the following key service improvements:

Redesign and relaunch of the JCCP’s public facing website – JCCP & me
Major redesign and upgrade to the JCCP website and policy/procedural document
Redesigned and simplified education and training provider application process
JCCP event management
Support to design and provide documents required for achieved PSA accreditation (2024-2026)
Design and implementation of a new online complaints portal for members of the public
Implementation of a new ‘Share point’/Client Management System and communication databases
Radical revision to the JCCP’s marketing and communication strategy, including the production of new and effective Registrant and Public facing newsletters, webinars and marketing material
Professional production and publication of JCCP ‘Licensing’ materials and responses to the Government’s Consultation exercise in England
Co-ordination of the JCCP Education and Training Committee’s Task and Finish Group on the review and revision of education and training standards.
Publication of regular professional articles and publications.

_2024/25

^Developments

The JCCP has been functioning for seven years at the time of producing this annual report. During the past twelve months the JCCP has continued to formally embed its governance structures and has retains a fully appointed representative Board of Trustees, all of whom are registered with the Charity Commission and Companies House.

Conflicts of interest policies and confidentiality procedures continue to be implemented and enforced to guide the work of the Charity. No significant breaches of confidentiality or governance have been witnessed during this year’s reporting period. A ‘Declaration of Interests’ register and risk registers are kept centrally. Conflicts of interest have been overtly declared where relevant and have been reported to the Trustee Board through the exercise of the Charity’s public duty and candour process. During the reporting year the JCCP has continued to publish the minutes of its Trustee Board on its public facing website to enable transparency and accessibility to members of the public. The JCCP also published its Annual Report (2023/24) and Accounts on its public facing website in July, 2024. The JCCP operates two risk registers (relating to patient safety and corporate governance) and reviews these at each Trustee meeting. During the past year the JCCP’s policies and operating procedures have been formally reviewed and updated.

An Extraordinary General Meeting of the Council was convened on the 15^th January, 2025 to propose changes Clauses within Sections 25 and 26 of the JCCP 2018 Articles of Association to enable Trustees and appointed officers to serve three terms of office (rather than two), with a caveat that ‘No Trustee, Chair or Vice-Chair shall be capable of serving in their office for more than twelve years in total’. This change to the JCCP Constitution was approved by this Extraordinary General Meeting of the Council. The Charity Commission, Companies House and the PSA were subsequently informed of the changes to the JCCP Articles of Association. The JCCP Practitioner Register Committee (PRC) has continued to meet at bi-monthly

intervals throughout the reporting year under the Chairmanship of Andrew Rankin and has received ongoing legal advice from Bevan Brittan following the full implementation of the Council’s Fitness to Practise Rules and procedures. The full ‘suite of’ policies and procedures governing the JCCP’s FtP have been reviewed and updated and continue to be regarded as ‘fit for purpose’. The JCCP’s list of ‘fitness to practise’ panellists (who are appointed by an independent Appointments Committee on behalf of the Council) has been updated again this year and the Panellists continue in their role. Additional Panellists have been appointed throughout the year to provide a fully representative group of lay and professional FtP panel members. All Panellists have been trained in the application of the Council’s FtP processes. The JCCP Practitioner Register Committee also produced

procedures relating to the annual audit/sampling of registrant’s self-returns for premises standards, supervision and for CPPD. The third annual sample of Registrants was undertaken in October, 2024 in accordance with agreed procedure. The sampling process continues to provide an effective method to quality assure practitioner annual renewal of registration requirements. During 2024 the PRC has continued to undertake regular bi-monthly checks to ensure the accuracy of Registrant data that appears on the JCCP public facing Practitioner Register. Upgrades and improvements have been made throughout the year to the Practitioner Register’s data base and operating system to enable more effective data processing and coding. Bi-monthly ‘deep dives’ have also been undertaken by a sub-committee of the JCCP in partnership with the Register Administration team during the reporting year to scrutinise registration data integrity and accuracy.

Throughout the year the JCCP Practitioner Register Committee provided rigorous oversight for the implementation of the PSA approved Part ‘A’ – ‘Category Two’ registration category for health care professionals. Revised definitions for these categories have been published on the JCCP website. Due to anticipated changes being made by the UK Government on the implementation of new education and training standards for the aesthetic sector in England the JCCP

sought agreement from the PSA in September, 2022 to extend the period for which the ‘Part A’ – ‘Category Two’ may stay open until the Government publishes its education and training standards and makes an explicit determination on its plans for the implementation of a new system of licensing for the aesthetics sector. The PSA conceded to this request. This concession has remained in force throughout the reporting year and will do so until the DHSC confirm their definitive proposals for a legally enforceable licencing scheme for non-surgical cosmetic practitioners in England.

The JCCP continues to enforce its standards and procedure to enable the collection of designated data relating to equality, diversity and inclusivity for its Registrants. The JCCP Executive Chair and Registrar and the Chair of the Practitioner Register Committee have met at bi-monthly intervals with the JCCP Register team to review EDI data returns/data and consider the ‘EDI’ representativeness of the JCCP Practitioner Register .

