NHBF Member update: Scottish Government to introduce aesthetic procedures regulation

Non-surgical Cosmetic Procedures Bill confirmed

The NHBF is pleased to inform our Members that the Scottish Government has officially confirmed plans to introduce a Non-surgical Cosmetic Procedures Bill as part of their 'Programme for Government 2025-26: Building The Best Future For Scotland', published on May 6th.

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This significant development marks an important step toward improving standards and safety across the aesthetics sector in Scotland, with potential implications for the wider UK beauty sector.

What the Bill will cover

The forthcoming legislation will:

• Regulate the delivery of certain non-surgical procedures offered for cosmetic or lifestyle purposes
• Enhance safety measures for clients undergoing these procedures
• Require specified procedures to be delivered only in suitable premises registered with appropriate bodies
• Establish provisions to enforce appropriate standards for service providers

The Bill will be introduced to Scottish Parliament before May 2026, with more information becoming available as it progresses through the legislative process.

Background: the consultation process

This announcement follows the Scottish Government's consultation on a licensing scheme for non-surgical aesthetic procedures, which ran from December 20, 2024, to February 14, 2025.

Similar to the previous consultation in England (September-October 2023), the Scottish proposal categorized procedures into three risk-based groups:

NHBF response to the consultation

It's important to note that the NHBF expressed concerns during the consultation about the proposed classification of certain procedures, particularly:

• The requirement for healthcare professional oversight for relatively low-risk procedures like Cryolipolysis, mesotherapy, HIFU and radiofrequency
• The reclassification of procedures traditionally performed by advanced beauty therapists (such as electrolysis) as medical-only procedures

The consultation response reflects feedback from our Members and has also been developed in collaboration with key sector organisations through the Beauty Industry Group (BIG) and BIAE (British Institute and Association of Electrologists).

• The grouping of the procedures in Group 1 are typical advanced beauty treatments with minimal or no risk.
• We feel if the practitioner is qualified (via a regulated Ofqual qualification) and experienced, there would be no need for supervision. Therefore, Group 2 cannot be used as a “Catch all”.
• We agree there needs to be oversight when a POM (Prescription Only Medicine) or medical device is required only.

• There need to be a further breakdown of the Group 2 category:

  • based on risk

  • scope of the procedure

  • technology used

  • practicality of achieving a level of medical oversight

  • immediate medical intervention (complications training) required

Examples include:

Defining the scope of the technology: High/radio frequency (range 3kHz–300GHz), low intensity LED light (below 500mW), as detailed in the apprenticeship standard.

We would support robust complications training via a regulated Ofqual qualification, which should be a mandatory requirement for all practitioners delivering aesthetic procedures.

We feel there is no need to develop training standards for these procedures, as they already exist through the Occupational Maps and Apprenticeship Standards, and are overseen in England by IfATE. Currently, there are five IfATE-approved Apprenticeship Standards and two standards in development.

Currently, the Beauty Professional Apprenticeship Steering Group are developing a Skin Rejuvenation Apprenticeship Standard at Level 5, which has recently been approved and is awaiting funding allocation, with a progression route into aesthetics at level 7.

Wider context and future outlook

This Scottish initiative comes amid ongoing efforts to regulate the aesthetics industry across the UK:

• The British Beauty Council and other industry bodies have long advocated for tighter regulations
• The Botulinum Toxin and Cosmetic Fillers (Children) Act was successfully implemented in 2021
• A consultation on UK-wide regulation was conducted in 2023, though progress has since slowed
• The Nursery and Midwifery Council recently banned remote prescribing of injectable cosmetic products across the UK from June 1st

Currently, Wales and Northern Ireland have not announced similar regulatory plans.

NHBF position and support

"The NHBF welcomes the Scottish Government's commitment to establishing a robust regulatory framework for non-surgical aesthetic procedures," says Caroline Larissey, Chief Executive of NHBF.

"While we support measures that enhance client safety, we believe regulation must be evidence-based and proportionate to actual risks. Our members are highly trained professionals who should be recognised for their expertise in delivering many of these treatments safely."

Jo Lancaster, Quality and standards Manager – Beauty and Aesthetics, adds: 

"We're particularly focused on ensuring that the final legislation acknowledges the extensive training and qualifications held by beauty professionals. The NHBF has developed a comprehensive qualification and age restriction guidance document that clearly articulates academic progression pathways from beauty therapy into aesthetics. It is essential that there is no occupational bias against professionals entering the aesthetic industry via a beauty pathway, and that any legislation ensures fairness and equality for all practitioners regardless of their professional background.

This framework, alongside existing Ofqual-regulated qualifications, and apprenticeship standards, already provides thorough education in many of these procedures. We look forward to continuing our engagement with the Scottish Government to create a regulatory system that protects consumers while supporting skilled practitioners to thrive."

The NHBF welcomes these developments as a positive step toward enhancing industry standards and client safety. We recognise the importance of appropriate regulation while ensuring that skilled beauty professionals can continue to offer services within their competence.

We will continue to monitor the Bill's progress closely and advocate for balanced regulation that protects public safety while supporting our Members' businesses. We are committed to keeping our Members informed of developments and providing guidance as the regulatory landscape evolves.

For any questions or concerns regarding these upcoming changes, please contact the NHBF Member helpline.