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It’s hard to put the finger on exactly when the aesthetics industry first came into being, but having been insuring the sector for more than 25 years, Hamilton Fraser has been there since the early days.
We have watched the non-surgical side of the industry evolve rapidly since the late 90s and early 00s, with treatments like botulinum toxin injections, dermal fillers, and other minimally invasive techniques becoming increasingly popular.
But one thing that has plagued the sector is the lack of regulation.
Despite the booming demand and rapid expansion of the industry, the regulatory framework has struggled to keep pace, leading to significant concerns about patient safety, the quality of practitioner training, and the ethical marketing of aesthetic services.
The Joint Council for Cosmetic Procedures (JCCP) has long been a partner of Hamilton Fraser, working closely with government and national bodies seeking greater regulation on non-surgical aesthetic treatments and hair restoration surgery in the UK, with the ultimate aim of creating a safer environment for members of the public undergoing non-surgical treatments.
This article delves into the historical developments, key legislative milestones, and future prospects for the regulation of the aesthetics sector in England, where the first steps are being made towards formal regulation and where we are currently waiting for the outcome of the public consultation on licensing of non-surgical cosmetic procedures in England.
The rise of non-surgical aesthetics began in the 1990s with the advent of dermal fillers and botulinum toxin treatments, with Allergan’s Botox being licenced for cosmetic use in the US in 2002 and the UK in 2006. Initially, these procedures were predominantly performed by trained medical professionals, such as plastic surgeons and dermatologists. However, as the popularity of the treatments grew, so did the number of practitioners from non-medical backgrounds entering the field, often with minimal training. This proliferation of unregulated practice led to mounting concerns over patient safety, prompting discussions on the need for regulation.
The first significant step towards addressing these concerns was the Keogh Review, published in April 2013. Commissioned by the Department of Health and spearheaded by Sir Bruce Keogh, the report provided a scathing critique of the state of regulation in the aesthetics industry. It highlighted that individuals seeking non-surgical cosmetic interventions had little more protection than those buying everyday consumer goods, like toothbrushes or ballpoint pens. The report’s findings underscored the urgent need for regulatory reform to protect patients from the risks associated with poorly performed procedures.
In response to the Keogh Report, Health Education England (HEE) was tasked with developing a framework to improve training standards across the non-surgical aesthetics sector. Over the course of 18 months, HEE worked closely with a wide range of stakeholders, including professional regulators, universities, and industry representatives, to develop a set of educational standards aimed at enhancing practitioner competence and patient safety.
The culmination of this effort was the publication of two key reports in November 2015. These reports outlined a structured qualification framework for practitioners, categorising treatments based on their level of risk. For example, high-risk procedures like injectable toxins and dermal fillers were designated as Level 7 treatments, requiring advanced training and the oversight of a qualified prescriber. This framework represented a significant step forward in ensuring that practitioners possessed the necessary skills and knowledge to safely perform these procedures.
However, the implementation of these standards faced several challenges. The qualifications were introduced on a voluntary basis, leading to inconsistent uptake across the industry. Many training providers found loopholes, offering substandard courses that failed to meet the rigorous standards envisioned by HEE. As a result, a large number of practitioners continued to operate with inadequate training, perpetuating the risks highlighted in the Keogh Report.
The role of the Joint Council for Cosmetic Practitioners (JCCP)
Recognising the need for a more robust regulatory body, the Joint Council for Cosmetic Practitioners (JCCP) was established in 2017 and formally launched in 2018. The JCCP took ownership of the HEE standards and sought to enforce these through its voluntary register, which was designed to recognise practitioners who met the highest standards of training and practice. The JCCP also played a crucial role in lobbying for more stringent regulation and public protection within the industry.
The JCCP’s efforts were bolstered by the Cosmetic Practice Standards Authority (CPSA), which developed the competency frameworks that underpin the JCCP’s standards. Together, these organisations worked to raise the bar for training and practice within the non-surgical aesthetics sector. Despite these efforts, the voluntary nature of the register meant that many practitioners, particularly those from non-medical backgrounds, remained outside its purview. The same was true of other voluntary registers established following the Keogh review, including Save Face and Treatments You Can Trust.
The JCCP and CPSA Code of Practice and Guidance for Practitioners Who Provide Cosmetic Interventions was developed following a wide-ranging consultation process for those involved in providing cosmetic treatments. This updated and revised version of the guidelines was approved by the CPSA and JCCP in 2020. A third edition was published in March 2023.
In 2021, the JCCP laid out its 10-point plan, setting out the campaigns the JCCP is carrying out and the goals they are seeking to achieve in their aim to create a safer aesthetic industry with mandated qualifications, premises criteria, insurance and other steps relating to the sector, which are:
In July 2021, the All-Party Parliamentary Group (APPG) released its findings and recommendations after conducting a year-long inquiry. The group, established to advocate for the rights of the UK beauty and medical aesthetics industries in Parliament, emphasised the importance of setting minimum educational standards for aesthetics practitioners to enhance patient safety.
