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It’s hard to put a finger on exactly when the aesthetics industry first came into being, but having been insuring the sector for more than 30 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 1990s and early 2000s, with treatments such as botulinum toxin injections, dermal fillers, and other minimally invasive techniques becoming increasingly popular - you can read our article on changing practitioner risks over the last three decades for more on this. But one issue has consistently challenged the sector: regulation.
Despite booming demand and rapid expansion, the regulatory framework has historically struggled to keep pace. This has led to significant concerns about patient safety, practitioner training standards, ethical marketing, and professional accountability.
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.
Today, however, UK aesthetics licensing is no longer a distant ambition. Following years of consultation and campaigning, both England and Scotland are moving towards formal licensing frameworks for non-surgical cosmetic procedures, with the Scottish Parliament’s Health, Social Care and Sport Committee recommending agreement to the general principles of The Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill passed in March 2026 and the Government in England outlining new measures to crack down on cosmetic procedures in August 2025, following the 2023 consultation.
There’s a feeling across the sector that we have shifted from campaigning for regulation towards preparing for it. Regulation affects patient safety, training standards, and insurance requirements, so understanding the landscape and how it could impact your clinic is more crucial than ever.
This updated guide provides a comprehensive overview of:
For a detailed jurisdiction comparison, see our England vs Scotland road map article.
The rise of non-surgical aesthetics began in the 1990s with the advent of dermal fillers and botulinum toxin treatments. Initially, these procedures were predominantly performed by trained medical professionals, such as plastic surgeons and dermatologists.
However, as popularity grew, so did the number of practitioners entering the field, including those from non-medical backgrounds, often with minimal training. This proliferation of unregulated practice led to mounting concerns over patient safety and prompted serious discussion about reform.
The first significant step towards addressing these concerns was the Keogh Review, published in April 2013. Commissioned by the Department of Health and led by Sir Bruce Keogh, the report delivered a stark assessment of the sector.
It concluded that individuals seeking non-surgical cosmetic interventions had little more protection than consumers purchasing everyday goods. The report underscored the urgent need for regulatory reform to safeguard patients from poorly performed procedures.
This marked the beginning of modern non-surgical aesthetics regulation discussions.
In response to the Keogh Review, Health Education England (HEE) developed a qualification framework to improve training standards.
In 2015, HEE published structured competency frameworks categorising treatments by risk level. High-risk procedures, including injectable toxins and dermal fillers, were designated as Level 7 treatments requiring advanced training and prescriber oversight.
However, implementation was voluntary. Uptake was inconsistent, and substandard training continued in parts of the market. While this framework raised awareness, it did not fully solve the regulatory gap.
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. It took ownership of the HEE standards and introduced a voluntary register recognising practitioners who met defined training and practice criteria.
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.
Alongside the CPSA, the JCCP developed competency frameworks and a Code of Practice. A third edition of the Code was published in March 2023.
In 2021, the JCCP introduced its 10-point plan, calling for:
This plan has effectively become a blueprint for future aesthetics licence requirements.
Despite these advances, voluntary registration meant many practitioners remained outside formal oversight.
The first significant statutory intervention was the ban on cosmetic injectables for individuals under 18 in England, introduced in October 2021. This marked a turning point in aesthetics regulation in the UK, placing patient protection firmly at the centre of policy.
Building on this momentum, the Health and Care Act 2022 laid the legal foundation for a future licensing scheme covering both practitioners and premises in England.
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 implementing a mandatory licensing system by the end of 2026.
The UK Government issued its formal response to the 2023 public consultation on licensing non-surgical cosmetic procedures in England in August 2025.
Among the proposed measures are:
The Women and Equalities Committee published its Health impacts of breast implants and other cosmetic procedures report (HC 869) on February 18, 2026, calling for urgent reform of the non-surgical cosmetic procedures sector, an immediate ban on liquid BBLs and stronger action on cosmetic tourism and body image pressures.
While the report also examines breast implant safety, its warnings also focus on the rapid growth and lack of effective regulation across the non-surgical aesthetics market.
The inquiry examined:
The Committee concluded that regulation has “not kept pace” with demand, creating an environment where inadequately trained individuals can carry out high-risk procedures, often with serious consequences.
