The New Licensing Scheme for Non-Surgical Cosmetic Procedures: What's Coming and How to Prepare (2026)
Written by Dr Tom Fisher, GP and founder of Fisher Clinics. Last reviewed 24/08/2026.
For years, one of the strangest features of aesthetics in England has been how little control there is over who can inject. As things stand, there is no general legal requirement to hold any particular qualification to perform most non-surgical cosmetic treatments. That is set to change. The Government has committed to a licensing scheme for non-surgical cosmetic procedures in England, and it will reshape who can do what, and where.
This guide explains what has actually been decided, what is still only proposed, who is likely to run the scheme in practice, and how to prepare, without pretending the detail is settled when it is not.
(This is a fast-moving area of policy. This guide reflects the position at the date above and focuses on England; the other UK nations are developing their own approaches. Because the scheme is not yet in force and the detail is still being worked out, treat this as an overview of direction rather than a final rulebook, and check the current position before making decisions.)
The quick answer
A national licensing scheme for non-surgical cosmetic procedures in England is coming, but is not yet in force.
The legal power to create it already exists, through Section 180 of the Health and Care Act 2022.
The Government ran a consultation in 2023 and published its response in August 2025, confirming it intends to proceed and to tackle the highest-risk procedures first.
The proposed model sorts procedures into red, amber and green risk categories, with different requirements for each.
Local authorities are set to run the licensing scheme for the green and amber tiers, while the highest-risk (red) procedures are to be brought under the Care Quality Commission (CQC) instead.
In the 2023 consultation, botulinum toxin and facial dermal fillers were proposed for the amber (medium-risk) category, which would allow suitably qualified non-medics to perform them under the clinical oversight of a named regulated healthcare professional. The final categorisation has not yet been confirmed, and the 2025 response acknowledged that this remains under discussion.
You would likely need both a personal licence and a premises licence, plus evidence of training, indemnity and safe practice.
A further public consultation is expected before the scheme is finalised, and the detailed rules will need secondary legislation and parliamentary approval.
Nothing here is law yet. But the direction of travel is clear, and there are sensible steps you can take now.
Why a licensing scheme, and why now?
The concern is long-standing. Non-surgical cosmetic procedures have grown enormously, while the controls on who can perform them have not kept pace. Botulinum toxin is a prescription-only medicine and must be prescribed by an authorised prescriber after an appropriate face-to-face assessment, but there has been no general legal restriction on who may actually inject it once prescribed, while dermal fillers do not generally require a prescription and have historically been subject to much less control over who may administer them.
That gap is what the licensing scheme is designed to close. The aim is a consistent set of minimum standards for training, hygiene and infection control, insurance and safety, so that patients can expect a baseline of competence and safety wherever they go.
The red, amber and green model
The heart of the proposals is a risk-based classification. Procedures would be placed into one of three categories, each with different requirements.
Green: lower risk. These could be carried out by any licensed practitioner who meets the agreed standards, without a requirement for healthcare-professional oversight.
Amber: medium risk. In the 2023 consultation, this was the category proposed for botulinum toxin and facial dermal filler treatments. The proposal was that these could be performed by qualified and licensed practitioners, including suitably trained non-medics, but under the clinical oversight of a named, regulated healthcare professional such as a doctor or prescribing nurse.
Red: highest risk. These would be restricted to regulated healthcare professionals working in CQC-registered premises, and would sit under the CQC rather than the licensing scheme. Examples discussed include the more invasive procedures, such as fillers used to augment the breasts, buttocks or genitals (the "liquid BBL"), high-risk body contouring and thread lifting. The Government has said it will prioritise regulating these highest-risk procedures first.
Two things are important here. First, the precise allocation of procedures to each category has not been finalised. The 2025 response reaffirmed the tiered approach in principle, but specifically acknowledged disagreement about the amber category and said the supervision requirements and other details still needed further work. Second, this allocation is likely to be a focus of the further consultation, so it should not yet be treated as settled.
