Aesthetics spoke to members of the Scottish aesthetics community about the landmark Non-surgical Procedures and Functions of Medical Reviewers Bill which the Scottish Parliament voted to pass. Aesthetic practitioner and dental surgeon Dr Emma Ravichandran, describes the Bill as a “significant and necessary step forward for the aesthetics sector.” For established medical clinics, Dr Ravichandran believes the Bill helps create a more equitable and transparent landscape. “Those already operating to high clinical and ethical standards will be better distinguished from providers who do not meet the same level of medical oversight,” she explains.
Director at the British Association of Medical Aesthetic Nurses (BAMAN), Amanda Demosthenous, welcomes the new legal offence for treating under-18s, noting it addresses a long-standing concern and establishes a key safeguarding measure. She continues, “At a system level, the inclusion of ministerial powers to define procedures, specify provider requirements, and introduce training and supervision standards is particularly important.” However, Demosthenous adds that the Bill should be viewed as foundational rather than complete. She notes, “There is currently insufficient immediate clarity on scope of practice. This creates a risk that higher-risk procedures including injectables and advanced energy-based treatments may continue to be delivered without appropriate medical oversight during the interim period.”
Aesthetic practitioner Dr Nestor Demosthenous believes the Bill signals that non-surgical practice is being taken seriously as a healthcare-adjacent field. “Over time, that should encourage better training pathways, stronger clinical governance and a more professional culture across the discipline,” he says. Dr Demosthenous adds that the real test will be in the secondary regulations, the guidance the Scottish Government is required to issue, the enforcement powers exercised by Healthcare Improvement Scotland and the willingness to review and strengthen the regime over time. “The fact that the offence relating to procedures outside permitted premises will not come into force before September 6, 2027, also shows that there is still a transition period ahead,” he says.
In addition, Dr Ravichandran feels there should have been greater emphasis on the management of complications included within the Bill. “This should include clear protocols and appropriate indemnity requirements, which would further enhance patient protection,” she says. Aesthetic practitioner Dr John Elder notes that particular areas of concern within the Bill are lasers and the treatment of minor skin lesions with cryo-cautery. He explains, “Unlike in England, there is no compulsory local authority licensing of non-medical laser provision – the Bill refers to ablative lasers but seems to consider the use of laser and intense pulsed light for the treatment of other skin conditions to be acceptable.”
Dr Elder raises concern with the lack of diagnostic skills, as recognition of significant skin lesions can be challenging even for skilled clinicians, and that it is inappropriate for non-medically qualified practitioners to be diagnosing and treating such cases. He concludes, “The same concerns regarding diagnosis also apply to non-medical practitioners offering cryotherapy – currently a growing beauty add-on.”