If the Government adopts the recommendations, the sector could see significant legislative change within this Parliament.
As of early 2026, there is no fully implemented national licensing scheme in force in England. However, this position is changing.
The Government’s response to the 2023 consultation on licensing non-surgical cosmetic procedures in England (as detailed above) confirmed a move towards:
This shift represents a major development in aesthetic practitioner licensing England.
Implementation timelines are still being finalised, but the direction of travel is clear: licensing will become mandatory.
In June 2025, the Scottish Government confirmed that a new licensing system will be introduced by May 2026, following its own national consultation. The Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill was published on 8 October 2025 and passed Stage 1 in January 2026. On February 24, 2026, following a debate among MPs in Parliament, the bill moved to Stage 3 of the process to decide if it should become an Act. Stage 3 is the final opportunity for Members of the Scottish Parliament (MSPs) to debate and amend the Bill before voting on whether it should be passed. If approved, the legislation will proceed to Royal Assent and become an Act.
On 17 March 2026, the Scottish Parliament passed the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill. This means Scotland will be the first country in the UK to introduce legislation regulating non-surgical cosmetic procedures. The Bill now awaits Royal Assent, with enforcement powers granted to Healthcare Improvement Scotland and a transition period in place until at least September 2027.
The Bill introduces:
While the licensing system is not yet live, Scotland's aesthetics licensing is progressing towards statutory implementation.
Practitioners asking how to get an aesthetics licence in Scotland should begin preparing by reviewing qualifications, auditing premises, and aligning insurance arrangements ahead of May 2026.
Once the legislation is fully enacted, the new aesthetics practitioner rules in Scotland are expected to introduce:
Practising without the appropriate licence, once required, may lead to enforcement action and could affect the ability to operate legally.
While the Scottish and English models may differ, both share the same goal: a safer, more transparent, and professionally accountable aesthetics sector.
As of 2026:
For a full comparison, see our England vs Scotland licensing road map here.
Even before full implementation, practitioners should prepare for future aesthetics compliance UK requirements.
Practical steps include:
A proactive approach will minimise disruption when licensing becomes mandatory.
As discussed in Hamilton Fraser’s Aesthetic Business Podcast with Andrew Rankin, insurance will play a central role in future licensing frameworks.
As UK aesthetics licensing moves from consultation to implementation, insurance is likely to shift from being best practice to becoming an explicit regulatory requirement.
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.
While final regulations are still being drafted, proposed licensing models in both England and Scotland indicate that practitioners may be required to demonstrate:
In practice, this means insurance may become part of the licence validation process. Regulators could require documented proof of:
For practitioners, this marks a shift from insurance being a commercial safeguard to being a formal element of aesthetics licence requirements.
Insurers are uniquely positioned to support regulatory implementation because they already assess:
As licensing frameworks are introduced, insurers can:
Andrew Rankin, Chair of the JCCP Practitioner Register Committee, has stated:
“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.”
Eddie Hooker, Founder and CEO of Hamilton Fraser and trustee of the JCCP, commented:
“For too long, the aesthetics sector has had to contend with a small but damaging minority of untrained practitioners. Mandating robust licensing, training and insurance will draw a clear line between safe practice and rogue operators.”
As aesthetics regulation changes UK 2026 take shape, practitioners should review:
Early preparation reduces the risk of disruption once licensing becomes mandatory.
For 30 years, Hamilton Fraser has supported the aesthetics sector through evolving regulatory landscapes. As the UK moves towards statutory licensing, we continue to:
If you would like to review your current cover in light of forthcoming UK aesthetics licensing requirements, or discuss how regulatory changes may affect your practice, contact Hamilton Fraser or get a quote online.
Clear regulation supports safer practice. The right insurance supports you.
After more than a decade of lobbying, campaigning and consultation, formal licensing for non-surgical cosmetic procedures in the UK is becoming reality.
The direction of travel is clear: patient safety first.
While practical challenges remain, this new era of non-surgical aesthetics regulation lays the foundation for a more consistent, accountable and trusted sector.
Preparation today supports protection tomorrow.
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.
