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Scotland has become the first country in the UK to pass legislation regulating the non-surgical aesthetics sector. On 17 March 2026, the Scottish Parliament approved the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill, marking a major milestone in the move towards statutory oversight of treatments such as botulinum toxin and dermal fillers.
The Bill, which now awaits Royal Assent, introduces a framework designed to improve patient safety and bring greater consistency to the sector. It requires higher-risk procedures to be carried out by, or alongside, certain healthcare professionals in a registered setting, and confirms that under-18s will be prohibited from accessing these treatments.
Enforcement will sit with Healthcare Improvement Scotland, which will have the power to inspect premises where there are reasonable grounds to suspect non-compliance.
Importantly, the Scottish Government has confirmed a transition period until at least September 2027, giving businesses time to adapt to the new regulatory requirements. This reflects ongoing engagement with the sector and recognises the operational changes clinics may need to make around supervision, premises and governance.
Public Health Minister Jenni Minto described the legislation as a “proportionate” step to address the risks associated with poorly performed procedures, while ensuring responsible providers are supported through the transition.
She said: "Non-surgical cosmetic procedures are increasingly popular, and when not carried out safely they can cause serious and lasting harm. “This legislation is designed to ensure that higher-risk procedures take place in appropriate settings with a healthcare professional present, and that under-18s are properly protected. These are meaningful, proportionate changes that put public safety first.
“I also recognise the importance of ensuring businesses are supported to adapt to new requirements and we have listened closely to the sector. The offences in the Bill cannot come into force before September 2027 giving an extended period of time for businesses to respond to these changes. The Bill is designed to be responsive to changes in the industry, and the procedures will be kept under review to ensure the list remains effective and proportionate. "I am incredibly grateful to everyone who campaigned so passionately on this issue – their determination has helped shape stronger legislation. I am also grateful to colleagues across the Parliament who worked together constructively to pass this Bill.”
For practitioners, the message is clear. Regulation is no longer on the horizon in Scotland – it is now moving towards implementation. Clinics should begin reviewing their qualifications, supervision models, premises compliance and insurance arrangements to make sure they are prepared for the changes ahead.
Hamilton Fraser will continue to monitor developments and provide guidance to support practitioners through this transition.
For the latest regulatory updates, visit the Hamilton Fraser content hub:
https://www.hamiltonfraser.co.uk/content-hub