The Scottish Parliament’s Health, Social Care and Sport Committee has urged Parliament to agree to the general principles of the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill.
First introduced in October 2025, the Bill seeks to regulate non-surgical procedures, including cosmetic treatments such as dermal fillers, botulinum toxin, certain chemical peels and microneedling. The Committee says patient safety must come first and agrees it should be illegal for under-18s to access these treatments.
The Committee is now recommending that Parliament agree to the bill and shares that it supports the Scottish Government’s proposed two-tier approach to regulation. Under the plans, higher-risk procedures would only be permitted in approved premises under the supervision of authorised medical practitioners, while lower-risk procedures would be subject to a licensing scheme introduced through secondary legislation.
However, the Committee raised concerns about a lack of clarity around clinical supervision, including minimum qualification requirements for supervisors and the extent of their clinical and managerial responsibilities.
On enforcement, the Committee has called for a staged approach to implementation, allowing compliant providers time and support to meet the new requirements, while taking stronger action against operators who fail to engage with the legislation. It said the sanctions currently set out in the Bill would be insufficient to deter repeat offenders and urged the Scottish Government to introduce tougher penalties.
The Committee also questioned whether Healthcare Improvement Scotland has sufficient capacity and resources to enforce the Bill effectively, calling for assurances that additional funding will be made available from the outset.
Finally, the Committee highlighted significant variation in the quality of training and qualifications across the non-surgical sector and called for the introduction of clear, consistent standards for all practitioners.
The Health, Social Care and Sport Committee Convener and member of the Scottish Parliament, Clare Haughey, commented, “Our Committee believes patient safety must always come first, and that’s why we are supportive of this Bill, which will provide much-needed regulation of the non-surgical procedures specialty. We fully back provisions making it illegal for under-18s to access these procedures and believe the Scottish Government should work with the UK Government to improve and standardise training and qualifications so all providers meet a minimum standard.”