On 18th March 2026, the Scottish Parliament passed the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill, which will form a new framework to regulate Non-surgical cosmetic treatments and aims to tackle client safety concerns. The Bill is expected to come into force in Scotland in September 2027, but what does this mean for those delivering aesthetics treatments in England?
Key points of the new legislation for Scotland are:
- Age Restriction: It will be illegal for under 18s to receive certain cosmetic procedures such as dermal fillers or stronger chemical peels, addressing concerns around the pressures young people face via social media to undergo procedures that may have physical or psychological impacts upon them immediately or in future.
- Approval Only for Licensed Healthcare Professionals: Only those registered with regulated UK bodies such as doctors, dentists, nurses, midwives, pharmacists, physiotherapists and other allied health professionals will be permitted to perform non-surgical procedures (or to otherwise oversee suitably qualified professionals to act under their direction to deliver treatments), within an approved premises.
- Restrictions on Premises: Procedures will only be able to be carried out in ‘permitted premises’ as defined by the Bill such as medical settings or registered clinics. It is likely mobile based therapists and the like working on a casual basis will no longer be accepted.
- Enhanced Powers: Healthcare Improvement Scotland will have new powers to inspect premises delivering non-surgical procedures and intervene where practices are found to be unsafe.
- Powers to Extend Regulations: The Scottish Government will have powers to amend the list of regulated procedures, define who can perform them, qualifications they will require to perform treatments and how compliance can be enforced.
The Scottish Bill will cover non-surgical procedures that can or will:
- pierce or penetrate skin
- not provided as part of NHS healthcare
- not delivered for medical treatment purposes
- not already licensed under the Civic Government (Scotland) Act 1982
Examples of treatments which may come under enforcement of the Scottish Bill (although this is subject to further extension once the legislation becomes law in 2027):
- Ablative laser treatment
- Stronger chemical peels that penetrate deeper than the epidermis (outer layer of skin) so considered high-risk
- Dermal microcoring
- Injectable procedure (excluding tattooing)
- Intravenous procedure
- Licensed procedure carried out with prescribed anaesthetic
- Licensed procedure carried out on an intimate area (except non-ablative laser hair removal)
- Microneedling 1.5 mm or deeper
Under the new legislation Healthcare Improvement Scotland (HIS) will have powers to:
- Enter premises non-surgical procedures are suspected of being provided illegally
- Search premises / seize equipment or records to gather evidence
- Act against unregistered premises or unauthorised practitioners
The penalties for breaking the legislation are:
- Fine up to £2,500 for unlicensed practice
- Fine up to £1,000 for failing to notify authorities of major changes in circumstances
- Additional sanctions for breaching licence terms or providing misleading information

What impact does this new Bill have for those delivering these treatments in England?
Currently there is no definite confirmed plans to introduce a similar Bill to England or Wales.
While this new legislation is a welcomed step in the right direction by many to ensure safety for clients receiving aesthetics treatments, with the beauty industry long behind other industries that have had tighter consumer protection for many years; some fear this will make it difficult for qualified non-medical beauty professionals to continue in the aesthetics industry and some critics fear it may even create pressure or demand for treatments delivered ‘underground’ outside of legislation or due to potential rising costs when such treatments become clinic-only based treatments, many clients may seek treatments overseas for a lower cost.
Until the legislation becomes law in 2027, it is hard to be sure of the exact impact of these changes and the Bill will give the Government powers to amend requirements and enforcement as they see fit.
Given that the Government in England has no confirmed plans as yet to bring in such legislation, this means there are no immediate requirements for those delivering these treatments in England to make any changes to their practice and they can continue to practice as they do currently.
It would be wise to take stock of your current business practices, ahead of expected greater client concerns and scrutiny to ensure continued client confidence in your setting and treatments; such as to:
- Look at your guidance information provided to clients to ensure it is comprehensive.
- Review practices on health and safety in your setting to ensure you are working to the highest standards.
- Review your insurance and licensing obligations to ensure you are meeting all requirements.
- Collate and provide evidence of the qualifications / credentials of those delivering treatments in your setting, recent environmental health inspections and insurance, which is available to clients / potential clients to provide reassurance of your high standards of training.
- Take opportunities to advance your training where necessary and possible, such as refresh your practical training or develop greater theoretical knowledge to best advise your clients, upskill where you can with OFQUAL regulated qualifications (if not already held). While no specific qualifications have been indicated in the Scottish Bill for non-medics currently, it may be beneficial to still complete this for your setting.