The JCCP continues to recruit to its Practitioner Register. By the end of December, 2024, the total number of registrants had grown to over 1,130. Much of this growth continues to be attributed to the Council’s insurance incentive scheme with Hamilton Fraser and has been further supported through the approved access routes agreed with BCAM and BAAPS. The JCCP Council considers that by continuing to work in alliance with aesthetic insurers is a practical and logical step to encourage and develop safe practice and practitioners. The JCCP continues to believe that by increasing the number of Registrants on its Practitioner Register, their confirmation to practise in accordance with both CPSA and JCCP standards will further assist us in meeting our aim of assuring public safety and will provide Registrants with a ‘gateway’ towards the achievement of the Government’s Practitioner License in England when it comes into force in 2026/2027.

The JCCP has decided to continue to offer free membership to those persons who are insured with Hamilton Fraser for a further period of two years. All registered healthcare practitioners who have ‘Professional Indemnity Insurance’ with Hamilton Fraser are offered the opportunity to ‘opt in’ to join the JCCP Practitioner Register (subject to an agreed set of additional criteria related to JCCP standards). As such free membership of the JCCP will continue to be offered to Hamilton Fraser registrants at the point of both their initial offer of aesthetic insurance and also at the point of their annual renewal.

Throughout the year the Council has implemented robust systems of data integrity audit to ensure that public facing data relating to Registrants is accurate in compliance with PSA standards and requirements.

The JCCP has also continued to restrict access to its Level 7 practitioner register for Injectable Toxins, Fillers and Hair Restoration Surgery to suitably trained qualified and regulated Health Care Professionals only. This decision was reviewed by the JCCP Board of Trustees in September, 2024 when it was determined that such a restriction should continue to be enforced until the Government determines new standards for the award of a Practitioner Licence for aesthetic practice in England in 2026/2027. This remains the accepted policy position by the Council.

The Council has remained actively engaged throughout the year with beauty industry representative groups with the aim of promoting excellence in practice, education and training for the beauty sector. The JCCP meets regularly with representatives from The British Beauty Council, BABTAC, Habia and The National Hair and Beauty Federation. The JCCP has also continued to support a specific special interest group relating to ‘Safety and Beauty’ which is co-chaired by the JCCP Chair and by designated JCCP Trustee Victoria Brownlie MBE.

The JCCP has also continued to meet regularly with the British Beauty Council (and its affiliate members) and with the Chartered Institute for Environmental Health (CIEH) to discuss, agree and share opinion and advice with the aim of co-authoring and developing a range of position papers as part of an ongoing policy development exercise that has been designed to inform and influence the Government’s proposed licensing scheme for the non-surgical cosmetic sector in England and Scotland. This work has focussed on a wide range of cosmetic procedures themselves as well as premises from which such procedures are practised and the products, devices, machines and medicines used in their transaction.

The Practitioner Register Committee has also explored and considered arrangements for ‘Trainee’ specialist doctors and trainees who are registered on JCCP Approved Level 7 programmes of study to join appropriate parts of the JCCP Practitioner register.

The JCCP Education and Training Committee has also met regularly throughout the year under the Chairmanship of Professor Mary Lovegrove and has continued to provide oversight and governance for the JCCP ‘Competency Framework’ and ‘Standards for Education and Training’ provider organisations, exercising its role as ‘gatekeeper’ of the JCCP and CPSA competency standards. The Education and Training Committee continues to receive applications from Ofqual regulated Awarding Organizations and UK University education and training provider training organisations who seek to apply to enter the JCCP Register of Approved Education and Training Providers/Approved Qualifications. The JCCP Education and Training Committee has provided oversight for the audit and approval processes relating to the same.

Throughout 2024 the JCCP has again witnessed a significant rise in enquiries from education and training providers who are seeking approval from the JCCP for their qualifications and education and training provision. The JCCP also approved Acquisition Aesthetics (OTHM) and Interface Aesthetics (VTCT) this year to deliver their Level 7 programmes in Injectables. During the summer months the JCCP also reapproved OTHM and VTCT (Ofqual approved Awarding Organisations) as part of their triennial review to provide Level 7 qualifications in injectables. The JCCP also approved VTCT to deliver an RPL route for its Level 7 qualification in Injectable Therapies.

The JCCP continues to approve the University of Manchester, University of South Wales, Cosmetic Courses and the Harley Academy to deliver VTCT approved ‘Level 7 Diploma in Clinical Aesthetic Injectable Treatments’ courses and MAP-IQ to deliver an ‘RPL route for the VTCT approved qualification ‘Level 7 Diploma in Clinical Aesthetic Injectable Treatments’. An RPL route for the VTCT approved qualification ‘Level 7 Diploma in Clinical Aesthetic Injectable Treatments’ has also been approved by the JCCP for delivery by Cosmetic Courses and by the Harley Academy. The JCCP also continues to approve the Skin Appeal Training Academy to deliver the OTHM Level 7 qualification ‘Diploma in Clinical Injectable Aesthetic Therapies.

