The Scottish Government has taken another significant step towards formal regulation of the non-surgical aesthetics sector. On 27 January 2026, the Scottish Parliament Health, Social Care and Sport Committee published its Stage 1 report recommending that Parliament agrees to the general principles of the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill.
This follows the Scottish Government’s proposals outlined in October 2025 and marks a clear signal that mandatory regulation of non-surgical cosmetic procedures in Scotland is moving closer to becoming law.
A clear focus on patient safety
At the heart of the Committee’s recommendations is a firm commitment to patient safety, a key priority for Hamilton Fraser, as highlighted by our CEO, Eddie Hooker, in his recent reflections on 2025 and the year ahead.
The Bill seeks to regulate a wide range of non-surgical procedures, including dermal fillers, botulinum toxin, certain chemical peels and microneedling, and the Committee has strongly backed provisions that would make it illegal for under-18s to access these treatments.
This aligns with longstanding calls from patient safety groups, professional bodies and specialist cosmetic insurers like Hamilton Fraser for clearer safeguards in a sector that has expanded rapidly, often without consistent oversight.
A two-tiered regulatory model
The Committee has expressed support for the two-tiered regulatory approach proposed by the Scottish Government:
While the Committee broadly supports this structure, it has highlighted significant concerns around clarity, particularly regarding:
These are issues Hamilton Fraser has consistently flagged as critical for both patient safety and practitioner protection.
Support for responsible practitioners – and tougher penalties for the rest
Importantly, the Committee has acknowledged the concerns raised by clinics and practitioners who are already operating responsibly. It has called on the Scottish Government to provide clear guidance and practical support to help businesses transition smoothly into the new regulatory framework.
At the same time, the Committee has been unequivocal that current sanctions are not strong enough. It has recommended:
This dual approach recognises that the greatest risks to patients – and to the reputation of the sector – come from those who choose to operate outside any framework.
Enforcement and training under scrutiny
The Committee has also raised concerns about whether Healthcare Improvement Scotland (HIS) currently has the capacity and resources required to enforce the Bill effectively. It has called for assurances that additional funding will be made available so the legislation can be enforced properly from the outset.
Training standards have also come under the spotlight. The Committee highlighted the huge variability in qualifications and education across the sector and has called for the development of clear, appropriate and consistent standards for all practitioners.
What this means for aesthetic practitioners
While the Bill has not yet become law, the direction of travel is now unmistakable and could signal what is ahead in England.
For practitioners, clinic owners and business directors, this means:
“As regulation tightens, risks do not disappear – they change”, comments Eddie. “Liability increasingly extends beyond the treatment room into areas such as compliance, supervision, training oversight and business management.”
Hamilton Fraser’s perspective
Commenting on the Committee’s report, Hamilton Fraser Founder and CEO Eddie Hooker said: “This report reinforces what many responsible practitioners already understand, that regulation is coming, and that patient safety must sit at the centre of any framework. What’s crucial now is clarity. Practitioners need clear guidance, realistic timelines and proportionate enforcement, alongside robust penalties for those who continue to operate irresponsibly. Done properly, regulation can raise standards and protect both patients and practitioners alike.”
Staying informed and protected
Hamilton Fraser has supported aesthetic practitioners through every major regulatory shift over the past three decades. As Scotland moves closer to statutory regulation, staying informed and insured has never been more important.
For the latest regulatory news, visit the Hamilton Fraser Content Hub.
To learn more about specialist insurance for aesthetic practitioners and how regulation impacts your cover, contact the team on 0800 63 43 881. Alternatively, get a quote with Hamilton Fraser online today.
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