Aesthetics explores the Government’s proposals for tighter rules on who can perform high-risk procedures
The Department of Health and Social Care (DHSC) has announced a consultation on proposals to restrict high-risk cosmetic procedures to regulated healthcare professionals.
Under the draft rules, injecting filler into parts of the body other than the face would be legally classified as cosmetic surgery. This would include liquid Brazilian butt lifts (BBLs), in which filler is injected into the buttocks, and would therefore mean that only doctors could perform the procedures. Other treatments classed as high risk, including deep chemical peels, platelet-rich plasma (PRP) facials, dermal micro-coring and certain laser procedures, would be restricted to doctors, dentists and specified nurses, midwives and pharmacists who have completed an accredited training course, which means they are legally authorised to prescribe medications to patients. Only nurses, midwives and pharmacists who have completed an accredited training course, which means they are legally authorised to prescribe medications to patients. The precise scope of those restrictions remains subject to consultation.
The proposals would also prevent under-18s from undergoing high-risk cosmetic and wellbeing treatments. Cosmetic botulinum toxin injections and dermal filler for under-18s are already restricted under separate legislation.
In addition, the DHSC states that providers who breach the proposed rules could face criminal proceedings and unlimited fines, or fixed penalties of up to £4,000. These measures are not yet law.
Debating what constitutes a high-risk procedure
Reacting to the proposed restrictions, the Aesthetics Clinical Advisory Board (CAB) says restricting the highest-risk procedures to regulated healthcare professionals is the right approach. They commented, “For years, patients have had no reliable way of knowing whether the person holding the syringe or the laser has undergone appropriate training, understands the fundamentals of the procedure or would recognise a complication, let alone manage one.”
In addition, the CAB welcomes the proposed ban on treatments for under-18s, stating, “Young people are too often offered procedures they do not need and cannot properly consent to, and this measure would offer them meaningful protection.”
Questions remain, however, about which procedures should fall within the highest-risk category. The CAB questions whether body filler should be classed as surgical. “This is something the consultation will need to consider carefully. It is a high-risk treatment and should rest with practitioners equipped to deal with complications, but defining it as surgery may not be the most appropriate solution,” they explain.
Dr Sophie Shotter, aesthetic practitioner and president of British College of Aesthetic Medicine, raises a related concern about the exclusion of facial fillers from the proposed high-risk restrictions. She elaborates, “Dermal fillers carry significant risks, including rare but catastrophic outcomes such as blindness and stroke, particularly when involving high-risk areas like the nose. There is an inconsistent approach to risk assessment.” For Dr Shotter, this reflects a wider failure to recognise that aesthetic interventions require medical oversight, regardless of how “properly” a practitioner claims to perform them.
Gareth Lewis, chief executive officer of the British Association of Medical Aesthetic Nurses (BAMAN), says BAMAN are pleased to see patient safety and professional accountability at the centre of these proposals. However, he notes it is essential that the regulatory framework goes beyond professional registration alone. Lewis adds, “Practitioners must be able to demonstrate appropriate education, training and clinical competence in the specific procedures they undertake, supported by clear standards for managing complications and providing safe patient care.” He also highlights that access to emergency medicines, appropriate clinical oversight and how the proposed requirements will operate for nurse-led aesthetic practices needs to be addressed.
What a licensing scheme needs to achieve
The consultation follows the Government’s announcement in August 2025 that it would prioritise restrictions on the highest-risk procedures and develop a separate local authority licensing scheme for lower-risk treatments, including botulinum toxin injections and facial fillers. Those plans followed a 2023 consultation on non-surgical cosmetic procedures, which received nearly 12,000 responses.
Separate to the consultation, the Government stated that it remains committed to implementing a licensing scheme to ensure that clinics delivering botulinum toxin products, dermal fillers and other lower-risk treatments meet strict safety standards.
Paul Burgess, chair of the Association of Dental Aesthetic Practitioners, notes that the enforcement of regulation in the Amber category, which includes injectables and dermal fillers, will fall to local authority Environmental Health Officers (EHOs). “There will be a major debate around training and resources for EHO as local authorities face many financial pressures on budgets,” he believes.
Lewis says the separate scheme should address the full patient journey, rather than become a paperwork exercise. “We believe this needs to establish meaningful and enforceable standards for training, premises, infection prevention, patient assessment and the management of complications, rather than simply introducing another administrative requirement,” he adds.
Lloyd Bracey, chair at the Joint Council for Cosmetic Practitioners, commented, “We urge the Department to maintain momentum by moving promptly to implement the next phase of regulation for Amber and Green categories, ensuring public protection across all levels of aesthetic practice.”
Dr Shotter calls for the separate scheme to be introduced promptly, with safeguards that patients can verify. “The scheme should license both the practitioner and the premises and set one national training standard.” She also calls for a public register and mandatory reporting of complications. “Without enforcement, a licence is just an impressive looking certificate on the wall,” she concludes.
Deadline and next steps
The consultation invites clinicians, regulators, businesses, members of the public and other specialists to give their views on the draft regulations, with the survey remaining open until 11:59pm on January 13. The proposals are then expected to proceed to the parliamentary process in spring 2027, although the measures remain subject to consultation and are not yet law. The CAB concludes, “With thoughtful design, adequate investment and continued dialogue, this consultation could mark a real step forward, and it is an opportunity we should all embrace.”
References
- Department of Health and Social Care (DHSC) (2026) ‘Cosmetic cowboys crackdown continues with new restrictions’, GOV.UK, 21 October. Available at: https://www.gov.uk/government/news/cosmetic-cowboys-crackdown-continues-with-new-restrictions
- Botulinum Toxin and Cosmetic Fillers (Children) Act 2021, c. 19
- Department of Health and Social Care, ‘Crackdown on Unsafe Cosmetic Procedures to Protect the Public’, GOV.UK, 6 August 2025
- Department of Health and Social Care, ‘Consultation Launched into Unregulated Cosmetic Procedures’, GOV.UK, 2 September 2023
- Joint Council for Cosmetic Practitioners, DHSC Licensing of Non-Surgical Cosmetic Procedures Consultation Response (2023)