Government outlines plans to restrict cosmetic procedures in England

The proposals, set out in a consultation published by the Department of Health and Social Care (DHSC), would limit the performance of certain high-risk cosmetic and wellbeing procedures to specified healthcare professionals, while also introducing age restrictions and a new enforcement regime designed to improve consumer protection.

Under the new rules, high-risk procedures, including certain injectable and intravenous treatments and energy-based treatments, would only be permitted when carried out by appropriately qualified healthcare professionals. Cosmetic surgery procedures, including high risk treatments such as Brazilian butt lifts (BBLs), would be restricted to doctors only.

The consultation also proposes a blanket prohibition on in-scope procedures being carried out on people under the age of 18, except where treatment is provided through the NHS or is required to treat a medical condition.

“The consultation strikes a sensible balance,” said Louise Fullwood, healthcare and life sciences expert at Pinsent Masons.

“The proposals create a list of high-risk procedures which can now only be carried out by listed healthcare professionals but take a less stringent approach to anti-wrinkle treatments, such as Botox, and lower risk facial fillers. The proposals suggest hat these would not need to be restricted to healthcare professionals, but that a licensing scheme should be introduced.”

“This will be a relief to the many experienced and reputable providers of such services who are not healthcare professionals, whilst improving protection for members of the public obtaining these services from non-healthcare professionals,” she said.

Previous proposals had prompted fears among smaller operators that requirements for formal oversight by qualified healthcare professionals could make it economically unviable for them to continue providing lower-risk treatments.

The latest consultation proposes significant enforcement powers designed to deter non-compliance. Service providers and registered managers could commit a criminal offence if they allow an in-scope procedure to be carried out by an unauthorised individual or a person under the age of 18.

Those offences would be punishable on summary conviction by an unlimited fine. As an alternative to prosecution, the regulations would also introduce fixed penalties of £4,000 for service providers and £2,000 for registered managers.

The Care Quality Commission (CQC) would be responsible for taking enforcement action against providers that fail to comply with the new requirements.

The consultation also highlights the importance of cooperation across the UK, at a time when Scotland is developing its own regulatory regime. The Scottish Parliament’s Non-Surgical Procedures and Functions of Medical Reviewers (Scotland) Act 2026 received Royal Assent in May, although its principal provisions are yet to come into force.

The Scottish framework makes it an offence to provide in-scope procedures outside of certain registered premises whose services are “provided or managed” by specified individuals such as doctors or dentists. Any procedure that pierces or penetrates an individual’s skin and is included in a specified list is included. That list includes injectable procedures such as dermal fillers and anti-wrinkle injections, chemical peels, ablative laser treatment, microneedling and dermal microcoring.

Power is given to the Scottish ministers to make regulations imposing further restrictions and requirements, including specifying who may provide or supervise the provision of in-scope procedures.

Fullwood said: “The reference to procedures being ‘managed’ by a specified person is interesting. Does that mean the treatment can actually be administered by someone who is not qualified? The inference might be that ‘managed’ suggests an element of supervision, but that is not altogether clear at this stage and could point to an area of regulatory misalignment, although this may be clarified by further regulation.”

“Alignment will be critical for consumer protection, as will effective enforcement to keep rogue actors at bay,” she added.

The consultation is open until 7 January 2027.