Section 180: cosmetic licensing in England
What is Section 180?
Section 180 of the Health and Care Act 2022 is an enabling power. It gives the Secretary of State for Health and Social Care the authority to make regulations that would:
- Prohibit individuals from carrying out specified cosmetic procedures in the course of business without a personal licence
- Prohibit premises from being used for specified cosmetic procedures in the course of business without a premises licence
The Act received Royal Assent in April 2022, and Section 180 has been in force since 1 July 2022. It is an enabling power: the detailed licensing requirements would need to be set by regulations for specified procedures in England.
What counts as a cosmetic procedure?
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 of procedure:
Use horizontal scrolling to view the full table.
| Category | What it covers | Examples |
|---|---|---|
| (a) Injection of a substance | Any substance injected for cosmetic purposes | Botox, dermal fillers, fat-dissolving injections, PRP, polynucleotides, biostimulators, mesotherapy |
| (b) Application of a substance penetrating the epidermis | Substances applied to the skin that penetrate into or through the outer layer | Chemical peels, skin needling with active ingredients, transdermal delivery |
| (c) Insertion of needles into the skin | Needle-based procedures for cosmetic purposes | Microneedling, mesotherapy, semi-permanent makeup |
| (d) Placing of threads under the skin | Thread-based procedures | PDO, PLLA, and PCL thread lifts, barbed threads |
| (e) Application of light, electricity, cold or heat | Energy-based devices for cosmetic purposes | Laser hair removal, IPL, radiofrequency skin tightening, cryolipolysis, HIFU |
This definition is deliberately broad. It supplies the categories from which a future England scheme could specify procedures; it does not itself make every listed procedure subject to a licence. Surgical and dental procedures are explicitly excluded.
How a future licensing scheme could work
The Act permits regulations to create a framework for two types of licence:
Personal licence
A licence granted to an individual authorising them to carry out specified cosmetic procedures. The regulations would specify which procedures require a licence and the conditions attached.
Premises licence
A licence for the premises from which cosmetic procedures are carried out. Before granting a premises licence, the regulations may require the premises to be inspected.
If regulations create the scheme, licences would be issued by local authorities. The Act specifies which bodies count as local authorities for this purpose, including county councils, district councils, London borough councils, and combined authorities.
What Schedule 19 adds
Schedule 19 of the Act sets out what the regulations may include. This is significant because it shows the enforcement framework Parliament already approved:
- Licence conditions — local authorities can attach conditions; regulations can mandate specific conditions
- Duration, renewal, variation, suspension, revocation — the full lifecycle of a licence
- 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 costs
- Guidance — local authorities must have regard to guidance published by the Secretary of State
Current status (reviewed August 2026)
Section 180 is a power to make regulations; it does not itself license a practitioner or premises. The DHSC consultation response, updated on 7 August 2025, sets out policy proposals rather than a live licensing scheme.
The response says the government will prioritise work on restrictions for procedures considered highest risk, while continuing work on local-authority licensing for lower-risk procedures. It does not itself set a commencement date, prescribe a complete operative list of procedures, or create a personal or premises licence.
Any operative scheme would be made through secondary legislation. Check the official DHSC material and the relevant local authority before treating a proposal, a risk category or a consultation response as a current legal requirement.
Separate Scottish position
Section 180 is an England-only enabling power. Scotland has a separate legislative process; see the related Scotland update for that distinct framework rather than treating this article as a UK-wide licensing rule.
Who could be affected by future regulations
- Aesthetic practitioners — individuals carrying out procedures specified in future regulations could need a personal licence
- Clinic owners — premises used for specified procedures could need a premises licence
- Local authorities — the Act identifies the authorities that could issue licences and enforce regulations in their area
- Practitioners using energy-based devices — light, electricity, cold and heat appear in the statutory definition, but regulations would still need to specify any affected procedure
What to watch next
- Any published draft regulations or consultation from DHSC
- The specific procedures that regulations would classify or specify
- The education, training, and qualification requirements attached to licences
- The fee structure for licences
- The transition period for existing practitioners
We will update this article when official regulations, a consultation or a commencement date are published.