Aesthetics examines the upcoming CQC autumn consultation, reflecting on past regulatory failings and a sector-specific inspection model
England’s independent regulator for health and social care service, the Care Quality Commission (CQC) is launching a formal public consultation this autumn as part of its efforts to rebuild its regulatory framework following last year’s widely reported organisational failings.1,2 The healthcare regulator has shared that the consultation will invite providers, stakeholders and the wider public to give their views on the proposals that have been developed. This is to ensure the new regulatory system is evidence-informed, inclusive and geared towards continuous improvement.3
The consultation follows two major reviews of the CQC in 2024 by chair of the NHS Dr Penny Dash as well as oncologist and chair of the CQC, Professor Sir Mike Richards. Dr Dash’s review uncovered “significant failings” within the regulators internal workings, with issues ranging from unclear rating methodologies to a loss of sector expertise.4 In October 2024 Dr Dash made seven recommendations for the CQC, which included rebuilding expertise, clarifying rating calculations, increasing transparency and rapidly addressing operational performance.4
Under current guidelines, the CQC regulates providers of non-surgical and surgical cosmetic treatments carried out by a registered healthcare professional (HCP) that involve surgical procedures or non-surgical medical approaches. Some of these include cosmetic surgery, liposuction, thread lifting, treatment with prescription medication for a medical condition such as hyperhidrosis, bruxism, acne and rosacea or weight loss support.⁵⁻⁶
Current challenges
Aesthetic practitioner Dr Olivia McCabe-Robinson who has a clinic in Glossop, Derbyshire, faced challenges during her CQC application process, including the loss of her online application following a system change. This resulted in Dr McCabe-Robinson having to resubmit in paper format which she says caused the process to take over a year to complete, due to what she agrees are “failures in the system.”
Nurse practitioner and regulation consultant at Inspire to Outstand, Tracey Jones, believes there is a need for a clear and consistent set of requirements, adding, “The duration of registration interviews significantly vary depending on the inspector, and the timeline for these interviews can span anywhere from four to six months.” She reflects on past instances where inspectors have requested clinics to stock emergency medications that are not aligned with the specific patient demographic or clinical risk profile of the service. Jones believes this suggests a limited understanding that not all services operate in the same way or serve the same population.
Sector-specific approaches
A series of regional roadshows organised by the CQC earlier this year aimed to help the regulator listen and co-design the future of regulation with the people who live it every day.1 A key theme raised was the idea of sector-specific inspection approaches that reflect how different services operate.1
Dr McCabe-Robinson believes a sector-specific model for CQC inspections would be hugely beneficial for medical aesthetics, explaining it would help move the conversation away from a one-size-fits-all approach and towards a model that genuinely supports high standards. She argues the broad and generic framework that was originally designed with GP surgeries or hospitals in mind doesn’t always reflect how aesthetic clinics actually operate.
Dr McCabe-Robinson notes, “Issues like product procurement and storage, traceability, managing complications and ensuring patients truly understand consent are at the heart of safe practice. These are often overshadowed when the inspection criteria are geared towards bigger healthcare settings with very different systems and pathways.”
Jones believes that a sector-sensitive approach will help ensure inspectors have specialist knowledge. She says, “This ensures a more informed, fair and relevant assessment of the specific service being reviewed.”
CQC’s involvement with aesthetic regulation
The urgent need for the regulation of non-surgical cosmetic treatments was discussed during a Westminster Hall debate on September 11.7 Minister of State at the Department of Health and Social Care (DHSC), Karin Smyth, explained that the CQC will have a clear role in the Government’s plans to prioritise developing legal restrictions on high-risk cosmetic procedures such as the non-surgical Brazilian butt lift. This was previously announced in August 2025, when the DHSC confirmed plans to introduce a licensing scheme for non-surgical cosmetic procedures in England.8
Smyth says, “Bringing the restricted high-risk procedures into the CQC’s scope of registration will mean procedures being performed only by suitably qualified, regulated HCPs working for providers who are registered with the CQC. We will come down like a ton of bricks on providers who flout the rules, with tough enforcement from the CQC.”
Jones explains that implementing a more robust CQC framework alongside the proposed licensing scheme will help prevent unregulated practice. She adds, “Ensuring that HCPs understand the necessity of CQC registration will reduce the risk of individuals working outside their professional scope, thereby, protecting both patient safety and their own professional registration.” Jones also believes that the proposed licensing scheme may lead to more treatments being brought under the CQC’s scope of registration, which would strengthen public safety while also requiring a greater number of HCPs to consider CQC registration.
A phased approach to reform
Director of engagement at the CQC Chris Day shared that following the autumn consultation, the new assessment approach will begin to roll out.3 Day says, “We will continue working together, learning from what’s working, adjusting what isn’t and keeping pace with a changing care sector.” Dr McCabe-Robinson encourages all aesthetic practitioners to submit their responses to the consultation when it opens, noting, “This is everybody’s problem who works in the aesthetic sector, so make sure you have your say otherwise nothing will get better for our patients.”
References
- Care Quality Commission, Rebuilding Regulation: What We’ve Heard — and Where We Go Next, Medium, 18 August 2025 https://carequalitycomm.medium.com/rebuilding-regulation-what-weve-heard-and-where-we-go-next-5336683e342a
- Care Quality Commission, CQC Responds to Reviews by Dr Penny Dash and Professor Sir Mike Richards, Care Quality Commission, 15 October 2024 https://www.cqc.org.uk/press-release/cqc-responds-reviews-dr-penny-dash-and-professor-sir-mike-richards
- Care Quality Commission, Rebuilding regulation: Co‑designing a stronger, fairer CQC together, Medium, 9 June 2025 https://medium.com/@carequalitycomm/rebuilding-regulation-co-designing-a-stronger-fairer-cqc-together-50251c7b96f8
- Department of Health and Social Care, Review into the operational effectiveness of the Care Quality Commission: Full Report (GOV.UK, 15 October 2024) https://www.gov.uk/government/publications/review-into-the-operational-effectiveness-of-the-care-quality-commission-full-report/review-into-the-operational-effectiveness-of-the-care-quality-commission-full-report
- Care Quality Commission, ‘Help choosing care: Choosing cosmetic surgery’, CQC, https://www.cqc.org.uk/care-services/help-choosing-care/choosing-cosmetic-surgery
- Care Quality Commission. Scope of registration. Guidance: registration, Scope of registration. Last updated 29 January 2025. Available at: https://www.cqc.org.uk/guidance-regulation/providers/registration/scope-registration
- Bradley Thomas MP, Non-surgical Aesthetic and Cosmetic Treatments, Westminster Hall Debate, 11 September 2025, Hansard, https://hansard.parliament.uk/Commons/2025-09-11/debates/ed9f417f-f795-467f-8f83-830c25ae8f44/WestminsterHall
- Department of Health and Social Care, Licensing of Non-Surgical Cosmetic Procedures in England (London: GOV.UK, 2025) Licensing of non-surgical cosmetic procedures – GOV.UK