Government Update: Licensing of Non‑Surgical Cosmetic Procedures in England

What This Means: Practical Implications for Professionals & Clients

Highest‑Risk Procedures (Red Tier)

• Dermal fillers to the breasts, buttocks or genitals and similar invasive procedures will be:
  • Reserved for regulated healthcare professionals only.
  • Subject to CQC oversight (not just local council licensing).
  • Required to meet strict standards on emergency management, hygiene, and complication handling. 

Local Authority Licensing (Green & Amber Tiers)

• A new licence system will apply to both:
  • Practitioners (skills, qualifications, insurance).
  • Premises (cleanliness, infection control, suitability).
• If you are a practitioner in these categories, prepare now by:
  • Checking training is evidence-based and current.
  • Ensuring premises are compliant with upcoming hygiene standards.
  • Getting ahead of expected licence fees and application paperwork.

Age Restrictions

• 18+ will be the standard legal minimum.
• Client screening processes must verify age.
• For those treating under-18s (e.g., for skin conditions), additional regulation and medical sign-off will be necessary.

Training & Grandfathering

• Practitioners should review:
  • Whether their qualifications meet anticipated standards.
  • CPD and complications training (especially for injectables).
• Government may allow “grandfathering” for experienced practitioners—but this will not be automatic.

Supervision & Oversight

• Non-healthcare professionals will need formal arrangements with named, regulated healthcare professionals for amber-tier treatments.
• Clear definitions of oversight responsibilities are coming—practices should:
  • Identify potential supervisors now.
  • Document who is accountable for prescriptions and client safety.

Data, Transparency & Communication

• A national register will help clients verify:
  • Practitioner licensing status
  • Approved qualifications and training
• Clinics should get ready to log complaints, adverse outcomes, and training records—these may be inspected or audited in the future.

Enforcement & Inspections

• Local authorities and the CQC will gain:
  • Powers to inspect
  • Levy fines
  • Suspend or revoke licences
• Businesses must be ready for compliance checks, especially regarding:
  • Cleanliness and infection control
  • Accurate record-keeping
  • Client consent protocols

Innovation & New Technologies

• The system will evolve over time to include:
  • New procedures (e.g., skin boosters, radiofrequency devices)
  • Updated product regulations
• Clinics should remain agile—new treatments may be added to licensing requirements with little notice.

CosmediCheck’s Advice for Trusted, Safe Practice

To support our professionals through this transition, CosmediCheck recommends:

• Audit your procedures now: Know which risk tier each falls into.
• Review all qualifications: Make sure you can evidence appropriate training and insurance.
• Understand your premises obligations: Whether fixed, mobile or home-based.
• Budget and plan for licensing: Applications, fees, staff documentation.
• Establish supervisory relationships: If applicable under amber-tier, confirm oversight agreements in writing.
• Update your client documentation: Informed consent, age verification, risks, aftercare.
• Communicate proactively: Let clients know you are licensed, compliant and working under safe, professional standards.

Looking Forward: What to Expect & When

• Early 2026: Further government consultations on the red-tier procedures (highest risk).
• 2026–2027: Regulatory rollout begins, including licensing applications and inspections.
• Transitional period: Local authorities and CQC will begin capacity building and practitioner education.
• Ongoing reviews: Treatment risk categories and training standards will be monitored and updated regularly.

CosmediCheck’s Final Thoughts

The introduction of a national licensing system is one of the most significant developments the aesthetics and personal services sector has faced. While the intention to improve safety and accountability is welcome, the potential impact on non-healthcare professionals must not be overlooked.

For those practitioners, many of whom are highly trained, experienced and running female-led businesses these reforms bring uncertainty. Mandatory supervision, evolving qualification requirements, and insurance restrictions may fundamentally alter how and whether some can continue to practise.

While the red-tier restrictions were expected, the amber-tier conditions (particularly supervision models and insurance barriers already emerging via underwriters) could reduce autonomy and disrupt otherwise safe, compliant businesses. There is a real concern that these measures, if poorly implemented or overly restrictive, may penalise skilled professionals simply for not holding a medical title, despite meeting or exceeding industry standards.

The sector has consistently demonstrated its professionalism: according to the government’s own data, only 6% of the 9,032 responses consultation respondents reported dissatisfaction with treatment outcomes, which is exceptionally low for a rapidly growing industry. And let’s not forget the £31.5 billion contribution the UK beauty and personal care sector made to the economy in 2025 alone.

At CosmediCheck, we support the creation of a clear, safe and enforceable licensing structure, but only if it recognises and protects all competent practitioners, not just those with a clinical registration. Safety must be based on training, oversight and client outcomes – not job title alone.

We will continue to monitor developments closely and advocate for a balanced, fair and inclusive regulatory approach, one that enhances public trust without marginalising the very professionals who helped shape and sustain this vital sector.