The Education and Training Committee also continues to approve Learna in association with the University of South Wales and both Cosmetic Courses and Harley Academy to operate and deliver JCCP Approved Assessment Centres in support of its ‘Fast Track’ scheme for practitioner registration as agreed with the PSA. The Fast Track Assessment Centre is delivered in strict accordance with JCCP Education and Training Committee policy guidelines and commitment to providing this alternative route to achieving full membership status to the JCCP Practitioner Register. Independent monitoring systems have been implemented during the reporting year to provide further assurance that the JCCP’s Fast Track Assessment Centres operate in accordance with JCCP standards and policy requirements.

The Education and Training Committee also recognises the GMC Plastic Surgery and the Dermatology Specialist Register qualifications as alternative routes to being benchmarked against the JCCP Competency Framework with the result that ‘equivalence’ has been formally approved between these two educational frameworks. In addition, the JCCP continues to engage with the British College of Aesthetic Medicine (BCAM) to formally approve and endorse the BCAM Knowledge/Theoretical and Practical examination components of their Membership Examination and associated Grandparenting Scheme.

The JCCP’s Education and Training Committee commissioned an internal Task and Finish Group to make recommendations on future standards and qualifications for non-surgical cosmetic practice undertake a desktop review of the JCCP/CPSA’s current ‘JCCP/CPSA Competency Framework’ (2018) and to make proposals on how aesthetic practitioners should be prepared to evidence their compliance with forthcoming DHSC Licensing standards (relating to requisite knowledge, practical competence and professional behaviours).

The Task and Finish Group was independently Chaired by Juliet Anderson (until recently Operations Director with Health Education England). The aim was to consider whether the current standards are still ‘fit for purpose’ and to undertake a ‘gap analysis’ of the current 2018 standards that we consider should be reflected in our proposals to revise the standards in association with the DHSC ‘industry’ standards when they are crafted in 2025 as part of the proposed Government’s licensing scheme for the non-surgical sector in England.

Members of the Task and Finish Group reviewed the 2018 JCCP/CPSA Competency Framework and confirmed that the 2018 competency standards (subject to updating) remained both relevant and ‘fit for purpose’ for adoption in the post-licensing era in England (and in the other three UK nations, subject to agreement with the relevant devolved Government Departments). In accordance with this aim the Task and Finish

Group considered potential new ‘modality’ specific standards that will need to be developed next year following the UK Government’s determination regarding which ‘licensable’ procedures will be included in their proposed ‘Green’, ‘Amber’ and Red’ categories.

The Task and Finish Group’s second task related to consideration of how practitioners should use independently verified evidence to demonstrate their compliance with the yet to be determined Government standards (Education, Training and Practical Competence and Professional/Ethical Behaviours). The Task and Finish Group considered a range of routes to qualification, and potential ‘alternative’ routes (for regulated experienced practitioners) to demonstrate compliance with the new DHSC industry standards (when they are produced) and proposed a series of ‘principles and recommendations’ for the Government to consider going forward (with particular regard to including a new credentialing route for suitably experienced regulated healthcare practitioners). Representatives from Ofqual also attended as members of this Task and Finish Group.

The outcomes and conclusions of the JCCP Task and Finish Group were published in June, 2024 in a JCCP report entitled ‘Recommendations on Future Standards and Qualifications for Non-Surgical Cosmetic Practice’ The report may be accessed via the following weblink.

The JCCP Education and Training Committee also revised its guidelines on CPD and formed a task and finish group between the members of JCCP Practitioner Register Committee and the JCCP Education and Training Committee in association with ‘The CPD Standards Office’ to consider how best to make proposals to oversee and ‘accredit’ CPD activities delivered by various and diverse training providers in the UK. The resultant report of this Task and Finish Group was produced in November, 2024 and may be accessed here.

The JCCP Education and Training Committee reviewed and revised the JCCP ‘Benchmark Statements for Universities and Awarding Organisations’ in April, 2024.

A new simplified online portal was also developed in year to enable Education and Training Providers to upload evidence documents in support of their applications to the JCCP to be considered for formal approval status with the Council.

The JCCP Education and Training Committee has also hosted four webinars throughout the year relating to emotional and psychological aspects of education and training, patient perspectives on education and training and on matters pertaining to the Government’s forthcoming aesthetics licensing scheme in England.

Two of the JCCP Trustees continue act as ‘Technical Experts’ for UKAS, enabling the introduction of UKAS accredited ‘certification of persons’ at the lower levels of practice.

