Scottish Government publishes Non-Surgical Procedures Bill

The Scottish Government has introduced legislation to restrict a defined set of non-surgical procedures to clinical premises and to ban their provision to under-18s. The Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill was lodged at Holyrood on 8 October 2025.

The Bill creates two core offences: providing a covered procedure to a person under 18, and providing a covered procedure outside “permitted premises”. It also sets out age-verification defences and gives ministers wide regulation-making powers to add detail later.

Schedule 1 lists the procedures brought into scope now. These are ablative laser treatment, cellulite subcision, chemical peels that penetrate deeper than the epidermis, dermal micro-coring, any injectable procedure other than tattooing, any intravenous procedure, microneedling at depths of 1.5 mm or more, and thread lifts.

“Permitted premises” are defined as independent hospitals registered with Healthcare Improvement Scotland, independent clinics registered with HIS where services are provided or managed by a listed prescriber, certain NHS dental and GP premises named in contracts, and registered pharmacies. Dwellings and care homes are expressly excluded.

Enforcement provisions include powers of entry, search and seizure, with warrants available to authorised HIS officers. Obstructing an authorised person is an offence. Convictions for the main offences carry a maximum fine at level 5 on the standard scale.

The Bill allows ministers to update Schedule 1, refine what counts as permitted premises, and impose further requirements through affirmative regulations. Commencement will be by ministerial regulations after Royal Assent. The short title in the Bill indicates an Act of 2026.

The text does not lay out the often-discussed “Group 1, 2 and 3” model, nor does it hard-code qualification, supervision or training rules. Those matters are left to later regulations using the powers in section 5.

Government impact assessment and the wider plan

The Business and Regulatory Impact Assessment, published alongside the Bill, explains that ministers intend a graduated model. Lower-risk procedures would sit in a local authority licensing scheme, while higher-risk procedures would be restricted to HIS-regulated settings, with Group 2 potentially delivered by non-medics under supervision and Group 3 restricted to appropriate healthcare professionals. Midwife independent prescribers are to be included in the list of appropriate professionals, reflecting feedback since consultation.

The BRIA sets out staged implementation. Place-based restrictions and the 18-plus rule would come first, with training and qualification standards to follow in secondary legislation. It notes enforcement by HIS and local authorities, and records that penalties will be set at level 5, currently £5,000. It also flags interactions with the UK Internal Market Act that ministers intend to work through before finalising supervision and competency rules.

What this means for providers

If passed as introduced, any provider offering a Schedule 1 procedure would need to work from permitted clinical premises. That would capture, for example, all injectable and intravenous procedures, deeper chemical peels, ablative lasers, thread lifts, microneedling at 1.5 mm or more, and dermal micro-coring. Offering these in a salon, home setting or mobile environment would be an offence once commencement regulations take effect.

The Government’s impact assessment signals that a separate licensing scheme is still planned for other non-surgical procedures outside Schedule 1, with details to be set out later. The intention is to give businesses time to adapt and to align new rules with healthcare and medicines regulation.

The Bill now enters Stage 1 scrutiny, after which ministers can bring forward regulations to flesh out supervision, competency and any licensing elements. The Delegated Powers section makes clear that changes to the Schedule or to the definition of permitted premises will require the affirmative procedure.