Cosmetic procedure licensing UK: the complete guide

Last updated: 3 July 2026

What is cosmetic procedure licensing?

Cosmetic procedure licensing is a proposed regulatory scheme for non-surgical cosmetic procedures in England. It would require two types of licence:

• A personal licence — for individuals carrying out specified cosmetic procedures
• A premises licence — for premises where these procedures are performed

Both licences would be issued and enforced by local authorities. The scheme is designed to address a long-standing gap in UK regulation: unlike most healthcare activities, there are currently no specific requirements for who can perform non-surgical cosmetic procedures such as Botox injections, dermal fillers, laser hair removal, and microneedling.

Scotland is implementing its own version of the scheme and is further ahead in the legislative process. This guide covers both, with a focus on what practitioners and clinic owners need to know.

The Health and Care Act 2022, Section 180

Section 180 of the Health and Care Act 2022 is the legal foundation. It gives the Secretary of State for Health and Social Care the power to make regulations that would:

• Prohibit individuals from carrying out specified cosmetic procedures without a personal licence
• Prohibit premises from being used for specified cosmetic procedures without a premises licence

The Act received Royal Assent in April 2022 and Section 180 has been in force since 1 July 2022. The power to make regulations exists — what hasn't happened yet is the detailed secondary legislation that would create the actual licensing scheme.

Because the scheme would be introduced through secondary legislation, it does not require a new Act of Parliament. The primary legislative foundation is already in place. This is a faster process than passing a new bill, which is why the Scotland bill is advancing through a separate but parallel track.

What procedures are covered?

The Act defines a cosmetic procedure as:

"A procedure, other than a surgical or dental procedure, that is or may be carried out for cosmetic purposes."

The definition explicitly includes five categories. This table shows what each covers and examples:

This definition is deliberately broad. It covers most non-surgical cosmetic procedures performed in the UK today. Surgical and dental procedures are explicitly excluded. The government has indicated that specific procedures will be classified into risk categories (green, amber, red) within the regulations rather than the primary legislation.

Schedule 19 — enforcement framework

Schedule 19 of the Act sets out what the licensing regulations may include. Parliament has already approved the enforcement framework:

• Licence conditions — local authorities can attach conditions; regulations can mandate specific conditions
• Duration, renewal, variation, suspension, revocation — the full lifecycle management of licences
• Reviews and appeals — a mechanism for challenging decisions
• Criminal offences — regulations can create offences for breaching a prohibition, breaching a licence condition, or providing false information. These are punishable on summary conviction with a fine
• Financial penalties — local authorities can impose fines through a notice-of-intent and final-notice process, with a right of appeal
• Enforcement — local authorities have the function of enforcing regulations in their area
• Fees — regulations may provide for fees covering enforcement and inspection costs
• Guidance — local authorities must have regard to guidance published by the Secretary of State

Key insight: The enforcement infrastructure is already legislated. When the regulations come into force, every local authority in England becomes a licensing and enforcement body for cosmetic procedures. That is approximately 300 local authorities with no shared system — a significant administrative undertaking.

The three-tier system: green, amber, red

The government's August 2025 consultation response proposed a three-tier classification system for cosmetic procedures:

The specific procedures in each category have not yet been confirmed. The government has said it will prioritise the highest-risk procedures (red category) first. The amber and green categories would follow through the licensing scheme administered by local authorities.

This three-tier system reflects the reality that cosmetic procedures range from low-risk treatments (basic skin treatments) to high-risk interventions that should only be performed by medical professionals. The scheme is designed to match the level of regulation to the level of risk.

Scotland's licensing law

Scotland is ahead of England on implementation. The Non-Surgical Procedures and Functions of Medical Reviewers (Scotland) Bill passed Stage 1 in the Scottish Parliament in March 2026. Full enforcement is expected by September 2027.

The Scotland bill is structurally similar to the England proposals:

• Personal and premises licensing
• Local authority enforcement
• Minimum training and qualification requirements
• Age restrictions mirroring the Botulinum Toxin and Cosmetic Fillers (Children) Act 2021

Key differences: Scotland's bill creates a Medical Reviewer function (not proposed in England) and follows Scottish Parliament legislative procedure rather than UK secondary legislation. Practitioners operating in Scotland should track the bill's progress through Stages 2 and 3.

For practitioners operating across both jurisdictions: you will likely need separate licences for England and Scotland. The schemes are aligned in principle but administered separately.

Current status — July 2026

As of July 2026, the licensing regulations for England have not yet been made. Here is where things stand:

• July 2022: Health and Care Act receives Royal Assent. Section 180 comes into force, granting the power to make licensing regulations.
• September-October 2023: DHSC holds a public consultation on the design of the licensing scheme.
• August 2025: Government publishes consultation response, setting out the three-tier green/amber/red system and confirming the intention to proceed.
• January 2026: Health Minister confirms the government is working on proposals for the highest-risk procedures and intends to consult on draft legislation in spring 2026.
• June 2026: Government states it is "preparing a consultation on the draft legislation." The Scotland bill passes Stage 1.

The direction of travel is clear but the timeline remains uncertain. The government has consistently confirmed its intention to proceed, but has not set a firm date for publishing the draft regulations.

Timeline and what to expect

Based on the government's statements and the legislative process, the expected sequence is:

1. Consultation on draft legislation (expected late 2026) — the government will publish its detailed proposals for the red (CQC-regulated) procedures first.
2. Secondary legislation laid before Parliament (2027) — the regulations will be debated and approved through the parliamentary process.
3. Implementation and transition period (2027-2028) — existing practitioners will likely have a grace period to obtain licences.
4. Full enforcement (2028+) — all practitioners and premises must hold appropriate licences.

Scotland's timeline is more defined: Stage 1 passed March 2026, with full enforcement expected by September 2027. This means Scotland will likely be operational 12-18 months before England.

Clinics and practitioners should not assume the scheme will be delayed indefinitely. The legislative foundation exists, the consultation is complete, and the government has confirmed its commitment. The practical question is not if licensing will happen, but when.

Frequently asked questions