The JCCP Marketing and Communications Committee has also continued to make excellent progress this year and continues to function actively under the active chairmanship of John Underwood, JCCP Trustee, supported by Paul Burgess and Zoe Cooper. The Committee continues to raise public awareness about the Council’s mission, values, register(s) and public protection, in support of the DHSC’s declared commitment to enhance public awareness about the risks associated with some of the more invasive procedure practised within the sector. A key focus of the Committee’s work has been to review and promote activities undertaken by the JCCP’s political campaigns (such as those associated with the JCCP’s engagement with the UK and Scottish Government’s Licensing Scheme) in association with the JCCP’s Key Opinion Leaders and sector ‘Influencers’ and partner associations regarding debates and publications relating to the potential implementation of the long-awaited national system of licensing for the aesthetics sector in England.

The Committee’s membership has been refreshed and has met regularly throughout the year and continues to be supported by a range of expert Key Opinion Leaders to promote the work and image of the Council. Three new Key opinion Leaders were appointed in 2024: Dr. Patrick

Treacy, Dr. Dalvi Humzah and Julie Scott.

The Committee also led on the enhancement and population of both the JCCP’s dedicated public facing web site – JCCP & me and its main website.

The Marketing and Communications Committee has provided a forum for national discussion and debate regarding patient safety and public protection which also served to promote the work of the JCCP during 2024/25. Engagement at national conferences and industry trade shows provided the opportunity to further disseminate the JCCP’s ‘Narrative’. Members of the JCCP Board of Trustees attended multiple face-to-face events during 2024. The JCCP has also continued to rely purposefully on the use of social media to disseminate key messages to members of the public and to practitioners. Responsibility for the JCCP’s social media portfolio transferred to Hamilton Fraser in 2024. Excellent relationships have also been maintained and developed further with both the professional and aesthetic press/media sector, supported by the publication of regular articles and papers and conference presentations, including the provision of a monthly publication column with the Journal of Aesthetic Nursing and chairing their national conference in November, 2024. The JCCP has also continued to liaise and collaborate with other media fora to raise public and practitioner awareness of our shared mission to improve public protection and patient safety. Throughout the reporting year a range of purposeful and well received webinars have been transacted in support of the JCCP’s public protection and patient safety mission.

Zoe Cooper, the JCCP Project Development Officer, has assumed responsibility for the production and publication of monthly articles throughout the course of the reporting year. These articles promote matters of contemporary public and professional interest relating to a range of topics relating to public protection, patient safety, governance, body image and clinical enhancement. A range of interactive online guides, aimed at raising standards in aesthetic practice have also been launched this year. One such guide is entitled ‘The Insurance Guide: General Principles for Safe and Effective Insurance Cover’ and the JCCP Education and Training Committee's ‘Recommendations on Future Standards and Qualifications for Non-Surgical Cosmetic Practice’.

Other guides that have been released relate to ‘Avoiding Misleading Training Courses: Tips for Practitioners’, ‘Protecting Minors in Aesthetic Practice’, and ‘Best Practices for Education and Training Providers in Aesthetic Medicine, all of which have been designed to support ethical practices and professional growth. A further guide relates to ‘Mindful Aesthetics’, led by JCCP Trustee, Kimberley Cairns, explores the link between mental well-being and aesthetic practices. Unlike traditional articles, these interactive guides offer a more engaging learning experience, allowing users to actively interact with the content through clickable elements, multimedia, and real-time feedback.

The Marketing and Communications Committee also spearheaded a most successful campaign to ensure that the UK Government acts in a timely manner to enact the long awaited DHSC proposed licensing scheme for England. This campaign included the publication of public and stakeholder facing online briefing documents. The Committee has also actively promoted the Scottish Government’s 2024 consultation on non-surgical cosmetic licensing and regulation.

The JCCP’s Corporate Membership Scheme has thrived again this year, enhancing the JCCP’s capability and capacity to raise charitable funds with the aim of enhancing public protection and patient-safety-related activities within the aesthetics sector. In excess of £123,000 has been raised this year through this fundraising scheme which has enabled the JCCP to further its activities with regard to the promotion of patient safety and public protection (including the construction of a new patient/consumer facing website).

The JCCP reviewed and extended its memorandum of understanding with sk:n (in association with Optical Express) in October, 2024. This renewed partnership has been widely celebrated and is built on a shared commitment to ‘to enhance patient safety and public protection within the aesthetics sector and to work together to bring stakeholders together to unite around key safety/policy themes’. Shared activities have included major campaigns to develop models of robust evidence-based shared governance and co-production to improve public protection, patient safety, the promotion of evidence-based practice, and activity data collection/audit and to raise awareness of key patient safety issues regarding the sector with the public and, practitioners and education/training providers.

During 2024 the JCCP entered into an agreement to work with Healthxchange as a new corporate member. Our work with this corporate member has enabled the JCCP to successfully campaign for promotion of enhanced prescribing and dispensing standards for the cosmetic sector in support the new proposed licence for non-surgical practice in England and Scotland.

