Scottish Government Confirms Legislation to Regulate Non-Surgical Cosmetic Procedures Following Consultation
The Scottish Government has published its formal response to the public consultation on the regulation and licensing of non-surgical cosmetic procedures, confirming it will introduce legislation aimed at improving safety and oversight in the aesthetics sector.
Following detailed feedback from over 2,200 respondents, the government will move ahead with a dual licensing system and a three-tier classification of procedures based on risk. The regulatory framework will be introduced through both secondary and primary legislation during the current session of Parliament.
Three-tier procedure classification
The finalised model maintains the proposal to group procedures by risk and clinical complexity:
Group 1: Lower-risk procedures such as microneedling and superficial chemical peels. These will be permitted in licensed premises regulated by local authorities, with mandatory licences for both the premises and the practitioner. Clinics regulated by Healthcare Improvement Scotland (HIS) will be exempt from these requirements.
Group 2: Intermediate-risk procedures, including mesotherapy and injections of toxins or semi-permanent fillers. These must be performed in HIS-regulated clinical settings, either by healthcare professionals or by trained non-healthcare practitioners working under direct supervision. Supervision requires a qualified professional to assess the client's suitability and remain on-site during the procedure.
Group 3: Higher-risk interventions such as deep peels, platelet-rich plasma injections, thread lifting, and lipolysis injections. These will only be allowed in HIS-regulated settings and must be carried out by an appropriately trained healthcare professional.
Planned legislation and timeline
Two key legislative instruments will be used:
A statutory instrument under the Civic Government (Scotland) Act 1982 will create a licensing scheme for premises offering Group 1 procedures. This will be laid before the end of 2025.
A Non-surgical Cosmetic Procedures Bill, announced in the 2025–26 Programme for Government, will be introduced in autumn. This will restrict Group 2 and 3 procedures to clinical settings, introduce age limits (set at 18), and provide for enforcement powers and future regulatory flexibility.
The Scottish Government flagged the UK Internal Market Act 2020 as a potential obstacle to enforcing certain standards, particularly in relation to mandatory qualifications and professional restrictions. Ministers intend to cooperate with UK counterparts to resolve any jurisdictional issues.
Consultation responses showed a clear divide. Healthcare professionals advocated for stricter controls, particularly for injectables, while many non-clinical practitioners expressed concern over the burdens of HIS regulation and the risk of driving procedures underground.
The government will engage further with HIS and local authorities to finalise implementation plans and support businesses in adapting to the new requirements. Guidance and impact assessments for equalities, children’s rights, and small businesses will follow in due course.
This legislative package represents the most comprehensive effort to date to regulate non-surgical cosmetic procedures in Scotland, aiming to raise safety standards while preserving access to aesthetic services in both clinical and commercial settings.