Who will run the scheme, and what will you practically need?
This is the question most practitioners actually want answered: in practice, who will I be dealing with, and what will I need to have in place? Based on the proposals, the picture looks like this.
Local authorities (councils) would run the licensing scheme itself. For the green and amber tiers, which is where botulinum toxin and dermal fillers are currently proposed to sit, councils are set to be the licensing and enforcement body. This mirrors how local authorities already license activities such as tattooing and skin-piercing, so it is a natural fit. In practice, that means your licence application, your fees and any inspection or enforcement for standard injectable work would most likely go through your local council.
The CQC would handle the highest-risk (red) procedures. These fall outside the local-authority licensing scheme and instead require CQC registration, with treatment restricted to regulated healthcare professionals in CQC-registered premises. Enforcement of the rules for these procedures, including financial penalties, would come through the CQC. (If you want to understand how CQC registration already works, and the medical-versus-cosmetic distinction that triggers it, see my separate guide on CQC-regulated and non-regulated activity.)
Your professional regulator continues alongside all of this. The licensing scheme sits on top of professional registration, it does not replace it. A nurse, doctor, dentist or pharmacist would still answer to the NMC, GMC, GDC or GPhC as now, and would also need to meet the licensing requirements. Voluntary bodies such as the JCCP sit alongside the statutory framework but do not have legal powers of their own.
What a typical amber-tier practitioner would likely need. Nothing here is finalised, but across the proposals a consistent practical picture emerges. To carry out botulinum toxin and dermal filler treatments, you would probably need:
a personal licence confirming you meet the training and competence standards for the procedures you perform;
a premises licence for the location you work from, covering hygiene, infection control and suitability;
appropriate clinical oversight by a named regulated healthcare professional, if the amber proposal is retained and you are not a healthcare professional yourself;
proper prescribing arrangements, since botulinum toxin remains a prescription-only medicine requiring a face-to-face assessment by the prescriber;
adequate indemnity or insurance for exactly what you do;
evidence of accredited training and ongoing CPD; and
continued professional registration, if you are a healthcare professional.
The exact standards, fees and application process are still to be set, so treat this as the likely shape rather than a checklist you can complete today.
The question everyone asks: can non-medics still do Botox?
This is the most contested part of the proposals, so it is worth being precise about what has and has not been decided.
Under the 2023 proposals, botulinum toxin and facial dermal fillers fell in the amber category. That approach would not restrict them entirely to doctors, dentists and nurses. Instead, suitably qualified and licensed non-medics could continue to perform them, provided they worked under the clinical oversight of a named regulated healthcare professional.
This has been genuinely controversial, and it is not settled. Some professional bodies argue that injectables should be restricted to regulated healthcare professionals only. Others support a model that allows trained non-medics to continue, with oversight and standards. The 2023 proposals sat closer to the second position, but the Government's 2025 response acknowledged the disagreement over the amber category and left the detail, including supervision requirements, for further work. So the honest answer is that no one can yet say with certainty what the final rules for non-medics will be.
Two things are worth holding in mind whatever the licensing scheme eventually says about administering. First, the separate rules on prescribing still apply: botulinum toxin remains a prescription-only medicine, and prescribers must meet their regulator's prescribing standards. Second, because this is a proposal rather than settled law, the position could change at the next consultation.
A two-part licence: practitioner and premises
The proposed model is expected to involve two connected licences: a personal licence for the practitioner, confirming they meet the training and competence standards for the procedures they perform, and a premises licence for the location where treatments are carried out, covering hygiene, safety and suitability.
In broad terms, you would need both. A licensed practitioner working from unlicensed premises, or licensed premises used by an unlicensed practitioner, would not satisfy the scheme. As above, local authorities are expected to issue and oversee these licences for the green and amber tiers, with the detail of how they will be issued, by whom exactly, and at what cost, still being developed.