The Council is also working with other corporate partners to promote best practice in the manufacture, supply and use of medicines and products with the aim of enhancing health protection, infection control, medicines optimisation and patient safety. One such campaign was sponsored in partnership with Galderma and relates to the co-production of guidelines for the safe and ethical distribution and supply of dermal fillers. A further co-production project was transacted in association with Church Pharmacy relating to the safe and ethical procurement and supply of all products (including medicines) that fall within the remit of aesthetic practice (and within the purview of the proposed Licensing scheme). Corporate partners are represented within the JCCP as members of the Clinical Advisory Group (CAG) and the Trustee Board. This year the JCCP’s Clinical Advisory Group also

produced a paper relating to ‘Cosmetic procedures. Prescribing, supply and dispensing appropriate quantities.

The JCCP continues to transact a very active and productive partnership with the Aesthetic Complications Expert Group World (ACE). The partnership functions with the aim of enabling the JCCP and ACE to work together to promote best practice and standards in the aesthetic industry in furtherance of a shared commitment to public protection and consumer safety/awareness. This partnership has continued throughout 2024, providing mutual benefits for registrants and

members by supporting them to raise and share issues of concern regarding activities of aesthetic practitioners, where client/patient safety/public protection has been considered to have been compromised and to encourage aesthetic practitioners to engage in reflection and continuous professional development in order to further develop and improve their practice.

The JCCP (alongside ACE) has also called for the design and implementation of nationally agreed process for the reporting and analysis of complications and adverse incidents and has been working closely with the MHRA and other sector colleagues (such as Dr. Steven Land and Emma Stock) in pursuit of this objective. The JCCP published guidelines for the reporting of adverse incidents this year. This guidance statement acts as a reminder to all regulated healthcare cosmetic practitioners of their professional obligations in reporting adverse incidents. It also serves to highlight the ethical responsibility that unregulated practitioners have in doing the same. This statement concerns the reporting of both medicines and medical devices of all types that fall within the remit of the Medicines Healthcare products Regulatory Agency, and where facility is provided through its Yellow Card

scheme to enable such reporting. The JCCP considers that an improved data set of adverse incidents will inform the ongoing development of public protection-related regulations within the sector (including the design of the new proposed licensing standards and framework).

Positive working relationships have also been maintained and transacted with the British Association of Medical Aesthetic Nurses (BAMAN) with particular regard to the promotion of patient safety and public protection, education and training standards and prescribing practice standards. BAMAN and the JCCP signed a memorandum of understanding on the 10^th January, 2025.

With regard to fiscal and constitutional compliance the JCCP once again remains recurrently ‘solvent’ and has been able to attract charitable support from a range of benefactors who have again this year offered their services (without charge) to enable the Council to maintain its operational functions. During 2024 the JCCP was able to return a healthy surplus that has enabled the Council to continue to appoint a salaried Project Development Officer. The purpose of the Project Development Officer role has been to ensure the smooth and effective leadership, management, operational delivery and coordination of a range of work streams, projects and relationship management tasks relating to the running of the JCCP. This has also included oversight of the JCCP Operational Plan, including the operational management of projects, adhering to their financial allocations if applicable. The post

holder has also been responsible for the co-ordination of all marketing and communication services, social media accounts, website management and liaising with JCCP appointed contractors. The post holder has also assumed responsibility to assist in the co-ordination, screening and management of complaints received by the JCCP.

The JCCP Board Trustees are fully cited on these matters and share the responsibility of assuring the PSA of the diligent and prudent approach that the JCCP has taken with regard to managing and implementing its fiscal processes and quality assurance requirements relating to the maintenance and publication of a Registrant database and in the transaction of its responsibilities to members of the public and to stakeholders.

Two patient advocate representatives are appointed to the JCCP Trustee Board as full voting Trustees, supported by six other lay Trustees and seven Practitioner/Sector Stakeholder Trustees/Members.

The JCCP and CPSA hosted a virtual Stakeholder Council meeting during 2024, Chaired by Dr. Tamara Griffiths, President of the British Association of Dermatologists. The Stakeholder Council provides a conduit of engagement with the JCCP Trustees and with the Council and its sub-committees. The key themes for this stakeholder event related to patient safety, public protection, raising public awareness and messaging regarding safety in the aesthetics sector and an update on proposals for the implementation of a national system of licensing for the aesthetic sector in England.

The JCCP has also continued to maintain an excellent working relationship with the CPSA, underpinned by a robust Memorandum of Understanding and reciprocal Board membership. Throughout 2024 the JCCP and CPSA continued to meet regularly and to review, promote, implement and disseminate its Code of Conduct and clinical practice standards. Registrants have been reminded of the importance of complying with the JCCP/CPSA Code of Conduct (May, 2023) at all times. This document may be accessed via the JCCP website.

The key focus of the JCCP’s engagement with the CPSA this year has been to consider invasive BBL and liposuction-related procedures and emergent non-surgical procedures and to prepare for the Government’s licencing/regulatory schemes for England and Scotland.

