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Section 180 Health and Care Act: cosmetic procedure licensing UK

Published 2 July 2026 · Updated 2 July 2026

Summary: Section 180 of the Health and Care Act 2022 gives the Secretary of State power to introduce licensing for non-surgical cosmetic procedures in England. This article explains what the law actually says, what procedures it covers, who it affects, and where the scheme stands today.

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. However, the regulations that would actually create the licensing scheme have not yet been made. The power exists — the detailed scheme is still being developed.

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:

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 covers most non-surgical cosmetic procedures performed in the UK today. Surgical and dental procedures are explicitly excluded.

How the licensing scheme would work

The Act creates 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.

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 (July 2026)

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

September-October 2023: DHSC held a public consultation on the design of the licensing scheme
August 2025: The government published its consultation response, setting out proposed categories (green, amber, red) and next steps
January 2026: The Health Minister confirmed the government is working on proposals for the highest-risk procedures and intends to consult on draft legislation
June 2026: The government stated it is "preparing a consultation on the draft legislation" that would bring the proposals into effect

The regulations will be made through secondary legislation, which means they will not require a full parliamentary bill — the primary legislative foundation (Section 180) is already in place.

How Scotland compares

Scotland is ahead on implementation. The Non-Surgical Procedures and Functions of Medical Reviewers (Scotland) Bill passed Stage 1 in March 2026, with full enforcement expected by September 2027. While structurally similar, Scotland's law follows its own legislative process under the Scottish Parliament.

Who this affects

Aesthetic practitioners — anyone performing Botox, fillers, laser, microneedling, thread lifts, or other non-surgical cosmetic procedures will need a personal licence
Clinic owners — premises where cosmetic procedures are carried out will need a premises licence
Online pharmacies offering weight-loss services — many online pharmacies offer cosmetic-adjacent services that may be affected
Local authorities — every local authority in England will become a licensing and enforcement body for cosmetic procedures
Practitioners using energy-based devices — laser, IPL, radiofrequency, and other energy-based treatments are explicitly included in the definition

What to watch next

The promised consultation on draft legislation — expected later in 2026
The specific procedures classified as green, amber, or red risk categories
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 as the regulations progress.

Sources

Disclaimer: This article is for informational purposes only and does not constitute legal advice. Clinics and practitioners should seek independent legal advice for their specific circumstances.