Facial aesthetic treatments, including the use of botulinum toxin (Botox), have become increasingly popular and widely accessible in recent years. Alongside rapid growth in new technologies and treatment options, the sector has expanded beyond specialist clinics.
However, with minimal regulation, this expansion has brought a rise in unskilled practitioners operating in inadequate premises, and growing concerns about patient safety. Media reports of serious harm highlight the risks, and many GPs will be familiar with patients presenting with complications from such procedures.
In response, governments in England and Scotland have led public consultations on proposed new regulations to address these issues. This article reviews the current challenges and outlines what GPs need to know about the potential changes ahead.
‘Wild-west’ market in facial aesthetics
The UK facial aesthetics market has expanded at remarkable speed, with an estimated 16,000 businesses now providing non-surgical cosmetic procedures. Yet, legislation has failed to keep pace and MPs have described the industry as a “Wild West”, reflecting the absence of consistent safeguards for patients.
At present, there are no common standards for training, qualifications, or infection control, and there is no legal requirement for practitioners to be qualified before administering treatments such as Botox or dermal fillers. Voluntary registers and organisations such as Save Face, the Joint Council for Cosmetic Practitioners (JCCP) and Health Education England set their own recommended standards and encourage insurance cover, but compliance remains optional.
Regulatory scrutiny of unlicensed practitioners is minimal, and the powers available to enforcement bodies are limited. As a result, unsafe practice can go unchecked, leaving patients at risk, with few reliable routes for redress if they experience complications.
Current regulations for non-surgical aesthetic procedures
Any qualified healthcare professionals involved in the facial aesthetics industry are of course bound by the rules of their regulatory bodies such as the General Medical Council (GMC) or General Dental Council (GDC). These cover professional indemnity, working within competence, obtaining valid consent, and ensuring patients are fully informed. The GMC’s updated cosmetic interventions guidance (December 2024) also emphasises recognising patient vulnerabilities and marketing responsibly.
A key point of concern is that unqualified practitioners may also legally establish businesses to administer non-surgical aesthetic procedures, such as Botox and dermal fillers. The few relevant restrictions on their practice relate to the supply of prescription-only medicines, advertising, and the general safety of premises.
When prescription-only medicines, such as Botox, are supplied, GMC guidance states that the prescriber must have adequate knowledge of the patient’s health, physically examine them, and be satisfied that treatment is appropriate before prescribing. Advertising of prescription-only medicines is also strictly regulated. Yet in practice, these requirements are poorly enforced, and unlicensed providers often operate with little scrutiny. Crucially, the prescribed medicines for non-surgical cosmetic procedures can be legally administered by unregistered and untrained practitioners.
Risks to public safety and calls for change
Concerns over patient safety in the facial aesthetics industry have grown amid a rising number of complications and well-publicised cases of botched Botox and dermal filler treatments. The Chartered Trading Standards Institute (CTSI) has warned that unregulated aesthetic procedures could be “putting lives in danger”.
Many GPs are now treating patients harmed by cosmetic interventions, adding to the pressures on already overstretched general practice. Complications can be severe, ranging from infection to nerve injury and blindness. Care is often complicated because patients may not know what products were used or cannot provide details of the procedure, forcing GPs to liaise with the original practitioners and act as advocates to protect patients from further harm.
The significant risks to public safety have driven calls for urgent reform and stronger regulatory oversight.
Government consultations over new regulatory proposals
Proposed regulations in England
In response to the concerns, the government launched a consultation in 2023 on the licensing of non-surgical cosmetic procedures in England, receiving nearly 12,000 responses. The consultation proposed a new three-tier system to classify procedures according to risk, taking into account complexity, invasiveness, and potential complications.
Green procedures:
- Lowest risk; could be performed by all practitioners who meet agreed standards.
- Suggested procedures include microneedling, ‘no needle’ fillers, and non-ablative laser hair removal.