The JCCP has fully complied with its published Policy Statements on Complaints (2023), Equality, Diversity, and Inclusivity (November, 2021) Safeguarding (November, 2021) and Boundary Setting (2023), Statement on Bullying, Undermining and Harassment Guidance (2023), Raising Issues of Concern (Whistleblowing) Policy (2023). The JCCP confirms that all other policies, procedures, and governance arrangements remain fit for purpose. All policies and procedures have been shared routinely with the PSA. The JCCP also confirms that it possesses appropriate insurance and employer liability cover and remains in good financial and corporate governance standing with both the Charity Commission and with Company’s House.

The JCCP website and practitioner register has continued to be updated throughout the reporting year. The total investment made to the building, revision, and maintenance of the JCCP Practitioner Register during 2024 has been in excess of £24,000 and has been generously funded by HF Resolution Ltd.

The JCCP Board of Trustees confirms that there have been no legal or constitutional challenges to the work of the JCCP or to its published governance arrangements/procedures. Relationships with external bodies have been excellent, encouraging, supportive and most productive. All Memoranda with Professional Regulators remain valid and where applicable all have been renewed during 2024.

_{JCCP Annual Report}

^{The JCCP’s Continued Contribution to the Regulation in England and Scotland}

The JCCP has been campaigning for the implementation of new a new system of governance, supported by robust practice, premises and education and training standards for the aesthetic sector within the four countries of the UK since 2016. Our aim was partially realised following the enactment of the Government’s ‘Health and Care Act’ came which came into force on 1 July, 2022 in England and by the Scottish Government in December, 2024 through the launch of their consultation paper on the regulation/licensing of non-surgical cosmetic procedures.

The second half of the 2024 reporting year has been characterised by a period of slow progress and reduced engagement with the UK Government regarding their response to their consultation on non-surgical cosmetic licensing (which attracted 11,800 responses by November, 2023).

The JCCP remains firmly committed to the enactment of all of the key

proposals included in the DHSC consultation document (September, 2023) and has advised the UK Government that an urgent communication is required to enable an ongoing constructive dialogue to continue with members of the public and stakeholders in the interests of patient safety and public protection in this sector. As an eclectic stakeholder organisation, the JCCP relies upon consultation with multiple representative membership groups, regulators, the pharma and insurance industries and of course with members of the public.

In the ‘Next Steps’ section of the DHSC’s September, 2023 consultation paper the Government advised that they would ‘set a baseline of what members of the public and stakeholders in the cosmetic sector will expect from any forthcoming announcement’ and affirmed that they would ‘seek to publish the details of the responses received and our finalised policy positions in a timely way to ensure progress is made on this important work. From the date

the consultation closes and throughout 2024 and 2025, we will work with expert groups on the elements that will underpin the licensing scheme, including education and training standards, insurance, infection control and hygiene qualifications and a fees model. This will inform future public consultations on specific elements of the licensing scheme, which will include assessments on the economic and equality impacts of the proposed changes. We will then work to finalise the regulations and implement the licensing scheme. We anticipate there will be a set lead in time or a transitionary period before the licensing scheme is in full operation across England’.

The JCCP has reported that the delay in the UK Government’s publication of their full response to the 2023 consultation has created significant uncertainty and ambiguity for members of the public and for stakeholders. The JCCP is of the opinion that this delay has certainly led to an increasing number of social media posts, ‘rogue’ practitioners and training companies exploiting this ‘governance vacuum’ which has resulted in actual harm being occasioned to members of the public (particularly to those persons who have elected to receive BBL and liposuction-related procedures from non-regulated and untrained persons).

In response to a range of alarming reports that such invasive procedures were being performed inappropriately by unqualified persons the JCCP became actively involved in seeking the introduction of urgent government regulation to restrict procedures such as Brazilian Butt Lifts (BBL) and others across the aesthetics sector. The JCCP reported in May 2024 that ‘in recent years we have seen a growing prevalence and normalisation of non-surgical cosmetic procedures, associated with the rise of social media, the increasing accessibility and affordability of providers and the advancement of technologies and products in this field’. Alongside, the British Beauty Council (BBC0) and the Chartered Institute of Environmental Health (CIEH) the Joint Council for Cosmetic Practitioners (JCCP), has called upon the UK Government and devolved nations to introduce emergency legislation to ensure that invasive procedures, such as liposuction and BBL are performed only by appropriately qualified General Medical Council (GMC) registered doctors.