What still has to be decided
It is easy to read coverage of this scheme and assume it is already in force. It is not. Several important elements remain to be settled, and the Government itself has acknowledged that further work is needed on:
the educational and training standards required for each category;
infection prevention and cleanliness requirements;
indemnity and insurance requirements;
licensing fees and how the scheme will be funded;
the precise categorisation of individual procedures, including whether toxin and fillers remain amber;
the detail of how local authorities will operate the scheme; and
the timetable, including any transition period.
A further public consultation is expected, and the final rules will require secondary legislation. So while the direction is clear, the specifics are not yet fixed, and practitioners should be cautious about any source presenting the fine detail as settled.
The under-18 position
England already has one firm rule in this area. Under the Botulinum Toxin and Cosmetic Fillers (Children) Act 2021, it has been a criminal offence since October 2021 to administer botulinum toxin or filler by injection for a cosmetic purpose to anyone under 18, and arranging such treatment is also an offence, subject to limited statutory exceptions.
Separately, the proposed licensing scheme has considered how age restrictions should apply to other procedures within its scope, including whether limited exceptions should apply where treatment is medically approved. Those proposals should not be confused with the existing statutory restrictions on cosmetic botulinum toxin and filler injections for under-18s, which remain in force and are unaffected.
What about the rest of the UK?
The licensing scheme discussed here is for England. The other nations are moving separately, and in some respects faster:
Scotland has been progressing its own legislation on non-surgical cosmetic procedures, with proposals to restrict certain treatments to regulated healthcare professionals in appropriate settings and to set training and qualification standards.
Wales and Northern Ireland are developing their own positions, and the Health and Care Act power extends to Wales as well as England.
If you practise in more than one nation, or near a border, you will need to follow each nation's rules as they develop, and they may not be identical.
How to prepare now
Even though the detail is not final, the direction is clear enough to act on sensibly. Waiting until the scheme is in force is likely to leave you rushing. Practical steps:
Invest in recognised, accredited training for the procedures you perform, at a level appropriate to their risk. Whatever the final standards, credible training will count in your favour.
Keep your CPD current and be able to evidence it.
Sort out proper indemnity and insurance that genuinely covers what you do, and keep the documentation.
Get your prescribing arrangements right now, with a proper face-to-face assessment, because that requirement already applies and is not going to loosen.
Look honestly at your premises against likely hygiene and safety expectations, since premises licensing is central to the scheme.
Keep clear records of your training, your cases and your professional development, so that when licensing arrives you can demonstrate your standards rather than reconstruct them.
Follow reliable sources as the further consultation and legislation appear, rather than relying on sector rumour.
The through-line in all of this is being able to show that you already practise to a high standard. A licensing scheme rewards the practitioners who can evidence their training, competence and safe practice, and disadvantages those who cannot.
Keeping the evidence as you go
Much of preparing for licensing comes down to being able to show, rather than just assert, how you practise: your training, your ongoing development, and a clear picture of the treatments you carry out.
That is one of the reasons I built Aesthetics Logbook: a simple app for logging your treatments and CPD as you work, with space to capture reflections and feedback against each entry too. It is built around how aesthetic clinicians actually practise, and avoids storing direct patient identifiers to support data-minimisation. Your case numbers, activity and professional development build quietly in the background, ready for appraisal, revalidation, an insurer's query or, in time, a licensing requirement, rather than being reconstructed from memory. It does not replace the full clinical record, your training and licensing obligations or your indemnity arrangements, and you remain responsible for your own confidentiality and UK GDPR obligations. If that would help you keep your evidence in order, you can find it at aestheticslogbook.com.
This guide is for general information and reflects the position in England at the time of writing. The licensing scheme for non-surgical cosmetic procedures is proposed but not yet in force, and the detail is subject to further consultation and legislation. Always check the current position through official sources, and take professional advice where a decision depends on the final rules.
