Aesthetics considers the impact of the GDC removing non-surgical cosmetic injectables from its Scope of Practice Guidance
At the Aesthetics Conference & Exhibition (ACE) 2026 Dentists’ Round Table, attendees raised concerns about the General Dental Council (GDC) removing non-surgical cosmetic injectables from its updated Scope of Practice Guidance. In the previous guidance, published in 2013, “providing implants and non-surgical cosmetic injectables” was listed under “additional skills dentists could develop.”¹ However, in the updated document, which was published in November 2025, the reference to non-surgical cosmetic injectables was removed.² Responding to the concerns raised a GDC spokesperson commented, “We removed non-surgical injectables as it was an anomaly. The Scope of Practice Guidance relates to the role of dental professionals in dentistry, and non-surgical injectables are not the practice of dentistry. The GDC does not regulate these procedures.”
The GDC clarified that, for registrants, the new guidance does not change which non dental tasks they can undertake, and that many such procedures fall under the remit of other regulators. It went on to explain that some tasks, such as botulinum toxin and dermal fillers, are outside the scope of dental regulation, noting, “These may, however, be subject to regulation by other bodies, or specific legislation may apply.”
Aesthetic practitioner Dr Raquel Amado observes that classifying botulinum toxin and dermal fillers as ‘outside the scope of dental regulation’ raises legitimate questions about regulatory clarity. She explains, “It is important to acknowledge that at this point, dentists practising aesthetics do not yet have a fully dedicated professional organisation specifically advocating for their recognition and support within the aesthetics specialty. While broader bodies like the British College of Aesthetic Medicine (BCAM) and the Joint Council for Cosmetic Practitioners (JCCP) provide valuable frameworks, there remains a gap when it comes to a unified voice.”
Aesthetic practitioner Dr Lee Walker believes that removing non-surgical cosmetic injectables from the GDC’s Scope of Practice Guidance effectively formalises a grey area. “The GDC are essentially saying ‘this isn’t dentistry’ while still expecting us to uphold professional standards. That creates a disconnect – responsibility without clear ownership,” he says.
Indemnity cover
Aesthetics spoke with two insurance companies, Cosmetic Insure and Hamilton Fraser to better understand the implications.
What insurers care about
Lizzie Etcell, business development manager at Cosmetic Insure, explains that insurers do not base cover on whether a procedure appears in a scope of practice document, but whether the practitioner can demonstrate appropriate training, competence and governance. She notes, “Dentists remain well placed to deliver non-surgical injectables – provided their training, documentation and insurance arrangements accurately reflect their practice.” Nicola Bowtell, cosmetic account executive at Hamilton Fraser, points out that indemnity is based on the activities declared to the insurance provider, with aesthetic procedures treated as non-core dental work.
What has changed in underwriting
Etcell reassures that Cosmetic Insure has not had to update its policy wording due to this development, however the GDC’s updated guidance has sharpened the company’s underwriting focus. “We are now more likely to seek clarity around the specific aesthetic treatments performed, the level and recency of training and the clinical setting in which treatment is delivered,” Etcell explains.
What dentists should do now
Bowtell adds that from an insurer’s standpoint, practitioners should ensure their insurance policies accurately reflect all treatments carried out. Moreover, she explains practitioners should have clear, documented protocols in place for dealing with adverse events. “Take time to understand and manage patient expectations, particularly where they may be unrealistic, and always adhere to manufacturer guidelines for the products and treatments you use,” she notes.
In terms of consent processes, Etcell advises that protocols should be treatment-specific and outcomes-focused, with detailed clinical notes documenting the rationale, products used, technique and post-treatment advice.
Future landscape
Following the Department of Health and Social Care (DHSC) announcement of plans to introduce a national licensing scheme, a consultation is underway focusing on finalising the scope of procedures to be regulated.
Andrew Rankin, acting co-chair of the JCCP, expects that this framework will set out defined levels of competence and associated regulations. In his view, this should help GDC registrants to demonstrate their scope of practice within the cosmetic sector and clarify which registrants can perform or supervise procedures in each category.
Rankin also notes that the memorandum of understanding (MoU) – the existing cooperation agreement between the GDC and JCCP – remains in place and unchanged following the update to the Scope of Practice Guidance.⁴ This allows the JCCP to continue working with the GDC to examine the implications of proposed regulations for GDC registrants and to provide guidance accordingly.
Final thoughts
For Dr Walker, the bottom line is that the removal of non-surgical injectables from the GDC Scope of Practice Guidance does not make dentists less legitimate. He adds however, “It does mean you have to be sharper, clearer and more defensible in how you practice.”
Dr Amado concludes, “Ultimately, I believe there is a strong case for medical aesthetics to be recognised as a legitimate extension or even a future specialty within dentistry. The profession already possesses many of the core competencies required. What is needed now is recognition, representation and continued collaboration with regulators.”
GDC Removes Non-Surgical Cosmetic Injectables from Scope of Practice
Aesthetics considers the impact of the GDC removing non-surgical cosmetic injectables from its Scope of Practice Guidance.
At the Clinical Cosmetic Regenerative Congress (CCR) 2026, a new dentistry association founded by Paul Burgess – the Association of Dentists in Aesthetic Practice – will host a dedicated agenda on Day 1, providing a new stage for dentists in aesthetics to connect and access tailored education and support.
References
1- General Dental Council, Scope of Practice (2013)
https://www.gdc-uk.org/docs/default-source/information-standards-and-guidance/scope-of-practice/scope-of-practice-guidance-2025-(1).pdf [accessed 1 May 2026]
2- General Dental Council, Scope of Practice (2025)
https://www.gdc-uk.org/docs/default-source/information-standards-and-guidance/scope-of-practice/scope-of-practice-guidance-2025-(1).pdf?sfvrsn=18b7c40e_1 [accessed 1 May 2026]
3- Department of Health and Social Care, The licensing of non-surgical cosmetic procedures in England: consultation document (2023), GOV.UK
https://www.gov.uk/government/consultations/the-licensing-of-non-surgical-cosmetic-procedures-in-england [accessed 1 May 2026]
4- Sprintlaw UK, What Is a Memorandum of Understanding? A Guide for UK Businesses ([n.d.])
https://sprintlaw.co.uk/articles/what-is-a-memorandum-of-understanding/ [accessed 1 May 2026]