A subsequent guidance document entitled ‘Buttock Augmentation and other Body Contouring Procedures. -Guidance for Local Authority Environmental Enforcement Officers (authored by the Chair of the JCCP Clinical Advisory Group, Andrew Rankin in association with key professional stakeholders) was published in October, 2024. This guidance document refers to the injection of any product, including dermal fillers or autologous fat, intended to augment the buttocks. Requests for assistance in relation to this procedure have been received from a range of UK wide Local Authority Environmental Health Officers with a responsibility for enforcement. Equal concern has been raised regarding the injection of products into the breasts and the genitals, and this activity is also captured in this guidance. The conclusions expressed in this guidance document are the result of professional and expert assessment. They recognise the surgical nature of buttock, breast and genital augmentation as being ‘surgical’ in nature, as defined by the Royal College of Surgeons and the British Association of Aesthetic Plastic Surgeons. We are indebted to these organisations for their expert contribution and to the many health protection and healthcare professional practitioner representatives who provide expert advice to support local authority and other regulatory officers.

It is in this context that the JCCP has written to support the UK Government’s proposal to apply a sequential approach to a legally enforceable scheme of licensing, commencing with immediate legislation to restrict the procedures referred in the last three paragraphs, (with the caveat that the Government remains committed to ensuring that any such scheme of licensing is legally implemented and enforced as soon as possible to cover all procedures included in the Government’s final determination of ‘green’, ‘Amber’ and ‘Red cosmetic interventions).

More specifically we have also advised that the UK Government should urgently prepare and publish a statement outlining the Government’s commitment to publishing the full response to their September 2023 consultation (and a date advising when this will be published – presuming that you will not be publishing the full response along with the January communication which would be our preference). We have also requested that the UK Government should publish a statement regarding the priority and contingent timeline that they are proposing to give to legislating for the restriction of ‘Red’ cosmetic surgical procedures to be provided by appropriately trained and experienced GMC Registrants along with a firm commitment to publish a comprehensive timeline for the full enactment of the cosmetic licensing scheme for all agreed ‘Green’, ‘Amber’ and non-surgical ‘Red’ procedures in your proposed statement by April, 2025’.

The JCCP has reiterated its request to the UK Government that it will honour its previously declared ‘intention to work with expert groups on the elements that will underpin the licensing scheme, including education and training standards, insurance, infection control and hygiene qualifications and a fees model”, supported by an indicative ‘next steps’ timeline’. A further request related to the UK Government providing an endorsement of their intention to use the outcome of their work and engagement with ‘expert groups’ to “inform future public consultations on specific elements of the licensing scheme”, such as the co-design and development of underpinning knowledge and practice competence education and training standards’.

The JCCP also remains firm in its position the responsible Government Departments in all four UK nations should be required to acknowledge and commit to the formulation and implementation of a mandated minimum education and training standard as a core component of any future scheme of regulation/licencing. The JCCP believes that this is essential to ensure patient safety and thus should be a central pillar of a future licensing regime. We have

already advised that the Joint Council of Cosmetic Practitioners in partnership with the Cosmetic Practice Standards Authority (CPSA) has already developed a competency framework covering high-risk non-surgical cosmetic procedures. The JCCP and the CPSA look forward to contributing to this agenda discussion.

The JCCP has also been working apace with the Government and with the Advertising Standards Authority (ASA) to introduce more robust and assertive regulation on advertising and social media. During the reporting year the Government has outlined plans to strengthen medical devices regulation, including extending UKCA mark recognition as part of transitioning to a future regime and the scope of regulations to capture certain non-medical products with similar risk profiles to medical devices – this includes dermal fillers. The JCCP has advised that as an additional public protection measure that advertisements (across all media channels) should ‘include the requirement to display a kitemark and a warning logo on any advertisement for treatments that fall within the licensing regime’s scope’.

The JCCP’s Clinical Advisory Group (CAG) continues to advise that all aesthetic procedures that are considered to be invasive, complex or present with a higher risk of complications should be restricted and limited exclusively to qualified and regulated healthcare professionals (i.e., those procedures cited in the UK Government’s proposed ‘Red’ category and in the Scottish Government’s ‘Third’ category). Furthermore, the JCCP has urged the DHSC and Scottish Government to put in place a robust and stringent scheme of regulatory enforcement that is supported by a legislative framework that

mandates all practitioners to comply with nationally endorsed and implemented education and training standards, fit and proper person ‘tests’, robust insurance set at appropriate levels for medical indemnity, complaints procedures and access to redress schemes and compliance with the need to work from safe, hygienic and health-protected premises.

We have further advised that members of the public require additional assurance to confirm that registered healthcare professionals will meet the new standards set down by UK Government Departments within the context of the new practitioner license, whilst also recognising their right to autonomy and clinical decision-making without supervision (unless they do not possess a prescribing qualification and use prescription only medicines as part of their aesthetic practice). We continue to report that is therefore essential that registered healthcare professionals who do not hold a nationally recognised and mandated prescribing qualification should also require supervision from a prescriber when prescription only medicines form part of the patient’s treatment plan or where they may otherwise become necessary to treat complications. We acknowledged that this would require further

determination and consideration. The JCCP also called upon the Government to set out proposals and parameters to define whom they regard to be a suitable and responsible ‘professional health care practitioner’. We consider this to be a fundamental requirement since there are many healthcare professional groups that are regulated by professional statutory regulatory bodies whom we do not regard to possess the requisite competence, experience and knowledge to perform nonsurgical cosmetic procedures or to provide supervision of oversight to non-professional healthcare practitioners.

