The Scottish Government has published its response to the recent consultation on the regulation and licensing of non-surgical cosmetic procedures.
It has confirmed revised proposals ahead of legislation expected later this year. The consultation, launched in December 2024, sought views on how best to regulate non-surgical procedures, including those involving botulinum toxin and dermal fillers, particularly when delivered by non-healthcare professionals or outside NHS contracts.
A total of 2,207 responses were received. Of these, 94% came from individuals, with the remaining 6% submitted by organisations. Most respondents (55%) reported no formal connection to the aesthetics sector. Of the remainder, 24% identified as working within the regulated part of the specialty, such as healthcare professionals or those practising in settings regulated by Healthcare Improvement Scotland (HIS), and 17% as working in the unregulated sector, such as beauty salons or freelance aesthetic practices. According to the published report, the responses have informed a series of refinements to the Government’s original proposals.
Respondents broadly supported improving safety and regulation in the non-surgical cosmetic sector, though views differed on how to achieve this. Most agreed certain procedures should be performed in licensed settings and that some require healthcare professionals. There was less consensus on procedures restricted to HIS premises but still done by non-healthcare practitioners, with opinions often reflecting respondents’ backgrounds.
While safety is a shared priority, some feared the proposals may impose unnecessary restrictions impacting businesses. Support was strong for a dual licensing system, enforcement powers for local authorities and HIS, and setting a minimum age of 18 for these procedures.
Key developments following the consultation include plans to introduce a licensing regime for higher-risk procedures delivered by non-healthcare practitioners. Treatments involving prescription-only medicines, or those requiring clinical oversight, are expected to fall under the remit of HIS. The Government is also exploring future qualification requirements and training routes for those working in the field, and a series of impact assessments is underway to consider how the proposals may affect small businesses and protected groups.
The Minister for Public Health and Women’s Health, Jenni Minto MSP, said, “We need to act in the interests of all those who seek to undergo these procedures and respond to the evidence we have seen that some people have had negative and life changing experiences. In doing so I intend to bring forward robust proposals that allow the specialty to provide procedures as safely as possible. I am satisfied that we will achieve this, and I look forward to working with Parliament to put these proposals into legislation.”
The proposals will inform the forthcoming Non-Surgical Cosmetic Procedures Bill, which is expected to be introduced to the Scottish Parliament during the 2025–26 legislative session. According to the Government, the bill will establish a clearer regulatory framework for aesthetic treatments, bringing previously unregulated practice into scope and strengthening patient safety across the sector.
The full consultation report and supporting documentation are now available via the Scottish Government website. Further impact assessments are expected to be published in due course.