Legislative milestones
The first significant piece of legislation directly affecting the aesthetics industry was the ban on cosmetic injectables for individuals under 18, which came into effect in October 2021. This law marked a turning point in the regulatory landscape, reflecting growing concerns about the ethical implications of administering such treatments to minors. The legislation was the result of concerted efforts by various stakeholders, including industry professionals, advocacy groups, and public campaigns.
Building on this momentum, the Health and Care Act 2022 introduced a comprehensive framework for the future regulation of the non-surgical aesthetics sector. The Act laid the groundwork for a mandatory licensing scheme, which would cover both practitioners and their premises. This licensing scheme, once fully implemented, would represent a major step forward in ensuring that all individuals performing aesthetic procedures meet a consistent standard of training and competence.
2022 also saw the Health and Social Care Select Committee release its report focusing on the impact of body image on mental and physical health. The report includes the Committee's recommendations for regulating non-surgical aesthetic procedures in the UK.
In January 2023, the government confirmed its commitment to this licensing scheme, with plans to implement it by the end of 2026. The scheme is expected to include minimum education standards for practitioners, mandatory hygiene and safety protocols for premises, and ongoing oversight to ensure compliance. This regulatory framework is seen as a critical step towards safeguarding the public from unqualified practitioners and substandard practices.
After years of lobbying from professional bodies, practitioners, and insurers like Hamilton Fraser, the UK Government has now issued its formal response to the 2023 public consultation on licensing non-surgical cosmetic procedures in England.
Among the proposed measures are:
Minister of State for Health Karin Smyth MP said: “The cosmetics industry has been plagued by a Wild West of dodgy practitioners and procedures. There are countless horror stories of cosmetic cowboys causing serious, catastrophic damage.
“This government is taking action to protect those seeking treatments, support honest and competent practitioners, and root out the cowboys as part of our Plan for Change. This isn’t about stopping anyone from getting treatments – it’s about preventing rogue operators from exploiting people at the expense of their safety and keeping people safe. We’re giving them peace of mind and reducing the cost to the NHS of fixing botched procedures.”
Professor David Sines CBE PhD, Executive Chair and Registrar JCCP, said, “The Joint Council for Cosmetic Practitioners warmly welcomes the UK Government’s decision to introduce legislation to regulate and license cosmetic procedures according to the risks they present. Their ‘Plan for Change’ signals a commitment in the strongest terms, and it accords with the JCCP’s widely publicised call for statutory regulation.
“The introduction of standards to ensure that patients are safeguarded and protected from harm, ensuring that all cosmetic practitioners are regulated and licenced to a new national education and training standard, that they are appropriately insured and that they work from safe premises at all times has become imperative. These proposals have our full support and we welcome the opportunity to engage in further consultation.”
Eddie Hooker, Founder and CEO of Hamilton Fraser, who is also a trustee of the JCCP, commented, “Hamilton Fraser supports and welcomes the Government’s announcement. For too long, the aesthetics sector has had to contend with a small but damaging minority of untrained practitioners whose shortcuts put patients, reputable clinicians and the NHS at risk. Mandating that only suitably qualified healthcare professionals can perform higher-risk procedures, and the requirement of robust licensing, training and insurance for all treatments, will draw a clear line between safe, accountable practice and the ‘Wild West’ operators the Minister has rightly condemned.
“At Hamilton Fraser, we have championed higher standards and comprehensive insurance cover for nearly three decades. We stand ready to work with government, regulators, patient-safety groups, and our insured practitioners to implement these measures smoothly, making sure patients receive safe, ethical treatment and our industry continues to innovate and grow on a foundation of trust.”
In June 2025, the Scottish Government confirmed that a new licensing system will be introduced by May 2026, following its own national consultation. This was followed by the publication of the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill on 8 October 2025, marking a significant regulatory milestone north of the border.
The Bill introduces key safeguards:
The Scottish Government has also published impact assessments covering business regulation, equality, child wellbeing, and island communities.
While the Scottish and English models may differ, both share the same goal: a safer, more transparent, and professionally accountable aesthetics sector.
Read our blog on what’s happening in Scotland here.
As discussed in Hamilton Fraser’s Aesthetic Business Podcast, CEO Eddie Hooker and JCCP Practitioner Register Committee Chair Andrew Rankin emphasise that safeguarding begins with accountability, and that insurers will play a key role in verifying training, ethical practice, and continuing professional development as part of future licensing frameworks.
Rankin explains: “Insurance will be a central part of the licensing process. Regulators will need trusted partners to verify that practitioners are trained, insured, and operating safely. That’s where companies like Hamilton Fraser can support both professionals and the public.”
You can listen to the full discussion on Regulation in Aesthetics: Where Are We Now? With Andrew Rankin here and our podcast on The future of regulation and licensing in the aesthetics industry with Professor David Sines here.
After more than a decade of campaigning, formal regulation for non-surgical cosmetic procedures in the UK is finally becoming a reality. The Government’s response, supported by the JCCP, regulators, and insurers like Hamilton Fraser, signals a clear direction of travel: patient safety first.
While there will be practical and logistical challenges ahead, this new licensing framework lays the foundation for a more professional, consistent, and trusted sector.
To stay up to date on the latest regulatory changes and licensing developments, visit the Hamilton Fraser content hub and check out our regulation section.
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