The JCCP also strongly advised of their agreement with proposals to seek significant changes to CQC (and to other UK associated healthcare quality regulators) regulations to include restricted high-risk non-surgical cosmetic procedures within the scope of the CQC's registration system. We have advised that the DHSC should engage as soon as possible to determine the extent to which any proposed scheme of regulation that encompasses the more invasive and complex procedures can be enforced by the CQC in the absence of a significant change in the current scope of regulatory enforcement practice. The JCCP’s response was predicated on the need for the DHSC to introduce robust powers of enforcement to ensure that non-healthcare practitioners are not permitted to administer any restrictive procedure that falls within the scope and definition of the ‘RED’ category as proposed within their consultation document. In order to achieve these objectives, the JCCP considers that the CQC will also need to expand its definition of the ‘Treatment of Disease, Disorder or Injury’ (TDDI) to provide scope for the inclusion of a range of aesthetic procedures that are either ‘medical’ or ‘medically related’ in respect of their description/definition and

the use of medicines in accordance with the terms of their licenses. The JCCP has worked closely throughout the reporting year with the CQC, the Royal College of Surgeons and a range of professional associations/membership bodies and with the MHRA to reach agreement and alignment on how members of the public might be best protected when seeking both surgical and non-surgical cosmetic procedures.

Central to our response to UK Government departments was our advice that the Government should undertake to ensure that all procedures that involve the use of a prescription only medicine that is part of the actual procedural application, as an adjunctive requirement, such as the use of Lidocaine or Adrenaline, or any procedure that could involve the use of a prescription only medicine to manage an urgent complication arising from an aesthetic procedure should be supervised by a professionally, regulated prescriber who is present on site when the procedure itself is conducted. Should this not be agreed then we advised that any such procedure should be moved to the Government’s proposed ‘Red’ category in the interests of public protection and patient safety.

We have also advised UK Government Departments that we consider it necessary to define what is meant by ‘supervision’ and ‘oversight’, and also to determine who could be considered to be an appropriate supervisor for specific procedures. We stated that the concept of supervision would need to be determined in accordance with a risk assessment undertaken for each of the procedures that are determined to be included in national licensing/regulatory regimes on a procedure - by - procedure basis. The JCCP considers that a proportionate approach to the definition of supervision should be taken on the basis of risk to members of the public related to the level of complexity, invasiveness and the potential for complication that the procedure itself might present or where there is consistent evidence of abuse of or lack of compliance with current regulations.

The JCCP will continue to call for other additional measures to supplement the proposed licensing system:

The need for extended powers to be given to the CQC/HIS to inspect all premises where invasive procedures that are included in the license are to be performed.
To seek an assurance that the CQC/HIS will develop a memorandum of understanding with local authority licensing organisations to perform an integrated and enhanced scheme of regulation for aesthetics to avoid duplication for those healthcare professionals who are already registered with the CQC/HIS.
To call for the implementation of a national register of approved qualifications and of approved education and training providers.

To consider whether the PSA could be given extended powers to oversee registers of approved education and training providers and qualifications in the sector in addition to their current statutory function of overseeing practitioner registers.
Ofqual/SQA to be requested to ensure that they only approve qualifications in the future that meet the new Government standard for education and training for the aesthetics sector.
National, mandatory education and training standards to be introduced for all practitioners who practise in the industry.
The legal enforcement of the requirement for all practitioners to have an appropriate level of medical indemnity insurance and to provide a transparent redress scheme for service users.
National scrutiny and action to prevent the promotion through social media of unsafe, unethical and exaggerated messaging about products, education, training and aesthetic service provision.

The JCCP is also aware that a range of potentially harmful and unlicensed ‘products’ and devices are also being supplied and administered as part of a number of cosmetic procedures. The JCCP is reviewing many of these devices, ‘machines’ and products and is advising the MHRA of the need to introduce rigorous controls regarding the importing, manufacture and supply of such products and devices.

The JCCP remains committed to advise and support the Scottish Government to achieve the design and implementation of a robust scheme of regulation and governance for the non-surgical cosmetic sector in Scotland as set out in its consultation document (December, 2024). The JCCP produced a press release to promote the laudable aims included in this consultation document in December, 2024.

In Wales new arrangements for mandatory licensing of tattooing, skin piercing, acupuncture and electrolysis are being put into place. Under the Public Health (Wales) Act 2017 the Welsh Government may add procedures to these arrangements but have not announced any intention to do so at this time. The JCCP has been actively engaged with the Welsh Government at all stages of the formulation, consultation and enactment of this new policy change.

The Northern Irish Executive has not announced any current plans to introduce regulation in the non-surgical cosmetic sector.