Amber procedures:
- Moderate risk; could be undertaken by non-healthcare professionals only if licensed and working under the oversight of a named regulated healthcare professional with accredited qualifications. Regulated healthcare professionals would be permitted to perform amber procedures independently, provided they meet the required standards.
- Suggested procedures include Botox injections, semi-permanent dermal fillers injected into the face only, and biorevitalisation injections and/or any injection of hyaluronic acid.
Red procedures:
- Highest risk; would be restricted to suitably qualified and regulated healthcare professionals and subject to Care Quality Commission (CQC) regulation.
- Suggested procedures include thread lifting procedures, dermal fillers into the breasts, buttocks or genitals, deeper chemical peels, and all intravenous injectables and infusions.
Two separate regulatory mechanisms were proposed: a local authority-administered licensing scheme (covering green and amber procedures), and an extension of CQC regulation to include red procedures.
The proposals also included prohibiting licensed procedures on people under 18, unless approved by a GMC-registered doctor and performed by a specified healthcare professional, aligning with the existing Botulinum Toxin and Cosmetic Fillers (Children) Act 2021.
The consultation found broad support for stronger regulation to enhance public safety. Yet, it also highlighted the complexity of developing a proportionate system, particularly in defining risk categories. Further work is therefore required to finalise the standards.
Restrictions on the highest-risk (red) procedures will be prioritised, with a further public consultation expected in 2026 before the new regulations are presented to Parliament. Work will also continue to develop the proposals for licensing of amber and green procedures before further consultation.
Proposed regulations in Scotland
The Scottish government has also announced plans to strengthen regulation of non-surgical cosmetic procedures, following a 2024 public consultation. Under similar proposals to those in England, a minimum age of 18 would apply, and treatments would be regulated according to risk category:
- Group 1 procedures (e.g. microneedling, non-ablative lasers) will require both premises and practitioner licences from local authorities.
- Group 2 procedures (e.g. Botox, fillers) must be supervised by qualified healthcare professionals in settings regulated by Healthcare Improvement Scotland (HIS).
- Group 3 procedures (e.g. breast or buttock augmentation) must be carried out in HIS-regulated facilities and performed by qualified healthcare professionals.
The Non-surgical Cosmetics Procedure Bill, covering groups 2 and 3, will be introduced in autumn 2025. If passed, the regulations may be phased in from 2026 in Scotland, setting a precedent for UK-wide regulation.
What the proposals mean for GPs
For GPs, these proposed changes have several implications, although it will be important to review the final details once the regulations have passed Parliamentary scrutiny. The hope is that future implementation of tighter regulations will improve patient safety, leading to fewer complications and easing pressure on GP services.
Any GP involved in prescribing or administration of aesthetics treatments must always follow the GMC guidance. However, the potential role of regulated healthcare professionals in overseeing amber procedures makes it likely that more GPs will become directly involved in supervision within the aesthetics sector. They may need to complete additional training to ensure they are competent to perform this role.
GPs may also be called upon to advise patients considering treatments, provide information on safe providers, or liaise with regulators when concerns arise. GPs should remain aware of the evolving regulatory landscape, both to support patient safety and to fulfil their role as advocates when things go wrong. As always, GPs must clearly document their consultations with patients regarding facial aesthetics and any prescription of Botox. This could provide crucial evidence if a patient is harmed and wishes to make a complaint or seek compensation.
GPs also need appropriate indemnity to cover the full scope of their practice, including any changes that may occur as the regulations change.
Caution advised until new regulations take effect
While the measures are being developed, GPs should urge any patient considering a cosmetic procedure to check the provider’s qualifications and insurance, and to ensure they are receiving products licensed for use in England. The NHS website has information about to guide patients in choosing a cosmetic procedure.
New licensing rules and government reforms will reshape how Botox and fillers are delivered. For GPs, that means new responsibilities and new risks. Medical Defense Society is here to help you navigate the changes with clear, tailored indemnity and medico-legal guidance.
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